Current as of: 14th June, 2019
Why and when your consent is necessary
When you register as a patient of our practice, you provide consent for our GPs and practice staff to access and use your personal information so they can provide you with the best possible healthcare. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do this.
Why do we collect, use, hold and share your personal information?
Our practice will need to collect your personal information to provide healthcare services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your health. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training) and sending you updates about our practice via email.
What personal information do we collect?
The information we will collect about you includes your:
• names, date of birth, addresses, contact details
• medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors
• Medicare number (where available) for identification and claiming purposes
• healthcare identifiers
• health fund details.
Dealing with us anonymously
You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.
How do we collect your personal information?
Our practice may collect your personal information in several different ways.
1. When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
2. During the course of providing medical services, we may collect further personal information. Information can also be collected through electronic transfer of prescriptions (eTP) and My Health Record (For example, via Shared Health Summary or Event Summary.)
3. We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media.
4. In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:
• your guardian or responsible person
• other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services
• your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).
When, why and with whom do we share your personal information?
We sometimes share your personal information:
• with third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with APPs and this policy
• with other healthcare providers
• when it is required or authorised by law (eg court subpoenas)
• when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent
• to assist in locating a missing person
• to establish, exercise or defend an equitable claim
• for the purpose of confidential dispute resolution process
• when there is a statutory requirement to share certain personal information (eg some diseases require mandatory notification)
• during the course of providing medical services, through eTP, My Health Record (eg via Shared Health Summary, Event Summary).
Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.
We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent. Should we wish to transfer your personal information overseas, we will ask for your consent before we do so.
Our practice will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.
How do we store and protect your personal information?
Your personal information may be stored at our practice in various forms such as electronic records and visual records (X-rays, CT scans, videos and photos).
Our practice stores all personal information securely. We are an electronic medical records practice and do not retain any hardcopies of your medical or personal information. Everything is stored electronically in a secure, encrypted hosted service maintained by IT professionals. Once your data is entered onto our medical software, all paper copies are securely destroyed. We encourage patients to retain any hard copies of their imaging files (x rays, CT scans, ultrasound scans). Any temporary storage of hard copies of such data will be in a securely locked cabinet until you are able to collect them.
All personal information stored in electronic form is protected from unauthorised access, misuse, interference, loss, modification or disclosure. Some of the steps we take to ensure your personal information is secure include:
• Our staff are trained on privacy and we have detailed internal processes and systems to protect your privacy.
• We outsource our IT management and medical record hosting to Australian based IT professionals. They are specialists in provision of these services to the medical industry in Australia. They incorporate secure technologies to protect your personal records.
• Electronic records are hosted in professional data centres within Australia and sit behind two firewalls with business grade antivirus and antimalware software protection. The IT professionals regularly have independent penetration tests performed.
• All data is backed up daily and again weekly on a separate server than the “operating” server. All data is kept in Australia.
• We have selected the IT professionals based on their expertise and focus on security. They have a data breach response plan in place and our IT systems are fully maintained by them to ensure all software updates and licences are current, and that our system’s security integrity is maintained.
• We review our risk management program annually to protect privacy.
Our website and email is linked to the internet. No data transfer over the internet is 100% secure. Accordingly, any information which you transmit to us online or via email is transmitted at your own risk.
How can you access and correct your personal information at our practice?
You have the right to request access to, and correction of, your personal information.
Our practice acknowledges patients may request access to their medical records. We require you to put this request in writing addressed to the Practice Manager and our practice will respond within 30 days. There will be an Admin fee for processing records of $25.00 and registered postage (at cost +GST), if postage is required.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we will ask you to verify that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to The Practice Manager, Sante Medical, PO Box 267, Red Hill Q 4059.
How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?
We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure. Our Practice Manager and Principal Doctors will address your complaint within 30 days. Please send your written complaint to The Practice Manager, Sante Medical, PO Box 267, Red Hill Q 4059.
You may also contact the Office of the Australian Information Commissioner (OAIC). Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992.
Privacy and our website
Information collected through our website is processed by our staff and electronically stored directly into Best Practice Software. This information is kept privately and is not displayed anywhere public.
We abide by the Medical Board of Australia ‘Social Media Policy’ available from https://www.medicalboard.gov.au/Codes-Guidelines-Policies/Social-media-policy.aspx
Policy review statement