Privacy Policy

Introduction

North Rockhampton Medical Centre is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

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

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

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 (this is done when you complete our Patient Registration Form). 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 (e.g. 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 (if applicable)

What is a Patient Health Record? 

A patient health record is the information held about a patient, in paper form or electronic form, which may include

• • contact and demographic Information
  • medical history
  • notes on treatment
  • observations
  • correspondence
  • investigations
  • test results photographs
  • prescription records
  • medication charts
  • insurance information
  • legal information and reports
  • work health and safety reports

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.

1. 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 My Health Record, Department of Human Resources (Medicare) and National Databases such as the Australian Immunisation Register and National Cancer Screening Register.
   3. We may also collect your personal information when you send us an email, 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 eTP, My Health Record (e.g. via Shared Health Summary, Event Summary).  North Rockhampton Medical Centre participates in My Shared Health Summary which is uploaded to the patient’s MyGov account of which they can confirm or opt out.
  • 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.
  • The practice uses document automation technologies, particularly so that only the relevant medical information is included in referral letters.
  • The practice always obtains informed consent either verbal or written for real-time audio/visual recording, duplication and storage of a consultation including those via telehealth or those conducted remotely.

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. 

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 organizations 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 electronic form only (your administrative file as well as your clinical file).  Access to your file is limited to GP’s, nurses and Practice Manager

Our practice stores all personal information securely. 

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 access to their medical records. We require you to put this request in writing (submit a signed consent form, together with a $20 fee) and our practice will respond within 10 working days.  The fee is an administrative fee for the preparation of the records, once done they will be either printed and handed to the patient or sent via an encrypted document for which the patient will get a code (they must provide proof of identity to get this code). 

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 practicemanager@nrmedicalcentre.com.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We  will  take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Notifiable Data Breaches

What is a Data Breach?

A data breach is when information that is private and confidential information regarding a patient is
provided to, with intent or accidentally, to a third party without the consent of the patient.
The legislation now determines the severity and level of risk associated with a data breach to determine
whether it is classed as a notifiable data breach.
This means having to report the breach to the patient, any third parties who received the information and
should not have, and/or to the (Australian Office of Information Commissioner (AOIC).

How do Data Breaches occur?

Data breaches occur in a number of ways. Some examples include:

• • hard disk drives and other digital storage media (integrated in other devices, for example, multifunction printers, or otherwise) being disposed of or returned to equipment lessors without the contents first being erased.
  • databases containing personal information being ‘hacked’ into or otherwise illegally accessed by individuals outside of the agency or organisation.
  • employees accessing or disclosing personal information outside the requirements or authorisation of their employment.
  • paper records stolen from insecure recycling or garbage bins.
  • an agency or organisation mistakenly providing personal information to the wrong person, for example by sending details out to the wrong address, and
  • an individual deceiving an agency or organisation into improperly releasing the personal information of another person.
  • lost or stolen laptops, removable storage devices, or paper records containing personal information

How is a data breach assessed?

To determine what other steps are immediately necessary, agencies and organisations should assess
the risks associated with the breach. Consider the following factors in assessing the risks:

• • The type of personal information involved.
  • The context of the affected information and the breach.
  • The cause and extent of the breach.
  • The risk of serious harm to the affected individuals.
  • The risk of other harms.
   

Once the assessment has been made, the Practice will follow the appropriate steps to record and report
the breach appropriately and as required by the legislation.

What is a Notifiable Data Breach?

A notifiable data breach is an incident that has been assessed as meeting all of the above criteria. This
breach needs to be reported to all persons involved (the patient, any third parties) and the
Commissioner.

What are your obligations and who do you report it to?

If you have accidentally breached privacy, or have become aware of a breach in privacy, report it
immediately to the Practice Manager so that it can be recorded, assessed and appropriate action taken.
Risk management and prevention
There are four (4) key steps to consider when responding to a breach or suspected breach:

• Step 1: Contain the breach and do a preliminary assessment
• Step 2: Evaluate the risks associated with the breach
• Step 3: Notification Privacy Policy and Procedure 5 of 6
• Step 4: Prevent future breaches’