Privacy Policy

GuildLink’s Privacy Policy

GuildLink Pty Ltd (GuildLink) is committed to protecting the privacy of the personal information, including sensitive information, which it collects, holds, uses and discloses.

1. Overview of this Privacy Policy

This Privacy Policy tells you how GuildLink (we / our / us) will handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APP), and other privacy laws and regulations which govern the way in which GuildLink may handle personal information.

We will update our Privacy Policy if the way we handle personal information changes or as required by law. Updates to our Privacy Policy will be published on our website.

2. About GuildLink

GuildLink is a wholly owned subsidiary of the Pharmacy Guild of Australia, a leading advocate for the community pharmacy industry, representing almost 5,000 pharmacies across Australia (community pharmacy).

GuildLink’s core activities and functions include the following:

a software licensor and a managed IT service provider for community pharmacies – GuildLink provides and manages a software platform, known as GuildCare, for community pharmacies which enables pharmacies to maintain prescription and dispensing information and to deliver professional services to patients and consumers;
an administrator of programs and services on behalf of the Pharmacy Guild of Australia and the Australian Government Department of Health, including ProjectSTOP and MedsAssist;
a provider of pharmacy sector data and statistics to the Pharmacy Guild of Australia for the purposes of policy and advocacy work; and
a distributor of Consumer Medicines Information (CMI) Print applications;
a provider of the myPharmacyLink app.

This Privacy Policy is divided into four parts:

Part A: relates to GuildLink consumers and patients;
Part B: relates to community pharmacy staff;
Part C: relates to visitors and users of the GuildLink website; and
Part D: provides information about our personal information handling practices that applies to all categories of individuals specified in Parts A, B and C.

Part A: Consumers and patients

Part A of our Privacy Policy explains how GuildLink handles the personal information of consumers and patients, including consumers and patients of community pharmacies that use any of the GuildLink services, including ProjectStop and MedsAssist, as well as users of the myPharmacyLink app.

In this Part A, you and your refers to consumers and patients of community pharmacies that use any of the GuildLink services, as well as patients and users of the myPharmacyLink app. Where appropriate, you and your also refers to caregivers of consumers, patients and users.

1. Collecting your Personal Information

1.1 How we collect personal information

We collect your personal information in a number of ways. We may collect your personal information from a community pharmacy, directly from you or in the course of our dealings with you, for example when you:

use a community pharmacy to fulfil a prescription or to receive a health service provided by the community pharmacy, that community pharmacy may be using the GuildLink software platform, known as GuildCare, to assist the pharmacy to maintain prescription and dispensing information about you. In managing and administering this software platform as an IT service provider, GuildLink collects, stores and has access to your personal information, including some sensitive information, collected by community pharmacies;
use a community pharmacy to retrieve dispensing information about you for CMI Print. In managing and administering CMI Print, GuildLink collects, stores and has access to your personal information, including some sensitive information, collected by community pharmacies;
directly provide personal information to us, for example, when you register, log into or use the myPharmacyLink app, enquire about our products or services, or make any general enquiry of us, subscribe to our email or other communications, provide feedback to us or otherwise interact with us;
purchase pseudoephedrine or codeine based products, a community pharmacy may require your identification and may record that personal information, if required by law;
complete a form for us; or

contact us by phone or through our website. We record all calls that are made to or from our Pharmacy Support Centre as part of a Medication Adherence, Screening or New to Therapy Program and some calls made to or from our Pharmacy Services Team, Operations Support Team and Privacy Officer.

We may also collect personal information about you from other people or organisations or publicly available sources. This may include our related entities, including the Pharmacy Guild of Australia, and:

GP and other allied health professionals, from whom we may access pathology test results and other reports and referral letters;
our service providers and contractors that perform services for us like marketing, payment fulfilment, security and fraud protection; and
publicly available information from the Pharmaceuticals Benefits Scheme and the Therapeutic Goods Administration.

1.2 Types of personal information we collect

The personal information that we collect may include:

your identity and contact details including name, address, email address, phone number and date of birth;
Medicare card details, including Medicare card number and the names of those people who may share the same Medicare card as you; and
details of dependents that you are authorised to care for, including name, date of birth and phone number.

1.3 Collecting health and other sensitive information

We also collect the following health or other sensitive information about you:

medication, prescription and dispensing information, including historical information;
information about any professional health service that you may be receiving from a community pharmacy, including professional health services coordinated by a community pharmacy but received from a third party, such as blood pressure monitoring, vaccinations recording, cholesterol monitoring, DNA tests and sleep apnoea tests;
information about any patient adherence program that you may be involved in with a community pharmacy;
information about any adverse event in relation to a medication; and
information from GP and other allied health professionals, including pathology test results and referral letters.

By providing your health information to us and your community pharmacy, you consent to us collecting your health information and using and disclosing it for the purposes set out in this Privacy Policy.

1.4 Why we collect personal information

We collect your personal information so that we can provide you and community pharmacies with our services, including the functionality and maintenance of our software platform, GuildCare, and any products that you or a community pharmacy may have requested, to contact you and to carry out our functions and activities.

The purposes for which we collect your personal information may include to:

verify your identity;
provide community pharmacies with a managed IT service provider role in relation to our software platform, GuildCare;
provide the services and functionality of the myPharmacyLink app to you;
provide information and updates on services relevant to your prescription and professional services history from your community pharmacy or from GuildLink, including advice, information, alerts, invitations and warnings;
provide marketing information relevant to your prescription and professional services history from either your community pharmacy or from GuildLink;
provide marketing information unrelated to your prescription and professional services history from either your community pharmacy or from GuildLink;
assist you to manage your health in a variety of ways by, for instance, reminding you to take your medication; telling you when you will need to refill your prescription; telling you when your prescriptions will expire; giving you important information about your medication or telling you about when your next professional service should be completed;
administer and assist in the operation of Government-provided health programs and services on behalf of the Pharmacy Guild of Australia and the Australian Government Department of Health;
provide you with information and updates relevant to your prescription and professional services history, including, advice, administrative notices, health alerts, warnings, invitations and service-related communications primarily through the myPharmacyLink app but also through voice calls, email and SMS; respond to feedback, queries and complaints; and
help us to continuously improve the services and products we offer.

2. Use and disclosure of Personal Information

We will use and disclose your personal information for the purposes described in ‘Why we collect your personal information’. If we need to handle your information for any other purpose, we will only do so with your consent or where you may otherwise reasonably expect us to do so.

We may also disclose your personal information to:

the Australian Government Department of Health, in our function of administering certain health programs and services, such as ProjectSTOP, MedsAssist, vaccinations, and medication adherence and management, for the Pharmacy Guild of Australia and the Government;
pharmaceutical, third party referral, research companies, device and other health services companies, in our function of administering certain medication programs including adherence, new to therapy, third party referral programs and screening programs. Information that is given to these organisations is with your express consent which is obtained at the time that you agree to participate in the program;
any service provider we engage to carry out our business functions and activities (to the extent reasonably necessary to do so) such as:

outsourced service providers who manage the services we provide;
our advisers (including our accountants and lawyers);
organisations involved in sending you information about our products and services or who act on behalf of community pharmacies to send you information about their products and services;
organisations jointly participating in, or assisting us to manage, a promotion, event or seminar;
organisations involved in a transfer or sale of our assets or business, including any prospective purchaser of such assets or business; and
organisations involved in managing our corporate risk;

with your consent, any third parties involved in your care, such as other health professionals involved in your further treatment including, but not limited to, general practitioners;
government departments responsible for health where GuildLink or the Pharmacy Guild of Australia is required by law to do so;
our related companies, such as, but not limited to, the Pharmacy Guild of Australia or to any of its other subsidiaries;
any entity to which we are required or authorised by or under law to disclose such information (for instance, Federal or State law enforcement agencies and investigative agencies, courts and various other Federal or State government bodies);
others that you have been informed of at the time any personal information is collected from you;
with your consent, relatives, close friends and guardians;
with your consent, research institutions and sponsors with which GuildLink collaborates; and
with your consent, to private health insurance providers and Medicare Australia.

We take steps to ensure that third party recipients are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.

If you are under the age of 16 years and you share a Medicare card with another person, whether related to you or otherwise, that person may be able to access your information held on the GuildCare database once they register with a GuildLink software platform, such as myPharmacyLink.

Part B: Community pharmacy staff

Part B of our Privacy Policy explains how GuildLink handles the personal information of pharmacists and the staff of community pharmacies that use the GuildLink services.

In this Part B, you and your refers to pharmacists and the staff of community pharmacies that use the GuildLink services.

1. Collection of personal information

We may collect basic information from you, such as your name, role, postal address, email address, phone number and date of birth directly from you or from third party sources such as the Pharmacy Guild of Australia’s database of pharmacy members.

When you call us, we will record all calls made to or from our Pharmacist Support Centre and some calls made to or from our Pharmacy Services Team, Operations Support Team and Privacy Officer. We will collect any personal information you provide during these calls.

2. Use and disclosure of personal information of community pharmacy staff

We will use your personal information to provide the GuildLink services to the community pharmacy in which you work, and in supporting and training you on the use of the GuildLink services. This may include contacting you in relation to the functionality, operation of or updates to GuildCare, or any other products or services the community pharmacy may be receiving from us, or with marketing and promotional material about our offers or promotions, and to identify products and services that may be of interest to you or the community pharmacy in which you work.

Part C: Website visitors

Part C of our Privacy Policy tells you how GuildLink handles the personal information of visitors to our website or other social media channels and other individuals, such as job applicants.

In this Part C, you and your refers to such individuals.

1. Collection of personal information

If you visit our website or any of our social media channels, we may collect your personal information if you have provided any personal information to us on the website or via our social media channels. We may also collect your IP address or MAC address.

If you apply for a position with us, we will collect the information you provide to us in relation to such application. With your consent, we may also collect information from recruitment agencies and previous employers in relation to your application. Any such information collected will be used solely to assess your application and suitability for the specific role.

2. Google AdWords Remarketing

We use Google AdWords Remarketing to advertise GuildLink across the internet, in particular on the Google Display Network, to help provide you with relevant and targeted ads.

Google AdWords remarketing will display ads to you based on the parts of the GuildLink website you have viewed by placing cookies on your web browser. Cookies are used to indicate to other websites that "This person visited a particular page, so show them ads relating to that page." This, in turn, allows us to tailor our marketing to better suit your needs and only display ads that are most relevant to you. We use cookies that only remain on your device for as long as you keep your browser active (session) and cookies that remain on your device for a longer period (persistent). You are free to block, delete or disable these technologies if your device so permits. You can manage your cookies and your cookie preferences in your browser or device settings.

These cookies do not in any way identify you or provide us with access to your computer or mobile device.

Part D: General information

Part D of this Privacy Policy provides you with general information about how GuildLink handles the personal information of all individuals in respect of which we collect personal information, as specified in Parts A, B and C above.

In this Part D, you and your refers to such individuals.

1. No overseas disclosures

All of your personal information is processed and stored in Australia. We do not share your personal information with organisations or persons located outside of Australia.

2. Access

You have a right to request access to, or correction of, the personal information that we hold about you.

If you wish to access, correct or update any personal information that we hold about you, please contact us on the details below. We will need to verify your identity before we can process your request. You may do this by attending a local pharmacy. The pharmacy can submit a request via GuildCare stating that you have been identified and that GuildLink may provide a copy of all personal information held on you.

We will respond to your request within a reasonable period of time and provide access in the manner you have requested, unless it is unreasonable or impracticable for us to do so.

Making a request is free. However, we may charge a reasonable fee for collating and providing access to your personal information. The charges will not be excessive and we'll let you know if a charge will apply before we proceed with giving you access. There is no charge for correcting your personal information.

There may be reasons why we cannot give you access to the information that you have requested, or correct your personal information. If this is the case, we will let you know these reasons in writing. If you disagree with our decision, you can make a complaint about this, by following the complaint procedures in this Privacy Policy.

3. Storage and security of your Personal Information

We store personal information in different ways, including in paper and electronic form. We use third party service providers to store some personal information. These third party service providers are located in Australia.

The security of personal information is important to us and we take reasonable steps to protect it from misuse or loss and from unauthorised access, modification or disclosure. Some of the ways we do this include:

requiring our staff to maintain confidentiality;
implementing document storage security policies;
imposing security measures for access to our computer systems;
only allowing access to personal information where the individual seeking access has satisfied our identification requirements;
ensuring there is access control into our business premises;
training our staff to keep your information safe and secure; and
having online and network security systems in place for our websites and the myPharmacy Link app, so that the information you provide us and that community pharmacies provide us online is protected and secure.

When the personal information GuildLink collects is no longer required, GuildLink will de-identify it.

4. Complaints Handling

If you have a complaint about how we have handled your personal information, you can contact us using the details below.

Once we have received your complaint, we will investigate and respond to you within a reasonable period of time. Our aim is to resolve any complaint within 10 working days of receiving the complaint. If this is not possible, we will contact you and let you know why and how long we think it will take.

We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However if you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner (in writing) at:

Office of the Australian Information Commissioner (OAIC)

GPO Box 5218 Sydney NSW 2001

Phone: 1300 363 992

TTY: 1800 620 241

email: enquiries@oaic.gov.au

5. Changes to our Privacy Policy

We may update our Privacy Policy from time to time. Our Privacy Policy was last updated in September 2017. By continuing to use our website or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

We will post all updates to our http://www.guildlink.com.au/guildlink/privacy-policy1/

Should you wish to request access to this Privacy Policy in another form please contact us on the details below.

6. GuildLink Contact Details

If you have any queries or complaints with regards to our collection, use or management of your personal information, please contact us at:

Email: privacyofficer@guildlink.com.au

Address: Privacy Officer, PO Box A284, Sydney South NSW 1235