AUSTRALIAN PRIVACY PRINCIPLES (app) Policy
Part A – Purpose and Context
1.0 Graceville Medical is committed to ensuring the privacy and confidentiality of all personal information affiliated with the Graceville Medical’s business undertakings.
1.1 Graceville Medical follows the terms and conditions of privacy and confidentiality in accordance to the Australian Privacy Principles (APPs) as per schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), forming part of the Privacy Act 1988 (‘the Act’).
1.3 The point of contact regarding any queries regarding this policy is the Practice Manager at firstname.lastname@example.org.
Part B – Australian Privacy Principles
2.0 As a private sector health service provider and under permitted health situations, Graceville Medical is required to comply with the APPs as prescribed under the Act.
2.1 The APPs regulate how Graceville Medical may collect, use, disclose and store personal information and how individuals, including Graceville Medical’s patients may:
- address breaches of the APPs by Graceville Medical;
- access their own personal information; and,
- correct their own personal information.
2.2 In order to provide patients with adequate health care services, Graceville Medical will need to collect and use personal information. It is important to be aware that if the patient provides incomplete or inaccurate information or the patient withholds personal health information Graceville Medical may not be able to provide said patient with the services they are requesting.
- “personal information” as defined by the Privacy Act 1988 (Cth). Meaning
“information or an opinion including information or an opinion forming part of a database, whether true or not, and whether recorded in a material format or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion”; and,
- “health information” as defined by the Privacy Act 1988 (Cth). This is a particular subset of “personal information” and means information or an opinion about:
– the health or a disability (at any time) of an individual;
– an individual’s expressed wishes about the future provision of health services to him or her; or,
– a health service provided or to be provided to an individual.
2.3.1 Personal information also includes ‘sensitive information’ which is information including, but not limited to a patient’s:
- political opinions;
- sexual preferences; and or,
- health information.
2.3.2 Information deemed ‘sensitive information’ attracts a higher privacy standard under the Act and is subject to additional mechanisms for the patient’s protection.
Part C – Types of personal information
3.0 Graceville Medical collects information from each individual patient that is necessary to provide said patient with adequate health care services.
3.1 This may include collecting information about a patient’s health history, family history, ethnic background or current lifestyle to assist the health care team in diagnosing and treating a patient’s condition.
Part D – collection & Retention
4.0 This information will in most circumstances be collected directly from you via a Patient Registration form, treatment form, medical consult form, face to face consultation etc.
4.1 In other instances, Graceville Medical may need to collect personal information about a patient from a third party source. This may include:
- relatives; or,
- other health service providers.
4.2 This will only be conducted if the patient has provided consent for Graceville Medical to collect his/her information from a third party source; or, where it is not reasonable or practical for Graceville Medical to collect this information directly from said patient. This may include where:
- the patient’s health is potentially at risk and his/her personal information is needed to provide them with emergency medical treatment.
4.3 Graceville Medical endeavours to store and retain a patient’s personal & health information electronically onto a domestic server.
Part E – Purpose of collection, Use & Disclosure
5.0 Graceville Medical only uses a patient’s personal information for the purpose(s) they have provided the information for unless one of the following applies:
- the patient has consented for Graceville Medical to use his/her information for an alternative or additional purpose;
- the disclosure of the patient’s information by Graceville Medical is reasonably necessary for the enforcement of criminal law or a law imposing a penalty or sanction, or for the protection of public revenue;
- the disclosure of the patient’s information by Graceville Medical will prevent or lessen a serious and imminent threat to somebody’s life or health; or,
- Graceville Medical is required or authorised by law to disclose your information for another purpose.
i. Health Professionals to provide treatment
During the patient’s treatment at Graceville Medical he/she may be referred to specialist doctors, alternative medical treatment/services (i.e. pathology or radiology etc) where The Health Service’s staff may consult with senior medical experts when determining a patient’s diagnosis or treatment.
Graceville Medical’s staff may also refer the patient to other health service providers for further treatment during and following the patient’s admission (i.e. physiotherapist or outpatient or community health services).
These health professionals will be designated health service providers appointed to use the patient’s health information as part of the process of providing treatment. Please note that this process will be conducted whilst maintaining the confidentiality and privacy of the patient’s personal information.
ii. Alternative Health services
If at any point a patient wishes to be treated by an alternative medical practitioner or health care service that requires access to his/her personal/health information, Graceville Medical requires written authorisation. This written authorisation is to state that the patient will be utilising alternative health services and that these health services have consented for a transfer of personal/health information.
iii. Other Third Parties
Graceville Medical may provide your personal information regarding a patient’s treatment or condition to additional third parties. These third parties may include:
- other relatives;
- close personal friends;
- guardians; or,
- a person exercising a patient’s power of attorney under an enduring power of attorney.
Where information is relevant or reasonable to be provided to third parties, written consent from the patient is required.
Additionally, the patient may at any time wish to disclose that no third parties as stated are to access or be informed about his/her personal information or circumstances.
iv. Other Uses of Personal Information
In order to provide the best possible environment in which to treat patients, Graceville Medical may also use personal/health information where necessary for:
- activities such as quality assurance processes, accreditation, audits, risk and claims management, patient satisfaction surveys and staff education and training;
- invoicing, billing and account management;
- to liaise with a patient’s health fund, Medicare or the Department of Veteran’s Affairs, as necessary; and,
- the purpose of complying with any applicable laws – i.e. in response to a subpoena or compulsory reporting to State or Federal authorities.
5.1 If at any point or for any of the aforementioned reasons Graceville Medical uses or discloses personal/ health information in accordance with the APPs, Graceville Medical will provide written notice for the patient’s consent for the use and/or disclosure.
Part F – Access and changes to personal information
6.0 If an individual patient reasonably requests access to their personal information for the purposes of changing said information he/she must engage with the relevant practice manager.
6.1 The point of contact for patient access to personal information is:
Jan Ford or Erin Hudson
07 3379 1831
Monday to Thursday
6.2 Once an individual patient requests access to his/her personal information Graceville Medical will respond within a reasonable period of time to provide said information.
6.3 All personal information will be updated in accordance to any changes to a patient’s personal circumstances brought to Graceville Medical’s attention. All changes to personal information will be subject to patient’s consent and acknowledgement.
6.4 If an individual accesses his/her personal information or is supplied a copy, Graceville Medical will most probably charge a fee equivalent to a Standard Consultation + GST, unless extraordinary extra work is involved. A Medicare rebate will not apply.
Part G – Complaints handling
7.0 How an individual patient may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint.
7.1 If an individual wishes to lodge a formal complaint against Graceville Medical, it must be lodged in written form and addressed to the Practice Manager. A response will be made within a reasonable period.
7.2 If an individual is not satisfied with the outcome of the process of the initial complaint he/she may refer to the HQCC (Health Quality and Complaints Commission)
Part H – Personal Information and overseas recipients
8.0 Use of Overseas Parties:
(a) Graceville Medical does not engage with any overseas entities, with which personal or health information would be transferred, appointed or disclosed for the purpose of dictation or transcription.
(b) Graceville Medical does engage with overseas entities, with which personal or health information would be transferred, appointed or disclosed, where a patient has provided Graceville Medical with a written request and consent signed by the patient or his/her agent. These overseas entities may include:
- International Insurance agencies
- International Legal Firms
iii. International medical practices
In these cases, Graceville Medical does not guarantee that these entities will comply with the APPS, the onus for this resting with the patient who makes the request.
Part i – Disposal of personal/health information
9.0 If Graceville Medical receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Graceville Medical will reasonably de-identify and dispose of said information accordingly.
9.1 If Graceville Medical holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Graceville Medical will reasonably de-identify and dispose of said information accordingly.
Part J – Access to policy
Hard copy provided on request
Part K – Review of Policy
11.1 Graceville Medical in accordance with any legislative change will review the terms and conditions of this policy to ensure all content is both accurate and up to date.