This policy covers:
- practice procedures
- staff responsibilities
- patient consent
- collection, use and disclosure of information
- access to information.
The policy is designed to communicate to patients how a practice manages personal information and to complement other practice policies such as complaint resolution and breach notification procedures.
This policy was developed with assistance from the Office of the Australian Information Commissioner (OAIC) and was current at time of publication.
For more information on privacy visit www.oaic.gov.au, or for privacy policies for GPs, visit www.oaic.gov.au/privacy/privacy-resources/training-resources/privacy-policies-for-gps
This policy is freely available for our patients to view on our website: www.keysmedicalcentre.com.au/privacy-policy. Please note that this policy will be referenced in our registration forms and other consent forms and notices, and patients are encouraged to keep up to date with the information presented here.
This policy will be reviewed regularly to ensure it remains applicable to current practice procedure and legal requirements.
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).
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.
- When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
- During the course of providing medical services, we may collect further personal information. Information can also be collected through electronic transfer of prescriptions (eTP), My Health Record, eg via Shared Health Summary, Event Summary, etc.
- 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.
- 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. Keys Medical Centre does not, under any circumstances, send information overseas. If this changes, you will be notified posthaste.
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 optout of direct marketing at any time by notifying our practice in writing.
Our practice may use your personal information to improve the quality of the services we offer to our patients through research and analysis of our patient data.
We may provide de-identified data to other organisations to improve population health outcomes. The information is secure, patients cannot be identified and the information is stored within Australia. You can let our reception staff know if you do not want your information included.
How do we store and protect your personal information?
Your personal information may be stored at our practice in various forms. This may include, paper records, electronic records stored on a remote cloud system, and visual records such as X-rays, CT scans, videos, or photos.
Our practice stores all personal information securely. We store most information electronically, through a secure cloud-based system with routine updates and backups. All of the information is in password protected information systems and software, or in hard copy stored in a secure environment. All staff on the premises, as well as IT Support contractors, have signed confidentiality agreements regarding patients’ personal information.
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 transfer of their medical records to another practice. We require you to put this request in writing with signed consent and authority and our practice will respond within a reasonable time. Usually the request is processed within 30 days, unless it has been specified as urgent in nature. Patients are not charged for their own medical records at this practice. However, any companies acting on behalf of you may be charged in accordance with the type of information required.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or uptodate. From timetotime, 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 email@example.com or firstname.lastname@example.org.
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. Please send any complaints and concerns directly to email@example.com or via mail to Keys Medical Centre, 1/211-215 Chapel Road, Keysborough VIC 3173. Please contact us on 8759 3807 for more information or to speak with a manager. We generally aim to respond within 48 hours of receipt of a complaint, and aim for resolution within 30 days. Complaints are forwarded to the practice manager and they will contact you directly within 48 hours; this may be through writing, email, registered mail, or phone call.
You may also contact the 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
Policy review statement