Blooms The Chemist Privacy Policy
1. The importance of your privacy
Blooms The Chemist Management Services Ltd (ACN 003 584 718) (BTCMS Ltd/the Company) complies with the Australian Privacy Principles for the Fair Handling of Personal Information established under the Privacy Act 1988. BTCMS Ltd owns a trade mark – Blooms The Chemist’ - and it licences independently owned and operated pharmacy businesses to use the trade name (the Blooms Pharmacies). The Company and the Blooms Pharmacies together may be referred to as ‘we’ or ‘our’ in this Policy.
This Privacy Policy is designed to explain to you the sort of Personal Information that we may collect about you. It also sets out how and why we collect the Personal Information, our policies on management and storage of that material as well as how we use and disclose it and how you can access and seek correction of your Personal Information or complain about privacy matters.
2. What we may collect and hold
Personal Information is private or personal information or an opinion about a person who is reasonably identifiable from that information. The types of Personal information which we may collect and hold include:
Your name, gender, date of birth and address including email address;
• Your phone number and mobile phone number;
• Any allergies or conditions that you have;
• Your Doctor’s contact details;
• Medication that you are on;
• Your payment information if ordering online through our website;
• Your prescriptions and order history if ordering online through our website;
• The fact of you taking, and the results of the following health checks: Iron Testing, Stroke Risk Assessment, Blood Pressure Evaluation, Cholesterol Screening, Diabetes Monitoring, and Sleep Apnoea Testing (Health Checks);
• Your use of the My HealthRewards @ Blooms The Chemist Program, including the number and results of Health Checks taken by you;
• Your opinion/preferences about specific products and services;
• Communications between you and us; and
• Transactional information about your use of our products and services.
You consent to us collecting your Personal Information which is specialised information relevant to your health and medical history when our products and services require that information including, but not limited to, for the purposes of determining your entitlement to rewards points under the My HealthRewards @ Blooms The Chemist Program.
3. Storage and Management of Your Personal Information
Personal Information in digital format (i.e. computer records) is stored on servers located within Australia. Blooms The Chemist’s Pharmacies take active steps to secure the Personal Information which they hold as well as to keep this information accurate and up to date. The Blooms Pharmacies and the Company apply a range of technologies (including access control passwords and procedures, differentiated according to authority, network firewalls, encryption and physical security) to protect your privacy.
Documents containing Personal Information are filed in secure storage facilities until they are no longer required and may be securely disposed of. In many instances a copy of the material is saved to a digital format and the original document is then securely destroyed. . Company and Blooms Pharmacy employees and consultants are obliged to preserve the confidentiality of personal information that they deal with.
Visitors to the website who are not account holders with a Blooms Pharmacy may have anonymous information about their browsing noted. This helps us to understand what our customers want and to make sure we have it available. We sometimes use “cookies” (if your computer settings allow it) to track websites browsed by you. Again, this is aimed at optimising our service to you so, if you disable the cookies, you may not get the best out of our website.
A similar situation applies when you access our Facebook page or other digital properties where we may note anonymous information which tells us about online behaviour, but not your identity.
The online chat function on the website is provided by a third party and uses cookies to enable the online chat services. Data collected through the online chat may be used by us for providing support services, connecting your query with your online account and any online orders you have placed as well as collecting information to help us improve our online services.
Importantly, apart from needing the Personal Information at your chosen Blooms Pharmacy so as to provide a better service to you and to comply with our reporting requirements with government, your Personal Information is rendered anonymous before it is used by the Company or the Blooms Pharmacy for any analysis by us. In other words, it will no longer be Personal Information. This means that the reports we prepare will not identify you or attribute or associate any information or characteristics specifically to you, nor will it assist in doing so.
4. How we collect it
The Blooms Pharmacies and/or the Company collect Personal Information about you in two ways:
• When you provide us with your details at a Blooms Pharmacy (including when you undertake Health Checks) or through our website.
• Within Blooms Pharmacies when purchasing products or filling scripts.
5. Why we collect Personal Information
We collect Personal Information about you so that we can provide you with a better service including ensuring wherever possible that we have enough of the right stock on hand. We also collect Personal Information for the purposes of the My HealthRewards @ Blooms The Chemist Program, including to determine your eligibility to earn rewards points and to enable you to make an appointment for a vaccination at a Blooms The Chemist pharmacy.
We may use your email address in relation to orders placed by you online. Many of our patients prefer to receive their accounts online rather than in the post. We do not use these emails for commercial use without prior consent.
We have certain legal obligations to collect and provide Personal Information about you to government authorities. We will only disclose to those authorities who are authorised by law to receive your Personal Information or if you authorise us or as set out in this Policy.
We collect Personal Information for the purpose of providing customers of the Blooms Pharmacies with marketing material informing you of promotions which may be of interest along with details of other products or services we provide.
If you decline to provide us with your Personal Information (which is your right), we may not be able to provide all of the above services adequately and may be unable to accept certain orders or service requests.
6. What we do with that information
We sometimes share your Personal Information within the Company and among the Blooms Pharmacies where it is necessary to deliver your requested items or services to you.
When you have made an appointment for a vaccination via the online appointment platform on our website, your personal information will be accessed by by the applicable Blooms Pharmacy for the purposes of administering and providing the booked services. For example, an authorised representative of the Blooms Pharmacy where you have made the booking will be able to access your personal information held in the appointment platform.
Personal Information may be disclosed to our service providers, such as the operator of the appointment platform on our website or to our professional advisors.
In addition to the uses of Personal Information set out in paragraph 5 above we also use some of the Personal Information for a purpose that is different to the original purpose for which it was collected (Secondary Purpose). Where we do that we will make sure that at least one of the following applies:
• this secondary purpose is related to the original reason that we collected the Personal Information (the Primary Purpose) and you would reasonably expect that we would use or disclose the Personal Information for the Secondary Purpose provided it is related to the Primary Purpose. Where the information is in the category of Sensitive Information (that includes information about your health and the provision and results of Health Checks) the Secondary Purpose must be directly related to the Primary Purpose; or
• you have consented to the Secondary Purpose; or
• the use or disclosure is required or authorised by or under law (including for example, as a necessary part of an investigation of suspected unlawful activity).
In many instances your identity is irrelevant to the use of the data. Wherever we can, we de-identify Personal Information; in other words we strip out unnecessary identifying information, so that we can aggregate the data to undertake research and analysis. Once that has been done the information that remains no longer contains enough information to be classified as Personal Information.
We will assume you consent to management of your Personal Information, including Sensitive Information in the manner specified in this Privacy Policy (which may change from time to time) until you tell us otherwise by contacting the Privacy Officer.
7. What we do not do with your Personal Information
Neither The Company nor a Blooms Pharmacy will make your Personal Information available to any person not engaged or employed by us unless we:
• are obliged by law; or
• have your consent.
We will not share or disclose your Sensitive Information with any other party unless permitted or required to do so by law.
8. Sending your personal information offshore
We may transfer your personal information to someone who is in a foreign country where any of the following apply:
• we reasonably believe that the recipient of the information is subject to a law or other binding arrangement which protects and deals with your information in a similar way to the Privacy Act;
• you give your consent to the transfer
• all of the following apply:
- the transfer is for your benefit;
- it is impracticable to obtain your consent to that transfer;
- if it were practicable to obtain such consent, you would be likely to give it;
- the transfer is necessary for the performance of a contract between you and us;
- we have taken reasonable steps to ensure that the information transferred will not be help, used of disclosed by the recipient of the information inconsistently with the Privacy Act; or
- the transfer is necessary for the conclusion or performance of a contract between us and a third party entered into in your interest.
We may also provide your personal information to our contractors and service providers who may be located in a foreign country for the purpose of analysing the information in accordance with the terms of this Privacy Policy and the Privacy Act.
The operator of the appointment platform on our website is based in the USA. Where you have consented to the collection of your personal information via the appointment platform, your personal information will be stored in the USA by AppointmentPlus (the appointment platform operator). If you do not consent to your personal information being held in the USA, please do not use the appointment platform.
9. Accessing your Personal Information
It is important that the Personal Information we hold about you is correct and complete.
If you are aware that this is not the case and would like your personal information corrected, or simply desire access to your personal information, please contact us via the contact address set out in paragraph 12 below.
We may ask you to put your request in writing and pay a reasonable fee levied by us for this.
10. Questions, Comments or Complaints
If you have any questions, comments or complaints (enquiry) regarding our Privacy Policy or its implementation in relation to you, please contact us at the address set out in paragraph 13.
If you have a complaint, about how your personal information has been gathered, stored, used or released, including a complaint about a breach of privacy, and that complaint relates to how your information was handled by a pharmacy operating under the banner group 'Blooms The Chemist' you need to make your complaint to the relevant pharmacy. This is because all pharmacies using the 'Blooms The Chemist' banner name are individually owned and operated businesses. Contact details for each Blooms Pharmacy can be found on the internet by searching 'Blooms The Chemist' and the location. Otherwise you can visit the pharmacy and ask to speak to the Pharmacist in charge.
If your complaint is about how your personal information has been gathered, stored, used and released, by the Company please contact us at the address set out in paragraph 13.
Please make sure that you provide enough factual information to enable us/the pharmacy to understand the nature and extent of the enquiry. This includes the relevant Personal Information involved, the circumstances of the enquiry, and the Blooms The Chemist process or store, and staff member involved.
The Blooms Pharmacy or the Company (as applicable) will contact you to confirm receipt of your enquiry within 5 business days of receipt. At that time we will give you the contact details of both the person at the Company or the Blooms Pharmacy who is handling the enquiry and of the Privacy Officer.
If the response does not resolve a complaint then the person lodging the complaint and either the Company or the Blooms Pharmacy (as applicable) will meet in good faith to establish a process (which may or may not entail third party involvement) and a time frame for dealing with the complaint.
11. Other privacy terms and limits of this policy
This is a policy. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses. There are additional privacy terms in the terms and conditions which apply to the My HealthRewards @ Blooms The Chemist Program.
12. Amendments to our Privacy Policy
We reserve the right to amend this Privacy Policy from time to time to meet changing conditions however any changes will comply with Australian law
regarding privacy.
13. Contacting Blooms The Chemist’s Privacy Officer
The contact details for the Blooms The Chemist Privacy Officer are:
Mail
Privacy Officer
Blooms The Chemist
Suite 1, Level 1, 15 Bourke Road
MASCOT NSW 2020
Email: privacy@blooms.net.au
14. More information
More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email – enquiries@oaic.gov.au).