Our website address is: https://thornliesquaremedicalcentre.com.au.

PRIVACY POLICY

This template covers:

• Practice procedures
• Staff responsibilities
• Patient consent
• Collection, use and disclosure of information
• Access to information

Purpose

To ensure patients who receive care from Thornlie Square Medical Centre are comfortable in entrusting their health information to Thornlie Square Medical Centre. This policy provides information to patients as to how their personal information (which includes their health information) is collected and used within Thornlie Square Medical Centre, and the circumstances in which we may disclose it to third parties.

Related Standards

RACGP Compliance indicators for the Australian Privacy Principles: and addendum to the computer and information security standards (Second edition).

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 and 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 Thornlie Square Medical Centre staff in meeting these legal obligations. It also details to patients how Thornlie Square Medical Centre uses their personal information. The policy must be made available to patients upon request.

Practice Procedure

Thornlie Square Medical Centre 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.

Staff Responsibility

Thornlie Square Medical Centre 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
• Thornlie Square Medical Centre’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.

Patient Consent

Thornlie Square Medical Centre will only interpret and apply a patients’ consent for the primary purpose for which it was provided. When a patient registers, they provide consent for our GP’s and practice staff to access and use their personal information so they can provide the best possible healthcare. Thornlie Square Medical Centre staff must seek additional consent from the patient if the personal information collected may be used for any other purpose.

Collection of information

Thornlie Square Medical Centre will need to collect, use, hold and share personal information as a provision of clinical services to a patient at the practice. Collected personal information will include patients’:

• Names, date of birth, addresses and contact details
• Medicare number (where available) for identification and claiming purposes
• Healthcare identifiers and health fund details
• 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 Thornlie Square Medical Centre in various forms:

• As paper records
• As electronic records
• As visual – x-ray, CT scans, videos and photos
• As audio recordings.

Thornlie Square Medical Centre’s procedure for collecting personal information is set out below.

1. Thornlie Square Medical Centre staff collect patients’ personal and demographic information via registration when patients present to the Practice 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.
2. During the course of providing medical services, Thornlie Square Medical Centre’s healthcare practitioners will consequently collect further personal information.
3. Thornlie Square Medical Centre may also collect personal information when patients visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media.
4. Personal information may also be collected from other sources, when practical and necessary. This may include information from:
   • the patients’ guardian or responsible person,
   • other involved healthcare specialists, allied health professionals, hospitals, community health services and pathology/diagnostic imaging services,
   • the patients’ health fund, Medicare or the Department of Veteran’s Affairs (as necessary)

Thornlie Square Medical Centre holds all personal information securely, whether in electronic format, in protected information systems or in hard copy format in a secured environment.

Use and Disclosure of Information

Personal information will only be used for the purpose of providing medical services and for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training). Some disclosure may occur to third parties engaged by or for Thornlie Square Medical Centre business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with APPs and this policy. Thornlie Square Medical Centre will inform the patient where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).

Thornlie Square Medical Centre 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. Thornlie Square Medical Centre 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
• Other health care providers
• 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
• 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 Electronic Transfer of Prescriptions (eTP), MyHealth Record/PCEHR system (eg via Shared Health Summary, Event Summary).

Thornlie Square Medical Centre will not use any personal information in relation to direct marketing to a patient without that patients’ express consent. Patients may opt-out of direct marketing at any time by notifying Thornlie Square Medical Centre in a letter or email.

Thornlie Square Medical Centre evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.

Access, Corrections and Privacy Concerns

Thornlie Square Medical Centre acknowledges patients may request access to their medical records. Patients are encouraged to make this request in writing, and Thornlie Square Medical Centre will respond within a reasonable time.

Thornlie Square Medical Centre will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, Thornlie Square Medical Centre will ask patients to verify the personal information held by the practice is correct and up to date. Patients may also request Thornlie Square Medical Centre corrects or updates their information, and patients should make such requests in writing.

Thornlie Square Medical Centre takes complaints and concerns about the privacy of patients’ personal information seriously. Patients should express any privacy concerns in writing to the Practice Manager at info@forrestroadgp.com.au.

Thornlie Square Medical Centre will attempt to resolve any complaint in accordance with its complaint resolution procedure.

Under health services (conciliation and review) Act 1987 people with complaints should try to resolve them directly with the health service provider. Patients 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 336 002. If a satisfactory outcome is not achieved then the complaint can go directly to the Health Services Commissioner for action.

The public may also call the Health and Disability Services Complaints Office (HaDSCO) on 1800 813 583 at any time concerning a query to report a complaint.

The Australian Privacy Commissioner is able to receive complaints concerning privacy issues. Complaints should have a response within 28 days;

Australian Privacy Commissioner

Privacy hotline 1300363992

GPO Box 5218

Sydney NSW 2001

http:// www.privacy.gov.au/complaints

Members of the public may make a notification to Australian Health Practitioner Regulation Agency (AHPRA) http://www.ahpra.gov.au about the conduct, health or performance of a practitioner or the health of a student. Practitioners, employers and education providers are all mandated by law to report notifiable, conduct relating to a registered practitioner or student of AHPRA.

Policy Review Statement

This privacy policy will be reviewed regularly to ensure it is in accordance with any changes that may occur and patients will be notified when Thornlie Square Medical Centre amends this policy.