This website, www.aspenmedical.co.id (Website), is owned and operated by Aspen Medical Pty Ltd (Aspen Medical), located at Graha Pos Indonesia, 1st Floor A, Jl. Banda No. 30, Bandung West Java, Indonesia. This policy covers the Aspen Medical Group (Aspen Medical Group, us, our, we), which includes:

• Aspen Medical Pty Ltd (ABN 32 105 250 413)
• Aspen Corporate Medical Options Pty Ltd (ABN 42 142 501 111)
• Aspen Medical Advisory Services Pty Ltd (ABN 97 660 632 146)
• Aspen Medical Manufacturing Pty Ltd (ABN 13 640 278 995)
• Aspen Medical Retrieval Services Pty Ltd (ABN 49 648 677 696)
• Aspen Technology Pty Ltd (ABN 42 662 430 051)
• Equity Health Solutions Pty Ltd (ABN 70 621 280 162)
• Exemplar International Pty Ltd (ABN 75 652 533 241)
• Global Medical Supplies Pty Ltd (ABN 77 641 151 993)
• Mobile Medical Facilities Pty Ltd (ABN 74 609 873 047)
• Aspen Medical Ltd 
• Aspen Medical Services Pte Ltd
• Health Care (Fiji) Pte Ltd

Access to and use of our Website, and any products, services, content and information available through our Website (collectively, Services) are subject to the following terms, conditions and notices (Terms of Use). By using the Services, you are agreeing to all of the Terms of Use, as may be updated by us from time to time. You should check this page regularly to take notice of any changes we may have made to the Terms of Use.

1 Amendments to Terms of Use

We reserve the right to amend these Terms of Use from time to time. Amendments will be effective immediately upon notification on our Website. Your continued use of our Website following such notification will represent an agreement by you to be bound by the terms and conditions as amended.

2 Website Access and Online Accounts

1. Access to our Website, including any online account you register for, is permitted on a temporary basis, and we reserve the right to withdraw or amend the Services without notice. We will not be liable if for any reason our Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts or all of our Website.
2. When you register for an online account via our Website, you will set up a personal login containing your email address and password of your choice. You must not share these login details with anyone else or allow others to use and access your account.
3. You may upload content via your account including your image, and other information about you. You acknowledge and accept that any information you upload will be published and available in your online account.

3 Linked Sites

This Website may contain links to other websites (Linked Sites), which are not operated by Aspen Medical. Aspen Medical has no control over the Linked Sites and accepts no responsibility for them or for any loss or damage that may arise from your use of them. Your use of the Linked Sites will be subject to the Terms of Use and service contained within each Linked Site.

4 Our Information Policies

Information about how we collect, use, store and protect your information can be found in our Website Privacy Policy, Data Protection Policy and Personal Information Collection Notice. By using our Website, you consent to the collection and processing of your information as described in these policies and warrant that all data provided by you is accurate.

If you have any further questions regarding your personal information you can contact us at [email protected]

5 Prohibitions

1. You must not misuse our Website. You will not:
   1. commit or encourage a criminal offence;
   2. transmit or distribute a virus, trojan, worm, logic bomb or any other material that is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene;
   3. hack into any aspect of the Service; corrupt data; cause annoyance to other users;
   4. infringe upon the rights of any other person's proprietary rights;
   5. send any unsolicited advertising or promotional material, commonly referred to as "spam"; or
   6. attempt to affect the performance or functionality of any computer facilities of or accessed through our Website.

Breaching this provision would constitute a criminal offence and we will report any such breach to the relevant law enforcement authorities and disclose your identity to them.

1. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any Linked Sites.

6 Intellectual property, software and content

The intellectual property rights in all software and content (including photographic images) made available to you on or through our Website remain the property of Aspen Medical or its licensors and are protected by copyright laws and treaties around the world. All such rights are reserved by Aspen Medical and its licensors. You may store, print and display the content supplied solely for your own personal use. You are not permitted to publish, manipulate, distribute or otherwise reproduce, in any format, any of the content or copies of the content supplied to you or which appears on our Website, nor may you use any such content in connection with any business or commercial enterprise.

7 Disclaimer of liability

1. You use our Website, at your own risk. To the extent permitted by law, our Website is provided to you on an “as is” and “as available” basis without guarantee or warranty of any kind (express or implied). To the extent permitted by law, and subject to any non-excludable consumer guarantees and other consumer protection provisions set out in the Australian Consumer Law, Aspen Medical excludes any express or implied guarantees, conditions warranties under statute or general law in connection with our Website.
2. Whilst reasonable attempts are made to ensure the accuracy of the content on our Website, this is not always possible, and content may not be true, accurate, up-to-date or complete. Aspen Medical does not invite reliance upon and does not accept responsibility or liability for any content made available on our Website.
3. To the fullest extent permitted by law, you unconditionally release Aspen Medical, its officers, employees, contractors, volunteers, stakeholders, representatives and agents from all liabilities, actions, demands, loss, damage, costs and expenses (including legal costs on a full indemnity basis) and, including but without limitation to any direct, indirect, special, consequential, punitive or incidental damages, or damages for loss of use, profits, data or other intangibles, damage to goodwill or reputation, or the cost of procurement of substitute goods and services, incurred or suffered by you directly or indirectly in connection with your access to, or use of, inability to use, or any performance or failures of this Website or the Linked Sites and any materials posted on those sites, irrespective of whether such damages were foreseeable or arise in contract, tort, equity, restitution,
4. This does not affect Aspen Medical's liability for death or personal injury arising from its negligence, fraudulent misrepresentation, misrepresentation as to a fundamental matter or any other liability that cannot be excluded or limited under applicable law.

8 Disclaimer as to ownership of third-party trademarks, images of personalities and content

Except where expressly stated to the contrary all persons (including their names and images), third-party trade marks and content, services and/or locations featured on our Website are in no way associated, linked or affiliated with Aspen Medical and you should not rely on the existence of such a connection or affiliation. Any trade marks/names featured on our Website are owned by the respective trade mark owners. Where a third-party trade mark or brand name is referred to, it is used solely to describe or identify the products and services and is in no way an assertion that such products or services are endorsed by or connected to Aspen Medical.

9 Linking to our Website

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you. This Website must not be framed on any other site, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.

10 Indemnity

You agree to indemnify, defend and hold harmless Aspen Medical, its directors, officers, employees, consultants, agents, and affiliates, from any and all third-party claims, liability, damages or costs (including, but not limited to, legal fees) arising from your use of our Website including all content and intellectual property made available to you on our Website, or your breach of the Terms of Use.

11 Variation

Aspen Medical has the right to, at its absolute discretion, at any time, and without notice to amend, remove or vary the Services or any page of our Website.

12 Invalidity

If any part of the Terms of Use is unenforceable (including any provision in which we exclude our liability to you) the enforceability of any other part of the Terms of Use will not be affected and all other clauses remain in full force and effect. So far as possible where any clause or part of a clause can be severed to render the remaining part valid, the clause must be interpreted accordingly. Alternatively, you agree that the clause must be rectified and interpreted in such a way that closely resembles the original meaning of the clause as is permitted by law.

13 Questions or Complaints

We will try to answer your questions and resolve issues when they first arise. Please let us know if you have any questions, comments or concerns by first contacting us here.  

This privacy notice tells you about the information we collect when you use our website.

In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Aspen Medical Group is committed to complying with the Privacy Act 1988 (the Act) and other applicable privacy and data protection legislation, including the European Union’s General Data Protection Regulation (GDPR).

The Act is an Australian law that regulates the handling of personal information about individuals. The 13 Australian Privacy Principles (APP) are contained in Schedule 3 of the Act. The APPs provide guidance on how personal information is to be managed by organisations such as Aspen Medical.

The GDPR is the European regulation governing the handling of personal information about individuals. This is applicable to individuals within the European Union. Aspen Medical complies with the Act and the GDPR in its dealings with the personal information of individuals. Aspen Medical collects personal information from individuals using fair and lawful means in the course of its business and ihe care of patients. It collects this information so that it can conduct its business and provide the best possible care to patients.

Who are we?

Aspen Medical Pty Ltd is an Australian registered business with our head office located at 2 King Street, Deakin ACT 2600. You can contact us by post, by email at [email protected] or by telephone on +61 2 6203 9500. 

The Act does not require Australian entities to have a data protection officer, so all enquiries about our use of your personal data should be addressed to the contact details above.

How do we use your information?

• When you use our website
• When you submit an enquiry via our website
• When you are a patient
• When you apply for a position on our website
• To send direct marketing communications about Aspen Medical’s products, services, offers, company news, events, surveys or other documentation 
• To update you on your rights as a data subject
• To update you on your right to complain
• To provide you updates to this privacy policy. 

When you use our website

When you use our website to browse our products and services and view the information, we make available, a number of cookies are used by us and by third parties to allow the website to function, to collect useful information about visitors and to help to make your user experience better.

Some of the cookies we use are strictly necessary for our website to function. 

Strictly necessary cookies

Strictly necessary cookies are essential to enable you to navigate around our website and use its core features. Without these cookies, services such as remembering your login details or ensuring what you see looks correct on the device you are using would not be possible. These cookies do not gather information about you that could be used for marketing and do not track your internet usage. 

Preference cookies

Preference cookies enable the website to adapt to the user’s website template design, by gathering information such as the user's preferred language or region.

Statistical and performance cookies 

These cookies help us understand how you interact with our website by collecting and reporting information about your journey on our website. For example, they help us understand which pages you go to most often, how much time you spend on which pages, which links you choose to click and the journey you took during the website session.

When you submit your enquiry to our website

Submitted data 

When you submit an enquiry via our website or other electronic means, we may ask you for your personal data.  

We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered your query to your satisfaction. We will do this based on our legitimate interest in providing accurate information.

We will also use this information to contact you for direct marketing purposes. We retain this information until you unsubscribe or withdraw your consent.

Your enquiry is stored and processed as an email that is hosted by Microsoft in the region you have selected. We do not use the information you provide to make any automated decisions that might affect you. You can request Aspen Medical to delete any enquiry emails.

When you are a patient

Where you are a patient and we are providing you with medical treatment, we will collect personal information including demographic information (such as name, date of birth and address), health history, family history, ethnic background, and current lifestyle. We will collect this information directly from you. We may collect personal information about patients from other sources, but only where required and permitted by law, for example in a medical emergency.

We use this information to diagnose and treat your condition. If you fail to provide this information, we may not be able to provide appropriate healthcare. We may also use this information for the purposes of quality assurance, accreditation and audit activities, risk and claims management, patient satisfaction surveys and staff training and education. Where possible, we will de-identify this personal information where we use it for these purposes.

We will only disclose the personal information of patients to third parties with the consent of the patient, or as otherwise permitted by law as applicable to the circumstances. Unless the medical activity has occurred in an overseas jurisdiction, we do not send or store the personal information of patients overseas. We do not send personal information to third parties without prior authorisation.

The personal information of patients is stored securely using physical means such as locks and restricted premises and by electronic methods including passwords and secure servers located in Australia. We take reasonable steps to prevent loss, theft, misuse and interference of personal information, and we have policies and procedures in place to protect this information.

When you apply for a position via our website

When you apply for a position via our website, we ask you for your name, email address, phone, email and resume with other relevant information, including employment history and qualifications. We will generally collect this information from you, but we may also collect it from other sources, including previous employers, public domain and social media websites.

We use this information to process your application. Our Culture and Performance team may also email or phone you several times after your enquiry to follow up on your interest and ensure that we have answered you to your satisfaction. We will do this based on our legitimate interest in providing accurate information. If you fail to provide this information, we may not be able to process your application.

We will only disclose the personal information of job applicants overseas with the applicant’s consent. Where an applicant has completed paperwork for an overseas work permit or other authorisation, we deem this to be consent to release the paperwork to the overseas recipient named in the paperwork.

Your enquiry is stored and processed as an email which is hosted by Microsoft in Australia. Your details will also be stored on our CRM which is managed on an Aspen Medical server within Australia.

We do not use the information you provide to make any automated decisions that might affect you. We keep applicant details for seven years, after which they are deleted off the CRM. CRM records are kept for seven years after the last contact with you.

Your rights as a data subject Australian Privacy Act

In accordance with the Act, you may request access to, and correction of, personal information held by us. We will respond to such a request in a reasonable time and may charge a reasonable fee for the provision of information. We will provide access to records and correct information unless there is a reason under the Act or other relevant law. If we do not agree to provide you with access or to correct a record, we will provide you with reasons for this decision. Please email [email protected] for any enquiries.

European Union GDPR

By law, you can ask us what information we hold about you, and you may request corrections to any inaccuracies. If we have asked for your consent to process your personal data, you may withdraw that consent at any time. You may withdraw your consent by contacting us by email at [email protected] or by telephone on +61 2 6203 9500.

Where you have withdrawn your consent to our processing of your personal data, we will cease to process that information, though your withdrawal of consent does not affect the lawfulness of our actions before you withdraw your consent. Additionally, where our processing is based on the performance of our obligations under a contract, for example, your employment contract, then we may continue processing in accordance with those obligations.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider. If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling. To submit a request regarding your personal data by email, post or telephone, either under the Australian Privacy Act or the European Union GDPR, please use the contact information provided above in the Who Are We section of this policy.

Applicable law

Excluding third-party links or websites, our website is controlled and maintained in Australia by Aspen Medical. The courts will determine if any disputes are within the jurisdiction of laws in force in the Australian Capital Territory, Australia. If found within the jurisdiction, you must submit and comply with these laws. 

Content on this website may not comply with the laws of any country outside of Australia. If accessing this website outside of Australia, you do so at your own risk. You accept responsibility to ensure compliance with the laws that apply to accessing, dealing with or actioning transactions with us. 

Your right to complain

If you have a complaint about our use of your information, we would prefer you to raise in with us in the first instance at [email protected] to give us the opportunity to put it right. We will review all complaints received and our Privacy Team will respond to you as soon as is practicable. 

VeraSafe has been appointed as Aspen Medical Group representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation; and European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.

If you are located within the United Kingdom or, within the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. 

To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative 

Alternatively, VeraSafe can be contacted at: 
VeraSafe United Kingdom Ltd. 37 Albert Embankment London SE1 7TL United Kingdom or via telephone at: +44 (20) 4532 2003. 

VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland +420 228 881 031.

If you are not satisfied with our response, you can also contact the following government organisations: 

The European Data Protection Supervisor
Postal address: Rue Wiertz 60, B-1047 Brussels
Office address: Rue Montoyer 30, B-1000 Brussels
Telephone: +32 2 283 19 00
Email: [email protected]
Website: www.edps.europa.eu

Office of the Australian Information Commissioner
Postal address: GPO Box 5218 Sydney NSW 2001
Office address: Level 3, 175 Pitt Street Sydney NSW 2000
Telephone : 1300 363 992 or + 61 2 9284 9749
Email: [email protected]
Website: https://www.oaic.gov.au

Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent. We will update the version number and date of this document each time it is changed.

1. Purpose

In its everyday business operations Aspen Medical makes use of a variety of data about identifiable individuals, including data about:

• Current, past and prospective employees
• Customers
• Users of its websites
• Subscribers
• Other stakeholders

In collecting and using this data, the organisation is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it.

The purpose of this policy is to set out the relevant legislation and to describe the steps Aspen Medical is taking to ensure that it complies with it.

This control applies to all systems, people and processes that constitute the organisation’s information systems, including board members, directors, employees, suppliers and other third parties who have access to Aspen Medical systems.

The following policies and procedures are relevant to this document:

• Data Protection Impact Assessment Process
• Personal Data Analysis Procedure
• Legitimate Interest Assessment Procedure
• Information Security Incident Response Procedure
• GDPR Roles and Responsibilities
• Records Retention and Protection Policy

2. Data Protection Policy

1. The General Data Protection Regulation

   The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that Aspen Medical carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the UK and European Union. It is Aspen Medical’s policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.

2. Definitions

   There are a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:

   Personal data is defined as:

   any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

   ‘processing’ means:

   any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

   ‘controller’ means:

   the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

3. Principles Relating to Processing of Personal Data

   There are a number of fundamental principles upon which the GDPR is based. These are as follows:

   Personal data shall be:

   1. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency');
   2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
   3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
   4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
   5. kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
   6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

   The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).

   Aspen Medical will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.

4. Rights of the Individual

   The data subject also has rights under the GDPR. These consist of:

   1. The right to be informed
   2. The right of access
   3. The right to rectification
   4. The right to erasure
   5. The right to restrict processing
   6. The right to data portability
   7. The right to object
   8. Rights in relation to automated decision-making and profiling.

   Each of these rights are supported by appropriate procedures within Aspen Medical that allow the required action to be taken within the timescales stated in the GDPR.

   These timescales are shown in Table 1.

   Data Subject Request

   Timescale

   The right to be informed: When data is collected (if supplied by data subject) or within one month (if not supplied by data subject)

   The right of access: Without undue delay, the maximum timescale is one month

   The right to rectification: Without undue delay, the maximum timescale is one month

   The right to erasure: Without undue delay, unless retention as a requirement by laws. Maximum timescale one month

   The right to restrict processing: Without undue delay, the maximum timescale is one month

   The right to data portability: Without undue delay, the maximum timescale is one month

   The right to object: On receipt of objection

   Rights in relation to automated decision-making and profiling: Not specified

5. Lawfulness of Processing

   There are six alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is Aspen Medical policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The options are described in brief in the following sections.

   1. Consent

      Unless it is necessary for a reason allowable in the GDPR, Aspen Medical will always obtain explicit consent from a data subject to collect and process their data. In case of children below the age of 16 (a lower age may be allowable in specific EU member states) parental consent will be obtained. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information will be provided in an accessible form, written in clear language and free of charge.

      If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.

   2. Performance of a Contract

      Where the personal data collected and processed are required to fulfil a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question e.g. a delivery cannot be made without an address to deliver to.

   3. Legal Obligation

      If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.

   4. Vital Interests of the Data Subject

      In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. Aspen Medical will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.

   5. Task Carried Out in the Public Interest

      Where Aspen Medical needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.

   6. Legitimate Interests

      If the processing of specific personal data is in the legitimate interests of Aspen Medical and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.

6. Privacy by Design

   Aspen Medical has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments.

   The data protection impact assessment will include:

   • Consideration of how personal data will be processed and for what purposes
   • Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
   • Assessment of the risks to individuals in processing the personal data
   • What controls are necessary to address the identified risks and demonstrate compliance with legislation

7. Use of techniques such as data minimization and pseudonymisation

   Aspen Medical will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR. For more information, see the GDPR Controller-Processor Agreement Policy.

8. International Transfers of Personal Data

   Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time. Intra-group international data transfers will be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.

9. Data Protection Officer

   Under the Australian Privacy Act 1988 (Cth), entities are not currently required to have a Data Protection Offer.

   However, under the GDPR, a Data Protection Officer (DPO) is required under the GDPR if an organisation is a public authority, if it performs large-scale monitoring or if it processes particularly sensitive types of data on a large scale. Noting Aspen Medical would fall into the category of processing sensitive (medical) data, a GDPR Representative is required.

   VeraSafe has been appointed as Aspen Medical's representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation; and European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.

   If the relevant data protection matter relates to activities within the United Kingdom or, within the European Economic Area, VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data.

   External parties may make such an inquiry/complaint, by contacting VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative

   Alternatively, VeraSafe can be contacted at:

   VeraSafe United Kingdom Ltd. 37 Albert Embankment London SE1 7TL United Kingdom or via telephone at: +44 (20) 4532 2003.

   VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road

   Cork T23AT2P Ireland +420 228 881 031.

10. Breach Notification

    It is Aspen Medical’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours and the affected parties will be informed without undue delay. This will be managed in accordance with our Information Security Incident Response Procedure and Notifiable data Breach Procedure which sets out the overall process of handling information security incidents.

    Under the GDPR the relevant DPA has the authority to impose a range of fines of up to four percent of annual worldwide turnover or twenty million Euros, whichever is the higher, for infringements of the regulations.

11. Addressing Compliance to the GDPR

    The following actions are undertaken to ensure that Aspen Medical complies at all times with the accountability principle of the GDPR:

    • The legal basis for processing personal data is clear and unambiguous
    • All staff involved in handling personal data understand their responsibilities for following good data protection practice
    • Training in data protection has been provided to all staff
    • Rules regarding consent are followed
    • Routes are available to data subjects wishing to exercise their rights regarding personal data and such enquiries are handled effectively
    • Regular reviews of procedures involving personal data are carried out
    • Privacy by design is adopted for all new or changed systems and processes
    • The following documentation of processing activities is recorded:
      • Organisation name and relevant details
      • Purposes of the personal data processing
      • Categories of individuals and personal data processed
      • Categories of personal data recipients
      • Agreements and mechanisms for transfers of personal data to non-EU countries including details of controls in place
      • Personal data retention schedules
      • Relevant technical and organisational controls in place

These actions are reviewed on a regular basis as part of the management process concerned with data protection.

If you have any queries or concerns, please contact [email protected]

Why do we collect your information?

We collect your personal information to enable us to send communications, provide feedback or consider your suitability for potential job opportunities that you (or a person/company with whom you are associated) acquire or wish to acquire.

What happens if you don’t provide the information?

Without your personal information, we may not be able to supply those services or we may be restricted in the way those services can supplied.

Who might we share your personal information with?

Your personal information will not be shared with anyone else, unless it is needed in connection with our ongoing supply of services to you and for purposes associated with the supply of those services. We may share your information because we are required to do so by law.

Will any of your information be shared with overseas organisations?

We operate both in Australia and overseas. Therefore, we may need to share some of your personal information with organisations outside Australia, for example when a person is deployed to an overseas location. We may also store your information in cloud or other types of networked or electronic storage. For further information, please refer to our privacy policy.

How you can access your personal information or make a complaint?

Our website privacy policy contains information about how you may access your personal information and seek correction of such information; as well as how to complain about a breach of the Australian Privacy Principles and Global Data Regulation Protection (GDPR) and how we will deal with such a complaint.

View our website privacy policy for full details.