Last updated: 15 January 2021

Introduction

This privacy policy is to provide information to Health104 patients on how your personal information (which includes your health information) is collected and used within the practice, and the circumstances in which we may share it with third parties.

We are required by law to make this policy available to you.

We manage your personal information respectfully and our policies are like most high-quality general practices throughout Australia.

This information sheet outlines:

• the details of how we manage your information and,
• How our practice will access and use your personal information.

When you register as a patient of the practice, you will be provided with a registration form (view the registration form online)  that informs you that our doctors, nurses and practice staff will access and use your personal information so we can provide you with high quality and safe healthcare.

Our patient registration form also informs you that we send Health Reminders and SMS reminders and provides an opportunity to share with us any concerns you may have about this.

We document consent to communicate with you via SMS messages within our Clinical Information System (CIS).

Why and when your consent is necessary

When you register as a patient of our practice, you provide consent for our GPs, allied health professional and other 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.

When submitting a new patient registration form, you:

• acknowledge that your health practitioner (Health104) and the online booking system HotDoc Online Pty Ltd (HotDoc) will collect such information (including any personal or sensitive information), for the purposes of providing you with health services or enabling any related communications;
• and Consent to HotDoc’s Terms of Use (https://www.hotdoc.com.au/practices/terms-of-service-patients/), and to HotDoc handling your personal and sensitive information in accordance with its Privacy Policy (https://www.hotdoc.com.au/practices/privacy-policy/ )

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, accreditation, and business processes (eg staff training).

Our practice will do their best to make sure your medical records:

• Are accurate, comprehensive, well-organised and legible are up to date
• Have enough information to allow another doctor to care for you
• Contain a summary of your care and
• Can be used to remind you, with your permission, to return for follow up tests, check-ups and reviews.

Our practice will collect information we feel is relevant to your medical care. If you are uncertain as to why information is being requested, please ask us for an explanation.

The doctors, nurses and staff of this practice respect your right to decide how your personal health information is used or disclosed (for example to other doctors, hospitals and allied health providers).

It is important that additional people involved in your care, such as other doctors, or other healthcare providers are informed of relevant parts of your medical history so they can best care for you. After discussion with you, your doctor may write a letter or referral to a specialist or another healthcare provider such as a physiotherapist.

This referral will generally be given to you to take to them and some referrals may also be sent electronically. If you have any concerns about this process, please discuss these with your doctor at the time of the referral.

The practice is also registered for the My Health Record system and if you are also registered for the My Health Record system, with your permission, we will share appropriate information via the My Health Record Shared Health Summaries and Event Summaries. When available in My Health Record in future, pathology and imaging reports and other documents may also be shared.

In most practices, it is customary for all doctors in the practice to have access to all the medical records. If you would like to limit which doctors at this practice are able to see your record, please let your doctor know. It is possible to mark consultations or whole files as confidential, in which case only the doctor that made the notes can access that record. However, this may create a risk for you if other doctors are not able to access important information about you in a consult, it is important all doctors are able to deliver safe and high-quality health care to you.

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), DVA card or Pension Card for identification and claiming purposes
• Healthcare identifiers (Healthcare Identifiers is a number that identifies a patient for healthcare purposes.)
• Health fund details (where applicable).

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.

Please note that by accessing care under anonymously or under a pseudonym, we may not be able to contact you to follow up abnormal results or recalls and you will not be able to access Medicare rebates, Pharmaceutical Benefits or private Insurance rebates.

How do we collect your personal information?

Our practice may collect your personal information in several different ways.

1. When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
2. 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.

3. 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.
4. 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 (e.g. 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 (e.g. some diseases require mandatory notification)
• during the course of providing medical services, through Electronic transfer of prescriptions (eTP), My Health Record (e.g. via Shared Health Summary, Event Summary).
• If the information is necessary to obtain Medicare payments or other Health Insurance rebates.

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.

With your permission, 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.

Parents/Guardians and Children

To protect the rights of a child’s privacy, access to a child’s medical information may at times be restricted for parents and guardians. Release of information may be referred back to the treating Doctor where their professional judgement and the law will be applied.

Quality Improvement and Research

De-identified health information is used to improve the quality of care we provide. Research may also be undertaken using de-identified data if an appropriately constituted ethics committee has approved the activity.

Recalls and Reminders

We may send out reminders by phone, SMS and by mail from time to time for scheduled health care services and may text to confirm appointments.

We do not regard this as direct marketing. Please let us know if you have any concerns about this.

We will not use your personal information for marketing of goods or services to you without your express consent. If you do consent, you may opt-out at any time by notifying us in writing.

How do we store and protect your personal information?

Your personal information may be stored at our practice in various forms. E.g. as paper records, electronic records, visual records (X-rays, CT scans, videos and photos).

Our practice stores all personal information securely.

– electronic format: in protected information systems with the use of passwords

– hard copy format in a secured environment with lockable cabinets

– confidentiality agreements for staff and contractors.

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.

You may ask your doctor about any aspect of your health care, including information in your record.

We believe that sharing information is important for good communication between you and your doctor and for good health care.

Information in your record can be provided to you by way of an accurate and up-to-date summary of your care, for instance if you are moving away and are transferring to a new doctor. Do not hesitate to ask your doctor if you want a summary of your care for any reason.

Your doctor will be pleased to provide a full explanation of your health summary or medical record, usually scheduling an appointment is the best way to do this.

Our practice acknowledges patients may request access to their medical records. We require you to put this request in writing and our practice will respond within a reasonable time. We require this request to be in writing and addressed to:

Practice Manager
Health104
104 Canterbury Rd
Middle Park VIC 3206
Phone: 1300 003 082

Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, 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 to the above mentioned address.

How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?

If you have concerns about any aspect of the service/s you have received, please email or talk to the Practice Manager or Director and discuss your concerns. We take complaints very seriously and will listen closely to your concerns or complaints as we are keen to constantly improve our services and help you stay well for longer. Please address your concerns to:

Practice Manager
Health104
104 Canterbury Rd
Middle Park VIC 3206
Phone: 1300 003 082

We believe problems are best dealt directly with the practice. However, if you feel the need to discuss a matter outside the practice you can contact:

Health Complaints Commissioner
26/570 Bourke St
Melbourne VIC 3000
Phone: 1300 582 113

You may also contact the Office of Australian Information Commissioner (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

To improve your experience on our site, we may use ‘cookies’. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

Our website also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or “share” information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other Personal Information

Links to external websites

This Privacy Statement does not extend beyond this website.

When following links to other sites from this website, we recommend that you read the privacy statement of that site to familiarise yourself with its privacy practices.

Social Media

Please be aware it is against Practice Policy for staff to accept Facebook or other social media friend requests from patients.

Policy review statement

This privacy policy will be reviewed regularly to ensure it is in accordance with any legislative changes that may occur. Updated policies will be posted on our website and will be available from reception on request.

Helpful Resources

• The Australian Medical Association (AMA) has useful information about online professionalism for medical practitioners and medical students. It is available at https://ama.com.au/article/ social-media-and-medical-profession
• Information on the Australian Privacy Principles is available at https://www.oaic.gov.au/privacy/australian-privacy-principles/
• The Australian Privacy Principles form part of the Privacy Act 1988, available at www.legislation.gov.au/Details/C2016C00838
• The OAIC lists each state and territory’s privacy legislation, available at www.oaic.gov.au/ privacy-law/other-privacy-jurisdictions