Privacy Policy

[Current as at: 22/10/2021 | Review date: 22/10/22]

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Introduction

This Privacy Policy is to provide information to you, our patient, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.

Why and when your consent is necessary?

When you register as a patient of our practice, you provide consent for our doctors 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 details?

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 (e.g. staff training).

Definition of a Patient Health Record

Information, held about a patient, in paper form or electronic form, which may include:

• contact and demographic information

• medical history

• notes on treatment

• observations

• correspondence

• investigations

• test results photographs

• prescription records

• medication charts

• insurance information

• legal information and reports

• work health and safety reports

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.

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.

There may be a range of circumstances where providing services anonymously may be impracticable e.g:

• a service may require follow up – if the person does not provide details to allow this, the ongoing care may be compromised.

• the care to be provided involves a multi-disciplinary team, making it difficult to provide ongoing care without a clear identification of the patient.

• a patient’s medical status may be compromised if a clinician cannot obtain clinical information critical to providing safe and appropriate care.

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 form.

2. During the course of providing medical services, we may collect further personal information.

3. Information can also be collected through ‘My Health Record’ e.g. via Shared Health Summary, Event Summary.

4. We may also collect your personal information when you send us an email or SMS, phone us, make an online appointment or communicate with us using social media.

5. In some circumstances personal information may also be collected from other sources 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 required/applicable).

When, why, and with whom do we share your personal details?

We sometimes need to 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 Australian Privacy Principles (APP) and this policy.

• with other healthcare providers.

• when it is required or authorised by law (e.g. court subpoena).

• 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 (e.g. some diseases require mandatory notification).

• during the course of providing medical services, through ‘My Health Record’ (e.g. 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.

In the above cases, only information needed to meet the requirements will be provided. Where health information must be disclosed to a third party, our practice considers what information is relevant for the proposed purpose. Patients will reasonably expect the disclosure of only the necessary subset of their health information, along with third-party access restrictions. We will only forward patient information that relates to the condition for which the referral is being made. Prior to disclosing any health information, our practice carefully examines authority for disclosure and seeks advice where necessary.

Referrals are written in our clinical software – in the patient’s health record. Referrals are sent to third parties by faxed.

We discourage patients emailing the practice with confidential information due to the risk of privacy breaches.

We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.

Our practice will not use your personal information for marketing any of our 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 is stored at our practice in electronic records and visual records (e.g. x-rays). Our practice stores all personal information securely. Our practice has confidentiality agreements in place for all staff and contractors.  Our computers, clinical and administration programs are all password protected.

How can you access and correct your personal details?

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 by completing a ‘Request for Health Information’ form and our practice will respond within 30 days. There may be a fee for your medical records.

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.

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. All complaints will be addressed within 30 days of receiving the complaint.

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Complaints can be emailed to the practice manager at info@gheringhapmedical.com.au

or posted to:

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The Practice Manager

Gheringhap Medical Centre & Skin Clinic

21a Gheringhap Street,

Geelong 3220 Victoria

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Contacts

You can contact the Office of Australian Information Commissioner (OAIC):

P: 1300 363 992 | E: enquiries@oaic.gov.au

Generally, the OAIC will require you to give them time to respond before they will investigate.
More information can be found on their website: www.oaic.gov.au.

OR

You may also contact the

Health Complaints Commissioner

Level 26, 570 Bourke Street | Melbourne | 3000

P: 1300 582 113 | W: https://hcc.vic.gov.au/make-complaint

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Policy Review Statement

This privacy policy was reviewed on 22nd October 2021.

This policy will be reviewed annually to ensure it is in accordance with any changes that may occur.

Next review date: 22nd October 2022.

An up-to-date copy can be accessed at the practice.