PRIVACY POLICY
DATE OF POLICY: MARCH 2017, APRIL 2021, NOVEMBER 2023,
Review Policy: November 2024
The purpose of this document is to outline how ‘The Clinic Altona’ complies with its confidentiality and privacy obligations. The Clinic Altona will make this Privacy Policy available to anyone who asks for it.
As a Healthcare organization, our principal concern is the health and welfare of our patients. A high level of trust and confidentiality is required to ensure the confidence of the patients we serve.
This policy is line with the Health Records Act 2001 (Victoria) (HRA) the Commonwealth Privacy Act 1988 (effective 21 December 2001) that was amended to include the private health sector throughout
• protected when visiting this practice
• that all information collected and retained is up to date and
• that access to their information is available for review
The Health Records Act 2001 Victoria will serve to complement our existing culture of confidentiality and professional practice obligations. This will always ensure best practice obligations and policy.
No exceptions under the Privacy Act will apply to any personal information held here at the clinic.
Definition:
A Patient Health Record is a history of someone’s health.
Your record brings together health information from you, your healthcare providers and Medicare. This can include details of your medical conditions and treatments, medicine details; including bush medicines and supplements you may take, allergies, and test or scan results all in one personal file held at this practice.
Practice procedure
The Practice will:
-provide a copy of this policy upon request
-ensure staff comply with the APP and deal appropriately with inquiries or
-take such steps as are reasonable in the circumstances to implement practices, procedures and systems to ensure compliance with the APP and deal with inquiries or complaints
-collect personal information for the primary purpose of managing a patient’s healthcare and for financial claims and payments
Staff responsibility
The Practice’s staff will take reasonable steps to ensure patients understand:
-what information has been and is being collected
-why the information is being collected, and whether this is due to a legal requirement
-how the information will be used or disclosed
-why and when their consent is necessary
-the Practice’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.
Patient consent
The Practice will only interpret and apply a patient’s consent for the primary purpose for which it was provided. The Practice staff must seek additional consent from the patient if the personal information collected may be used for any other purpose.
Collection, Use & Disclosure
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. If wishing to remain anonymous, then a ‘use single name’ or ‘known as’ can be activated in our Pracsoft software.
We are a service company to the practitioners who provide services at our practice. For administrative and billing purposes, and to enable the patient to be attended by other practitioners in our practice, patient information is collected and shared between the practitioners who attend a patient.
We (on behalf of) and the practitioners may collect personal information (including but not restricted to health information) regarding patients for the purpose of providing medical services and treatment to patients. Personal information collected will generally include: the patient’s name, address, telephone number and Medicare number; health care fund; current drugs or treatments used by the patient; previous and current medical history, including where clinically relevant a family medical history, and the name of any health service provider or medical specialist to whom the patient is referred, copies of any letters of referrals and copies of any reports back.
- provided directly by the patient;
- provided on the patient’s behalf with the patient’s consent;
- from a health service provider who refers the patient to medical practitioners
- from health service providers to whom patients are referred
Personal information collected by us may be used or disclosed:
- for the purpose the patient was advised of at the time of collection of the information by us;
- as required for delivery of the health service to the patient;
- as required for the ordinary operation of our services (i.e. to refer the patient to a medical specialist or other health service provider)
-required by law
-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
-to assist in locating a missing person
-to establish, exercise or defend an equitable claim
Personal information will only be used for the purpose of providing medical services and for claims and payments, unless otherwise consented to. Some disclosure may occur to third parties engaged by or for the Practice for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy. The Practice will inform the patient where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).
The Practice will not disclose personal information to any third party other than in the course of providing medical services, without full disclosure to the patient or the recipient, the reason for the information transfer and full consent from the patient. The Practice will not disclose personal information to anyone outside Australia without need and without patient consent.
Other than as described in this Policy or permitted under the National Privacy Act, Park ‘The Clinic Altona’ uses its reasonable endeavours to ensure that identifying health information is not disclosed to any person.
We keep health information for a minimum of 7 years from the date of last entry in the patient record (unless the patient was a child in which case the record must be kept until the patient attains or would have attained 25 years of age). This is because we are required to maintain such records under some laws.
Because of the sensitive nature of the information collected by us to provide its services, extra precautions are taken to ensure the security of that information. Our electronic files are password-protected on several levels and the computer backup tapes are stored securely offsite daily.
We require all our employees and contractors to observe obligations of confidentiality in the course of their employment/contract. We require independent contractors to sign a confidentiality undertaking.
Practitioners who provide services at our practices may refer patients to the following services:
- pathology services
- radiology services;
- public hospitals;
- private hospitals;
- day procedure centres;
- allied health services – specialist medical practitioners and other health providers involved in the relevant patient’s care which may include surgeons, nurses, occupational therapists, pharmacists, physiotherapists, psychologists, dietitians, audiologists, podiatrists and the ambulance service.
Only relevant personal and medical information is included in letters and referrals.
This is assisted through our clinical software that allows GPs to customize and change referrals relevant to the patient being consulted.
Secondary purposes which are directly related to the primary purpose of collection for which we may use or disclose personal information may be for quality assurance, training, billing, liaising with government offices regarding Medicare entitlements and payments and as may be required by our insurers.
We also collect information about the medical practitioners who provide services at our practices. This information is collected directly from or with the agreement of the medical practitioner. This information includes the name, address, qualifications and experience of the medical practitioner.
1. Practice staff collect patients’ personal and demographic information via registration when patients present to the Practice for the first time. Patients are encouraged to pay attention to the collection statement attached to/within the form and information about the management of collected information and patient privacy.
2. During the course of providing medical services, the Practice’s healthcare practitioners will consequently collect further personal information.
3. Personal information may also be collected from the patient’s guardian or responsible person (where practicable and necessary), or from any other involved healthcare specialists
4. The Practice will not use any personal information in relation to direct marketing to a patient without that patient’s express consent. Patients may opt-out of direct marketing at any time by notifying the Practice in a letter or email.
5. The Practice evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.
Accessing your information, complaints and obtaining further information.
If an individual wishes to:
- complain to us about a breach of privacy; or
- access his or her own information held by us; or
- correct any information held by us concerning his or her own information; or
- find out more about how we deal with personal information, that individual can contact:
Practice Manager/Privacy Officer, The Clinic Altona,
The Practice acknowledges patients may request access to their medical records. Patients are encouraged to make this request in writing, and the Practice will respond within a reasonable time.
The Practice will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, the Practice will ask patients to verify the personal information held by the Practice is correct and up to date. Patients may also request the Practice corrects or updates their information, and patients should make such requests in writing.
Contacts
If you have questions or a complaint about the privacy of your personal information, please ask to speak to the privacy contact officer at the practice.
Further information on privacy legislation is available from:
Office of the Australian Information Commissioner/ OAIC on 1300 363 992
Phone: 1300 363 992
Web: www.oaic.gov.au
Office of the Health Complaints Commissioner
Phone: Victoria – 1300 582 113 Web: www.hcc.vic.gov.au