Privacy Policy

Protecting your personal information

Introduction

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.

Legislation

Our practice must comply with the Privacy Act 1988 (Cth) (Privacy Act) in dealing with any personal information. We have systems in place to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

The Australian Privacy Principles (or APPs) are the cornerstone of the privacy protection framework in the Privacy Act. They apply to any organisation or agency the Privacy Act covers (an APP entity). The APPs require that APP entities take reasonable steps to implement practices, procedures and systems that will ensure compliance with the APPs.

The 13 Australian Privacy Principles set out standards, rights and obligations around:

• the collection, use and disclosure of personal information;
• an organisation or agency’s governance and accountability;
• integrity and correction of personal information; and
• the rights of individuals to access their personal information.

Our practice regularly reviews our privacy policy to ensure compliance with the APPs.

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. 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?

Personal information under the Privacy Act is any information or an opinion about an identified individual (or an individual who is reasonably identifiable). The Privacy Act sets out various obligations in relation to the collection, handling, storage, use or disclosure of 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?

The information we 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

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. 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.

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, and government and other agencies
• 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 the 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 electronic transfer of prescriptions (eTP) or 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, we 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 permitted by law, without your consent.

We 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.

We may use your personal information to improve the quality of the services we offer through research and analysis of patient data. We may also provide de-identified data to other organisations to improve population health outcomes. This 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 various forms.

Electronic medical records are used to securely store your medical and personal information, and our practice software conforms to all government regulations for security. We do not keep any paper records. Any paper records provided to the practice are scanned into the electronic medical record and originals are shredded or returned to you.

Practitioners in the practice may sometimes use artificial intelligence transcription tools and other similar tools to record consultations and generate medical notes. These tools meet all required privacy and security standards.

We store all personal information securely and have strict policies in place regarding who can access your information and in what circumstances.

How can you access and correct your personal information?

You have the right to request access to, and correction of, your personal information.

We acknowledge that patients may request access to their medical records. Please put your request in writing by letter or email and we will respond within a reasonable time (normally within 30 days unless exceptional circumstances occur). You may be charged administration costs associated with providing this information.

We will take reasonable steps to correct your personal information where it is not accurate or up to date. From time to time we may ask you to verify that your personal information is correct and current. You may also request that we correct or update your information by writing to the practice manager by email or letter.

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. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure.

To notify us of a concern, you can email us at reception@ourplacehealth.com.au or write to us at 86 Eudoria Street, Gosnells, WA 6110. You can also call us on 08 6388 4453. We will investigate your concern and reply in writing within 30 days other than in exceptional circumstances.

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 1300 363 992.

Privacy and our website

We may collect personal information through digital channels, including our website, email communications and social media platforms. This information may include names, contact details, health-related queries and other data voluntarily provided by users. We also use website analytics tools and cookies to improve user experience and monitor website performance. These tools may collect information such as IP addresses, browser types and usage patterns.

All digital data collection is conducted in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, and relevant amendments including the Privacy and Other Legislation Amendment Act 2024 (POLA). We take reasonable technical and organisational steps to ensure the security and confidentiality of personal information collected online. Patients are informed of the purposes for which their information is collected, and they have the right to access, correct or request deletion of their personal data. By using our digital services, users consent to the collection and use of their information as outlined in this policy.

Policy review statement

This policy will be reviewed every two years, and remains in force until superseded.