Privacy Policy :

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. Our website address is: https://lidcombemedical.com.au. Our privacy policy is displayed in the waiting room and also on the practice information sheet and practice website, and is readily presented to anyone who asks. Our collection of information , informs patients about how their personal health information will be used, including by other organisations to which the practice usually discloses patient information to, and any law that requires the particular information to be collected. Patient consent to the handling and sharing of personal patient health information is sought and documented early in the process of clinical care, and patients are made aware of the collection statement when giving consent to share health information.

According to the Privacy Act 1988 and the Australian Privacy Principles, an organisation may use or disclose personal health information for a purpose (the secondary purpose) which is directly related to the primary purpose of collection without seeking consent, but only if the individual would have a reasonable expectation that the information could be used or disclosed for that secondary purpose.

A directly related secondary purpose for the use and disclosure of personal health information in our practice includes the many activities necessary for the provision of a health service, such as management, funding and monitoring, as well as complaint-handling, planning, evaluation and accreditation activities.It is essential to recognise the importance of ‘reasonable expectation’ as many individuals may be unaware of the range of activities for which their personal health information may be used and disclosed, such as the accreditation process. Our practice ensures we tell patients how, and for what purpose, personal health information collected about them could be used or disclosed. Patients are advised of this ‘secondary purpose’ in a number of ways, including:

At the time of the consultation with a general practitioner,
Via the practice privacy statement in the practice information sheet,
Via the practice privacy statement on signage on the walls of the practice, and/or
By reading, understanding and signing a new patient information form when first registering at the practice, which incorporates the practice privacy statement.

It is important we maintain a patient’s right to ‘opt out’ of the secondary purpose through refusal to consent. If an individual expresses negative views or opposition when made aware of a proposed secondary use or disclosure of their personal health information, this would indicate that they have a reasonable expectation that their personal health information will not be used or disclosed in that manner, and their non-consent is recorded on file.

We inform our patients about our practice’s policies regarding the collection and management of their personal health information via:

A sign at reception,
Brochure(s) in the waiting area,
Our practice information sheet,
New patient information forms,
Verbal means if appropriate, and
Our practice website.

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.

Prior to a patient signing consent to the release of their health information, patients are made aware that they can request a full copy of our privacy policy. Patient consent for the transfer of health information to other providers or agencies involved in the patient’s healthcare (e.g. treating practitioners and specialists outside the practice) is obtained at the patient’s first visit to our practice through the New Patient Information Form. Once signed, this form is scanned into the patient’s health record and its completion is noted.

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 (eg 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.

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.

When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
During the course of providing medical 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 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 (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 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 medical 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 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 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?

Your personal information may be stored at our practice in various forms.

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 email , fax and our practice will respond within a reasonable time.

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 info@lidcombemedical.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. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure. You can email us on info@lidcombemedical.com.au or can send a complaint through mail . 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. .

Your contact information

You can email us on info@lidcombemedical.com.au or contact us on 02 8022 8442

How we protect your data

For each patient we have an individual patient health record containing all clinical information held by our practice relating to that patient. Our practice ensures the protection of all information contained within these files. Our patient health records are accessed only by an appropriate team member as required, and we ensure information held about the patient in different records (e.g. at a residential aged care facility) is available when required.

Our practice has appointed the Practice Manager with designated responsibility for ensuring the privacy and security of personal health information held within our practice. Our general practitioners, clinical and allied health team members and all other staff and contractors associated with this practice have a responsibility to maintain the privacy of personal health information and related financial information; the privacy of this information is every patient’s right.

The maintenance of privacy requires that any information regarding individual patients (including practice team members who may be patients) may not be disclosed either verbally, in writing or by copying it either at the practice or outside it, during or outside normal opening hours, except for strictly authorised use within the patient care context at the practice or as legally directed.

All patient information must be considered private and confidential, even that which is seen or heard and therefore must not to be disclosed to family, friends, members of the practice team not involved in that patient’s care, or any other people without the patient’s approval. Details about a person’s medical history or other contextual information such as details of an appointment can sometimes still identify them, even if no name is attached to that information. This is still considered personal information and as such it must be protected in accordance with the Privacy Act 1988.

Any information given to unauthorised persons will result in disciplinary action and possible dismissal. Each member of our practice team is bound by a confidentiality agreement, which is signed upon commencement of working at our practice . If a breach of privacy occurs within our practice, we have processes in place to ensure this breach is reported appropriately, handled quickly and effectively, and reviewed to prevent recurrence.

What data breach procedures we have in place

Lidcombe Family Medical Centre understands the importance of protecting patient information at all costs. However, in the event that a data breach does occur, our practice complies with the Office of the Australian Information Commissioner’s (OAIC) Notifiable Data Breach (NBD) Scheme where notification must be made where the breach is deemed ‘eligible’ for notification.

An eligible data breach is when there is evidence of unauthorised access, unauthorised disclosure, or loss of personal health information; the breach is likely to result in serious harm to one or more individuals; and the practice has not been able to prevent the risk of harm through remedial actions.

If all three of these criteria are filled, Lidcombe Family Medical Centre reports the breach to the OAIC using the Notifiable Data Breach Form available from their website. We then ensure we have notified any patients or personnel affected by the breach, as well as our medical indemnity insurer and all practice GPs’ personal insurance providers.

For breaches relating to My Health Record, the Australian Digital Health Agency will also need to be notified in addition to the notification made to the OAIC.

Upon notification of the breach and all possible remedial action being taken by the practice, our practice logs the incident within our incident register for review at the next practice team meeting or, if the data breach is significant, at a specifically arranged meeting as soon as possible. Any changes to systems or processes as a result of a breach are communicated to the practice team and are regularly monitored to ensure the changes remain in place and are effective for preventing a recurrence of the incident.

What third parties we receive data from

Requests for third party access to personal patient health information are initiated through receipt of correspondence from a solicitor or government agency or by the patient completing a Request for Personal Health Information form. Where a patient request form or signed authorisation is not obtained the practice is not legally obliged to release information.

Where our practice holds reports or other health information from another organisation, such as a medical specialist, we are required to provide access to this information in the same manner as for the records we create. We are also required to provide access to records which have been transferred to us from another health service provider.

General practice has a fundamental role in ensuring the privacy of personal patient health information. Our practice has access to and uses the RACGP’s Privacy and managing health information in general practice handbook which aligns with current best practice and includes commentary on the Privacy Act 1988. It provides guidance to our practice on the management of health information in a general practice setting and includes examples of compliance with the various Health Records Acts and the Australian Privacy Principles (APPs), which regulate the handling of personal information by both Australian government agencies and businesses.

Requests for access to patient health records and associated financial details may be received from various third parties including:

Subpoena/court order/coroner/search warrant,
Relatives/friends/carers,
External practitioners and healthcare institutions,
Police/solicitors,
Health insurance companies/workers compensation/social welfare agencies,
Employers,
Government agencies,
Accounts/debt collection,
Students (medical and nursing),
Research/quality assurance programs,
Media outlets,
International parties, and
Disease registers.

We only transfer or release patient information to a third party once the consent to share information has been signed and, in specific cases, informed consent has been sought from the patient.

Our practice team can describe the procedures for timely, authorised and secure transfer of patient personal health information in relation to valid requests. The practice team can describe how we correctly identify our patients using three (3) patient identifiers in accordance to ascertain we have selected the correct patient record before entering or actioning anything from that record.

Patient consent for the transfer of health information to other providers or agencies is obtained at the patient’s first visit and is retained on file in anticipation of when this may be required. As a rule, no patient information is to be released to a third party unless the request is made in writing and provides evidence of a signed authority to release the requested information, to either the patient directly or to the third party.

Written requests for the transfer of health information are noted in the patient’s health record, and are also documented in the practice’s Transfer Request register. Any request received is forwarded to the patient’s usual general practitioner for action. The requested record is to be reviewed by the general practitioner whilst using the Release of Health Information Checklist prior to release to a third party to ascertain if the information being requested is suitable for release.

To meet the costs associated with reviewing and preparing personal patient health information to be released to a third party, our practice charges an administrative fee. A list of the fees associated with the types of information being requested is located at reception.

Where patient information is being transferred in hard copy (i.e. post or being collected by the patient/third party), only copies are provided; the original is to remain at the practice. The security of any health information requested is maintained when transferring requested records. Electronic data transmission of personal patient health information from our practice is in a secure format.