3.1 Managing and assessing confidential material
Page last updated: October 2016
3.1.1 Material contained in submissions
Australian Government Department of Health
Electronic and paper-based records are maintained by the Australian Government Department of Health to show what happened, when and how it happened, who was involved, what was decided or recommended, what advice or instruction was given, and the order of decisions or events. The department maintains policies and procedures to ensure the management and storage of records is consistent, accurate and appropriate.
Submissions to the PBAC are usually supplied in electronic format (refer to Section 5). The USB or a similar storage device that is supplied by sponsors is kept in a secure storage area in the Pharmaceutical Benefits Division (PBD), and access to the area is limited. Submissions that are emailed are stored in the Department of Health’s IT system. General submissions and other correspondence are filed and stored in a secure area within the Pharmaceutical Evaluation Branch (PEB) and electronic copies are made for the PBAC agenda. The contents of all submissions are stored in the Department of Health IT system in the electronic format that was provided in the submission.
Access to the contents of the submission is limited to officers who need to work on the submission material. Access is controlled by senior officers in PEB.
The contents of submissions are potentially subject to release under Freedom of Information legislation and may also be subject to requests of the Parliament.
Contractors evaluating submissions and working on agenda items for the PBAC
The external evaluation entity (see Section 6.2) receives electronic copies of submissions that are allocated for them to evaluate. The conditions of storage, management and disposal of submission material are explicitly stated in the department’s contracts.
Signed deeds of confidentiality are required by all people undertaking evaluations or other work for the PBAC. Employees and subcontractors of each external evaluation group agree not to disclose information provided in the submission to a ‘third party’ – that is, they will maintain confidentiality in regard to the content of submissions and other PBAC materials.
Members of PBAC and its subcommittees
All agenda material is provided to committee members in electronic form.
Members of the PBAC and its subcommittees, and any working groups appointed by the PBAC or its subcommittees, are required to sign a deed of confidentiality when appointed. The deed includes text about not disclosing information provided in the agenda papers to a ‘third party’.
Members are advised of the requirements to securely handle and dispose of confidential material appropriately, whether electronic or printed.
Other interested parties
From time to time, other parties will need to have information from submissions or PBAC agenda papers released for specific purposes. These include – but are not limited to – giving technical or expert advice, assisting with implementation or providing a consumer perspective. Examples of the people who may have access to this material are other officers within the department, such as the Therapeutic Goods Administration (TGA) and Office of Health Protection, and non-department employees such as clinicians or other health care professionals, members of the Australian Technical Advisory Group on Immunisation (ATAGI) and its working parties (for vaccine submissions only), employees of the National Prescribing Service, and officers from the Australian Government Department of Human Services.
Where these other parties are not currently Australian Government employees, they will have access to submission material after they sign a Deed of Confidentiality that includes text about not disclosing any information provided in the agenda papers to a ‘third party’. All attendees at meetings are required to dispose of any electronic and paper material appropriately.
3.1.2 Material contained in contracts and deeds
All material in contracts and deeds is managed according to the requirements set out in the contract or deed.