Privacy Policy

Introduction

As an Australian-based organisation, any data and information collected is held, used and disclosed in accordance with the Privacy Act 1988.

This privacy policy is to provide information to you, our patient, on how your personal information including your health information is collected and used within our practice, and the circumstances in which we may share it with third parties.

Our legal obligations

As a private sector health service provider, Brunswick Doctors is required to comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) of Australia.

To provide you with health care services, Brunswick Doctors needs to collect and use your personal information. If you provide incomplete or inaccurate information to us, or choose to withhold personal health information from us, we may not be able to provide you with the services you are seeking.

Privacy Officer

This practice has a designated privacy officer who implements and monitors adherence to all privacy legislation in this practice.

The privacy officer acts as liaison for all privacy issues and requests for access to patient personal health information.

Matt Mahon, is our practice’s designated privacy officer.

The privacy officer is responsible for ensuring compliance with the Privacy Act 1988 and the Australian Privacy Principles and for developing and maintaining our written protocols. The privacy officer liaises with the person responsible for our computer security and systems to ensure our electronic systems remain compliant.

If any members of the public or of our practice team have any queries concerning privacy laws and how our practice manages adherence to these laws, these queries are directed to the privacy officer.

Definition

Personal health information & Patient’s health record-

‘Personal health information’ is a particular subset of personal information and can include any information collected about a person in order to provide a health service.

‘Patient’s health record’ includes the formal health record (written or electronic) and information held or recorded on any other medium (e.g. letter, facsimile, electronic, verbal).

These can include but not limiting to:

Notes recorded during a consultation with a health care provider

Any information conveyed to practice staff verbally in person or over the phone

Correspondence received from patient, specialists, other health care providers or other relevant agencies

Why and when your consent is necessary

When you register as a patient of our practice, whether it is through our website or verbally with one of our staff members, 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.

Our clinic uses a secure check-in platform to collect your information when you register for your first consultation.The digital registration form will ask you to agree to our Privacy Policy and how we use your information. 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?

We collect information from you that is necessary to provide you with health care services and to assist our health care team in diagnosing and treating your condition.

Often this includes:

Personal details: names, date of birth, employment and other demographic data

Your ethnic background or your current lifestyle: alcohol consumption & smoking history

Contact details: phone numbers, addresses, email & emergency contact

Medical details: family information, past medical and social history, current health issues and future medical care

Medicare numbers & health identifier (where available) for identification and claiming purposes

Payment & account details: credit card or direct debit information

Health fund details

Formal health record (written or electronic)

Results, reports or referrals received from other health care providers

and any health information such as a medical or personal opinion about a person’s health, disability or health status.

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 will collect your personal and demographic information via your registration. This can include any information you’ve entered through our digital registration form, on our website or verbally communicated to our staff in person. Our practice has a collection statement within the digital patient registration form which collect consent from you for us to use your information.

During the course of providing medical services, we may collect further personal information through electronic transfer of prescriptions (eTP), My Health Record via Shared Health Summary and Event Summary.

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 as well as your emergency contact

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).

How do we use your information?

Brunswick Doctors only uses your personal information for the purpose you have given the information to us unless one of the following applies:

The other purpose is directly related to the purpose for which you have given us the information and you would reasonably expect, or we have told you, that your information is usually disclosed for another purpose or to other individuals, organisations or agencies;

You have consented for us to use your information for another purpose;

We are required or authorised by law to disclose your information for another purpose;

The disclosure of your information will prevent or lessen a serious and imminent threat to somebody’s life or health;

1. Use among our staff involved in your care

Our health care practices mean that your treatment will be provided by a team of staff who work together. Our staff will share your health information as part of the process of providing your treatment and ongoing care. Your health information will only be disclosed to our staff who are involved in your treatment. The confidentiality of your information and your privacy will be protected at all times in accordance with the law.

2 Other health service providers

If in the future you are being treated by another health practitioner who needs to have access to the health record of your treatment at Brunswick Doctors, we will require prior written consent from you to provide a copy of your record.

The only time we would provide information about your health records to another medical practitioner without your consent is in the event of an emergency where your life is at risk and you are not able to provide consent.

3 Relatives, guardian, close friends or legal representative

We may provide information about your condition to your parent, child, other relatives, close personal friends, guardians, or a person exercising your power of attorney under an enduring power of attorney, unless you tell us that you do not wish us to disclose your health information to any such person.

4 Research purposes

Brunswick Doctors may use your health information, in a de-identified format, for research and teaching purposes. You can opt out of such use of your information by notifying us at any time without prejudicing your care and treatment.

5 Other Brunswick Doctors entities

Brunswick Doctors may share your health information amongst its facilities listed at the end of this Privacy Policy. For example, this may occur where you are transferred between any of Brunswick Doctors’s facilities or to coordinate your care.

6 Other common uses

In order to provide the best possible environment in which to treat you, we may also use your 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 your health fund as necessary; and

The purpose of complying with any applicable laws – for example, in response to a subpoena or compulsory reporting to State or Federal authorities (for example, for specified law enforcement or public health and safety circumstances).

7 Contractors

Where we outsource any of our services or hire contractors to perform professional services within our clinics we require them to also comply with the Privacy Act 1988 (Cth) (or other relevant privacy legislation) and our Privacy Policy.

8 Other uses with your consent

With your consent we can also use your information for other purposes such as including you on a marketing mailing list. Please note, however, that unless you provide us with your express consent for this purpose, we will not use your information in this way.

Please note, Brunswick Doctors may use or disclose your personal information as specified above via electronic processes, where available or relevant.

How the Practice uses document automation technologies

Brunswick Doctors relies on our Clinic Management Software (CMS), Best Practice Software, for a number of document automation and security measures. These include templates and autofill capabilities that insert medically relevant patient information into referrals within a patients health record. It is ultimately the responsibility of the Medical Practitioner to determine what information is medically necessary to be include in referral letters, such as specialist letters, referrals to imaging and pathology centres, and can include or omit relevant information as they see fit. The softwares and electronic systems we employ are password protected and members of the practice team have different levels of access to patient personal health information as appropriate to their roles.

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.

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 opt out of direct marketing at any time by notifying our practice in writing.

How do we store and protect your personal information?

1. Data quality and security

Brunswick Doctors will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date. We will also take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect your privacy.

Personal health information is kept where only those with authorisation can access it, and is kept out of view of and unable to be accessed by the public.

All softwares and electronic systems in our facility is passcode protected. Members of the practice team have different levels of access to patient personal health information as appropriate to their roles and, to maintain security all computer hardware and software passwords are kept confidential and are not disclosed to others.

Each member of our practice team as well as any contractors that we work with are bound by a confidentiality agreement, which is signed upon commencement of working at our practice.

2. How we store your personal information

Our practice is considered paperless, therefore all paper record that we receive from other health care providers such as letters, results, reports, X-rays, video, photos or audio recordings will be turned into soft copies and stored in the practice management softwares. the paper record will then be destroyed securely at our facility.

The personal health information we collect and store in an electronic format is hosted by Internet Service Providers with servers located in Australia. Such information is unlikely to be disclosed to overseas recipients. We will destroy or permanently de-identify any of your information which is no longer needed.

Access to and correction of your health information

You have a right to have access to the health information that we hold in your health record. You can also request an amendment to your health record should you believe that it contains inaccurate information.

Brunswick Doctors will allow access or make the requested changes unless there is a reason under the Privacy Act 1988 (Cth) or other relevant law to refuse such access or refuse to make the requested changes.

If we do not agree to change your medical record/personal information in accordance with your request, we will permit you to make a statement of the requested changes and we will enclose this with your record.

Should you wish to obtain access to or request changes to your health record you can ask for our Privacy Officer (see details below) who can give you more detailed information about Brunswick Doctors’s access and correction procedure.

Please note that Brunswick Doctors may recover reasonable costs associated with supplying this information to you.

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. If you have a complaint about privacy issues, or if:

You have questions or comments about this Privacy Policy;

Brunswick Doctors does not agree to provide you with access to your personal information; or

You have or a complaint about our information handling practices,

You can lodge a complaint with or contact our Privacy Officer on the details below. Please allow 30 days turnaround time for us to thoroughly investigate your concern.

By letter: Privacy Officer,

Brunswick Doctors,

55 Albion Street, Brunswick
VIC 3056

By email: info@brunswickdoctors.com.au

By telephone: (03) 9383 4155

If we are unable to resolve your issue, 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.

Information we collect from our website

This section of our Privacy Policy explains how we handle your personal information which is collected from our website: www.brunswickdoctors.com.au

This Privacy Policy applies to your use of our website and the use of any of the facilities on our website.

When you use our website, we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us.

Sometimes, we may collect your personal information if you choose to provide this to us via an online form or by email, for example, if you:

Post a comment on an article we have published;

Submit a general enquiry via our contacts page;

Send a written complaint or enquiry to our Privacy Officer.

When you use our website, our Internet Service Provider (ISP) will record and log for statistical purposes the following information about your visit:

Your computer address;

Your top level name (for example, .com,.gov, .org, .au etc);

The date and time of your visit;

The pages and documents you access during your visit; and

The browser you are using.

Our web-site management agent may use statistical data collected by our ISP to evaluate the effectiveness of our web-site.

We are, however, obliged to allow law enforcement agencies and other government agencies with relevant legal authority to inspect our ISP logs, if an investigation being conducted warrants such inspection.

Cookies

A “cookie” is a device that allows our server to identify and interact more effectively with your computer. Cookies do not identify individual users, but they do identify your ISP and your browser type. This website uses temporary cookies. This means that upon closing your browser, the temporary cookie assigned to you will be destroyed and no personal information is maintained which will identify you at a later date. Personal information such as your email address is not collected unless you provide it to us. We do not disclose domain names or aggregate information to third parties other than agents who assist us with this website and who are under obligations of confidentiality. You can configure your browser to accept or reject all cookies and to notify you when a cookie is used. We suggest that you refer to your browser instructions or help screens to learn more about these functions. However, please note that if you configure your browser so as not to receive any cookies, a certain level of functionality of the Brunswick Doctors website and other websites may be lost.

Links to third party websites

We may create links to third party websites. We are not responsible for the content or privacy practices employed by websites that are linked from our website.

Use and disclosure

We will only use personal information collected via our website for the purposes for which you have given us this information. We will not use or disclose your personal information to other organisations or any one else unless:

You have consented for us to use or disclose your personal information for this purpose;

You would reasonably expect or we have told you that your information is usually used or disclosed to other organisations or persons in this way;

The use or disclosure is required or authorised by law;

The use or disclosure will prevent or lessen a serious or imminent threat to somebody’s life or health; or

If we receive your email address because you sent us an email message, the email will only be used or disclosed for the purpose for which you have provided and we will not add your email address to an emailing list or disclose this to anyone else unless you provide us with consent for this purpose.

Data quality and security

If we collect your personal information from our website, we will maintain and update your information as necessary or when you advise us that your personal information has changed. Brunswick Doctors is committed to protecting the security of your personal information. We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of information. We will take all reasonable steps to prevent your information from loss, misuse or alteration. If you choose to complete our online forms or lodge enquiries via our website, we will ensure that your contact details are stored on password protected databases. Staff members associated with website maintenance have access to our website’s backend system. This is password protected. Our website service is also password protected.

The information we collect and store from our website is hosted by Internet Service Providers with servers located in the United States.

Access and correction

If you wish to obtain information about how to access or correct your personal information collected via our website, please contact our Privacy Officer using the details below.

Policy review statement

The privacy policy is reviewed regularly to ensure these policies and procedures are up-to-date. In the event of any issues or complaints relating to privacy matters, we also conducts a review in accordance to our review procedure outlined beloww:

Review Procedure

The privacy officer reviews the following items:

· What is the primary purpose of this practice?

· What data do we collect and document?

· How do we store this information?

· What data do we disclose and to whom?

· When and how do we obtain patient consent?

Information is collected from hard copy and electronic storage devices, and issues are discussed with the general practitioners and other practice team members to gain the most current information.