Background and Rationale
The Australian Privacy Principles (APP) provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APP consists of 13 principle-based laws that apply equally to paper-based and digital environments. The APP complements the long-standing general practice obligation to manage personal information in a regulated, open and transparent manner.
This policy will guide Platinum Health Group staff in meeting these legal obligations. It also details to patients how Platinum Health Group uses their personal information. The policy must be made available to patients upon request.
Platinum Health Group Procedure
Platinum Health Group will:
• Provide a copy of this policy upon request
• Ensure staff comply with the APP and deal appropriately with inquiries or concerns
• 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.
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
• Platinum Health Group’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.
Platinum Health Group will only interpret and apply a patient’s consent for the primary purpose for which it was provided. Platinum Health Group staff must seek additional consent from the patient if the personal information collected may be used for any other purpose.
Collection of Information
Platinum Health Group will need to collect personal information as a provision of clinical services to a patient at the practice. Patient information is collected on the Patient Registration Form. Collected personal information will include patients’:
• Names, addresses and contact details
• Medicare number (where available) (for identification and claiming purposes)
• Healthcare identifiers
• Medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors.
A patient’s personal information may be held at Platinum Health Group in various forms:
• Paper records
• Electronic records
• Visual – x-rays, CT scans, videos and photos
• Audio recordings.
The Practice’s procedure for collecting personal information is set out below.
Platinum Health Group staff collects patients’ personal and demographic information via registration when patients present to Platinum Health Group 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.
During the course of providing medical services, the Practice’s healthcare practitioners will consequently collect further personal information.
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.
Platinum Health Group participates in the personally controlled electronic health record system (PECHR). This record is designed to contain an electronic summary of your key health information. It is the patient’s choice to register for and control their eHealth record. The patient’s Individual Health Identifier is stored in the patient’s electronic record.
Platinum Health Group holds all personal information securely in electronic format using a password-protected information system or in hard copy format in an access-controlled environment.
Use and Disclosure of Information
Personal information will only be used for the purpose of providing medical services and for claims and payments unless otherwise consented to. Transfer of personal information for the provision of medical services is done using an encrypted messaging system, fax or letter.
Some disclosure may occur to third parties engaged by or for Platinum Health Group for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy.
Platinum Health Group will inform the patient where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).
Platinum Health Group 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.
Platinum Health Group will not disclose personal information to anyone outside Australia without need and without patient consent.
Exceptions to disclose without patient consent are where the information is:
• 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 consent
• To assist in locating a missing person
• To establish, exercise or defend an equitable claim
• For the purpose of a confidential dispute resolution process.
Platinum Health Group 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 Platinum Health Group in a letter or email.
Platinum Health Group evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.
Access, Corrections and Privacy Concerns
Platinum Health Group acknowledges patients may request access to their medical records. Patients are encouraged to make this request in writing and sent attention of the General Manager or email [email protected]; Platinum Health Group will respond within a reasonable time.
Platinum Health Group will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, Platinum Health Group will ask patients to verify the personal information held by Platinum Health Group is correct and up to date. Patients may also request Platinum Health Group corrects or updates their information, and patients should make such requests in writing and send attention of the General Manager or email [email protected]
Platinum Health Group takes complaints and concerns about the privacy of patients’ personal information seriously. Patients should express any privacy concerns in writing or speak with the Practice Manager. Platinum Health Group will then attempt to resolve the matter in accordance with its complaint resolution procedure. Patients may also contact the Office of the Health Ombudsman, PO Box 13281 George St, Brisbane QLD 4003 Phone 133646, email: [email protected] or the Office of the Australian Information Commissioner 1300 363 992, www.oaic.gov.au