Privacy

Policy

Coach GP recognises that the information we collect is often of a highly sensitive nature and as an organisation we have adopted the privacy compliance standards relevant to Coach GP to ensure personal information is protected.

The management of Coach GP is committed to protecting the privacy of the clients/patients within our practice. Information collected is kept strictly confidential and used only for the appropriate care of clients/patients.

Purpose

To ensure clients/patients who attend the practice are comfortable in entrusting their personal information to the practice. This policy provides information to clients/patients as to how their personal information is collected and used within the practice and the circumstances in which we may disclose it to third parties.

Scope

This policy applies to all employees and clients/patients of Coach GP.

Practice Procedure

Practice responsibility:

The Practice will:

• Provide a copy of this policy upon request
• Ensure staff comply with the National Privacy Principles 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 National Privacy Principles and deal with inquiries or complaints
• Collect personal information for the primary purpose of managing a client/patient’s healthcare and for financial claims and payments.

Staff responsibility:

Practice staff will take reasonable steps to ensure clients/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
• The Practice’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy

Client/patient consent: The practice will only interpret and apply a client’s/patient’s consent for the primary purpose for which it was provided. The practice staff must seek additional consent from the client/patient if the personal information collected may be used for any other purpose.

Collection, Use and Disclosure

Purpose for collecting personal information

Our main purpose for collecting, using, holding and sharing your personal information is to provide appropriate health and wellbeing services to you. We may also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training). For administrative and billing purposes and to ensure quality and continuity of client/patient care a patient’s health information is shared between the medical practitioners of Coach GP.

What personal information is collected

Collected personal information will include client’s and patient’s

• Names, date of birth, addresses, contact details including phone, email and Skype address/es.
• Medicare number for identification and claiming purposes (if required)
• Healthcare identifiers (if required)
• Medical information (as relevant) including medical and psychiatric history, medications, allergies, adverse events, immunisations, social history, family history and risk factors.

How personal information is stored and protected

Personal information may be held at the practice in various forms

• As paper records in a secured environment
• As electronic records in password protected electronic information systems
• As visuals ie videos & photos in password protected electronic information systems
• As audio recordings in password protected electronic information systems

Information collection procedure

The practice’s procedures for collecting personal information is set out below:

• Practice staff collect client’s/patient’s personal and demographic information via registration when they present to the clinic for the first time. Clients/patients are encouraged to pay attention to the collection statement that they complete as a new client/patient.
• During the course of providing medical services the practice’s healthcare practitioners will consequently collect further personal information.
• We may also collect personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or connect with us using social media.
• Where required, personal information may also be collected from: other involved healthcare providers; client/patient guardian or responsible person (where practicable and necessary); your health fund, Medicare or the Department of Veterans’ Affairs (as necessary); other relevant person as consented to by the client/patient.

Disclosure of personal information

Personal information collected by Coach GP may be used or disclosed in the following instances:

• For medical defense purposes
• For the purposes of professional supervision of practitioners where the supervisor is also bound by the same rules of privacy and confidentiality
• As required by law in instances of mandatory reporting
• Necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impracticable to obtain patient’s consent
• To assist in locating a missing person
• As required during the normal operation of services provided. i.e. for referral to a medical specialist or other health service provider
• For the purpose of a confidential dispute resolution process
• Some disclosure may occur to third parties engaged by or for the practice for the practice for business purposes such as accreditation or for the provision of information technology. These third parties are required to comply with this policy.
• Use of email address/es for delivery of informational or promotional material from this practice only. Your personal details will not be disclosed to any third party for this reason nor will you receive email promotional material from third parties via information received from this Practice. You may opt out of promotional communications at any time.

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 will not disclose personal information to anyone outside Australia without need and without consent.

The practice will not use any personal information in relation to direct marketing to a person without their express consent.

The practice evaluates all unsolicited information it receives to decide if it should be kept, acted upon or destroyed.

Coach GP will employ all reasonable endeavours to ensure that a patient’s personal information is not disclosed without their prior consent.

Data Quality

Patient information collected and retained in our records for the purpose of providing quality care will be complete, accurate, and up to date at the time of collection.

Data Security

All due care will be taken to ensure the protection of client/patient privacy during the transfer, storage and use of personal health information.

Retention of medical records is for a minimum of 7 years from the date of last entry into the patient record unless the patient is a child in which case the record must be kept until the patient attains the age of 25 years of age.

Access to Patient Information and Correction

The following will apply with regard to accessing personal and private medical information by an individual:

• An individual has the right to request access their own personal information and request a copy or part of the whole record
• Individuals have the right to obtain their personal information in accordance with the Federal Privacy Act from 20 December 2001 onwards. Requests must be made in writing and an acknowledgement letter will be sent to the patient within 14 days confirming the request and detailing whether the request can be complied with and an indication of any costs associated with providing the information. Time spent and photocopying costs when processing a request can be passed on to the requesting patient. Information can be expected to be provided within 30 days.
• Whilst the individual is not required to give a reason for obtaining the information, a patient may be asked to clarify the scope of the request
• In some instances, the request to obtain information may be denied, in these instances the patient will be advised
• The material over which a Doctor has copyright might be subject to conditions that prevent or restrict further copying or publication without the Doctor’s permission
• The practice will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time the practice will ask clients/patients to verify the personal information held by the practice is correct and up to date.
• Clients/patients may also request the practice corrects or updates their information they should make such requests in writing.
• Upon written request by the client/patient, the information held by this clinic will be made available to another health provider.

Complaints

The management of Coach GP understands the importance of confidentiality and discretion with the way we manage and maintain the personal information of our clients and patients. The Practice takes complaints and concerns about the privacy of client’s/patient’s personal information seriously. Clients/patients should express any privacy concerns in writing. The practice will then attempt to resolve it in accordance with its complaint resolution process.

All employees of Coach GP are required to observe the obligations of confidentiality in the course of their employment and are required to sign Confidentiality Agreements.

In the instance where you are dissatisfied with the level of service provided within the clinic we encourage you to discuss any concerns relating to the privacy of your information with your treating Practitioner.

If the complaint has not been resolved to your level of satisfaction, then all complaints should be directed to:

The Federal Privacy Commissioner

Level 8 Piccadilly Tower

133 Castlereagh Street

Sydney NSW 2000

Privacy Hotline: 1300 363 992

Supporting Documentation

National Privacy Principles

Freedom of Information Act 2001

Review Date

Approved February 2018

Dr Jocelyn Lowinger, Director, Coach GP