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Privacy policy

Current as of July 1, 2023

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 clinic, and the circumstances in which we may share it with third parties. 

 

Why and when your consent is necessary 

 

When you register as a patient of our clinic, you provide consent for our clinic 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? 

 

Our clinic 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, clinic 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, emergency contact details 

  • medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors where relevant in the course of assessment and treatment by our practitioners

  • Medicare number (where applicable) for identification and claiming purposes 

  • health fund details

  • details of other services involved in your health care provision, where relevant.

 

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 clinic may collect your personal information in several different ways.

  • When you make your first appointment our clinic staff will collect your personal and demographic information via your registration. 

  • During the course of providing health services, we may collect further personal information.

  • 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 general practitioners, 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).

    • your provider through Worksafe, TAC, Aged Care or NDIS packages.

 

When, why and with whom do we share your personal information?

 

We sometimes share your personal information:

  • with third parties who work with our clinic 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 (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 health services, through eTP, 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 health 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 clinic 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 clinic 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. 

 

How do we store and protect your personal information? 

 

Our practice stores all personal information securely.

 

Your personal information is stored electronically using Cliniko, our secure cloud-based practice management software. All Cliniko logins for our staff are protected by two factor authentication. Our data is encrypted in-transit and encypted at rest by Cliniko, however we retain ownership of this data. Our data is stored by Cliniko in physically secure datacentre facilities within Australia. Cliniko meets or exceeds all regulations of the Australian Privacy Principles, GDPR, PIPEDA, and HIPAA. Cliniko partners with Amazon Web Services (AWS), which has achieved the following accreditations and certifications: PCI DSS Level 1 (Payment Card Industry Data Security Standard), ISO 27001 (Information Security Management System), FIPS 140-2 (United States Federal Information Processing Standard).

 

Some limited information is shared with Physitrack, an exercise prescription software, by whom it is encrypted in-transit and encrypted at rest. TLS encryption is used by Physitrack for inbound and outbound email. Our data is stored by Physitrack in physically secure datacentre facilities in several countries. Physitrack is HIPAA compliant and holds ISO 27001 & ISO 27018 certifications.

 

We do not store paper records, once uploaded to our secure database, paper records are shredded and disposed of. We do not hold physical records of medical imaging or other such records. 

 

Emails we receive with personal information are permanently deleted. Where possible we utilise secure messaging portals for the communication of health records with other health providers.

 

We will take reasonable steps to protect your personal and sensitive information from misuse, loss, unauthorised access and modification or disclosure. We use commercially reasonable physical, technical and administrative measures to protect information that we hold, including, where appropriate, password protection and 2-factor authentication, encryption, and SSL to protect our website.

 

Despite taking appropriate measures to protect personal and sensitive information used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk.

 

Privacy and our website 

 

When you interact with our website, we strive to make your experience easy and meaningful. We, or our third-party service providers, may use cookies, web beacons (clear GIFs, web bugs) and similar technologies to track site visitor activity and collect site data. We may combine this data with the personal information we have collected from patients. Examples of information that we may collect include technical information such as your computer’s IP address and your browser type, an information about your visit such as the products you viewed or searched for, the country you are in, what you clicked on and what links you visited to get to or from our site. If we identify you with this information, any use or disclosure of that information will be in accordance with this Privacy Policy.

 

At times, our website may contain links to other, third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

 

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 clinic acknowledges patients may request access to their health records. We require you to put this request in writing either by email to hello@healthactions.com.au, or deliver to 203 Barker St, Castlemaine Victoria 3450. Our clinic will respond within 30 days, and there may be an administration fee which we will give you notice of, which will be reasonable and proportionate to the request.

 

Our clinic 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 clinic is correct and current. You may also request that we correct or update your information by phoning us on 03 4406 6614, completing the “Contact Us” form on our website at https://www.healthactions.com.au/, or by emailing  hello@healthactions.com.au

 

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. Please contact us on 03 4406 6614 or at hello@healthactions.com.au if you have any questions regarding privacy, or if you believe we may have wrongfully disclosed your Personal and Sensitive Information or breached our privacy obligations, you should lodge your complaint in writing to:

 

Attn: Directors

Health Actions Castlemaine 

203 Barker St

Castlemaine Victoria 3450

 

We will then attempt to resolve it in accordance with our resolution procedure, within 30 days.

 

If you are not satisfied with out response, 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 the OAIC on 1300 363 992.

 

Policy review statement

 

We may change this Privacy Policy from time to time. Any updated versions of this Privacy Policy will be posted on our website - you should check periodically to review our current Privacy Policy, which is effective as of the effective date listed below. Your continued use of any of our website and services constitutes your acceptance and understanding of the Privacy Policy as in effect at the time of your use. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on the website, or where practical, by emailing patients.

 

This policy is current as of July 1st, 2023.

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