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.

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?

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 Identifications (DVA, HCC, Pensioner ,etc )

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.
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.
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 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
• Tor 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 via email or by responding to an SMS reminder.

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.

Your personal information is primarily stored via electronic records. All data is secured via our extensive IT infrastructure, and backed up every 2 hours, in accordance with our accreditation requirements.

While we try to make every effort to limit paper records needing to be printed, all paper records will be placed in the locked shredding bin and securely disposed of. Otherwise, it will be provided to the patient directly or a carer of the patient with the patients consent.

Our practice stores all personal information securely.

Your personal information is primarily stored via electronic records. All data is secured via our extensive IT infrastructure, and backed up every 2 hours, in accordance with our accreditation requirements.

All staff and health professionals access the computer systems and patient management system by a unique password that is only known to them.

All our service agreements and employment contracts include confidentially agreements which all parties need to agree upon to maintain privacy of the personal information of all patients.

Paper copies of personal information is securely disposed of into a locked shredding bin. Staff and health professionals are encouraged to minimize paper records being printed and to dispose of them promptly as soon as they are no longer needed.

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 by completing a request for medical records with accompanying photo ID and our practice will respond within a reasonable time of 30 business days. An electronic version of your personal information can be provided for a cost of $66 including GST. If paper records are required the cost will be calculated as $38 +GST for the first 33 page, and $1.40 every additional page.

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 our Practice Manager via email (allsaintsdrs@gmail.com).

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. If you would like to express privacy concerns you may email your concerns to allsaintsdrs@gmail.com or call us on 95832999 and ask to speak to the practice manager. Alternatively you may send a letter addressed to the Practice Manager to 154-156 Ramsgate Rd , Ramsgate beach NSW 2217. We respond to all complaints within 20 business days.

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.

Privacy and our website

Personal information may be collected via our practice website when booking appointments. Information such as name, contact details, date of birth and address may be collected. Payments may be collected online via our booking system. Payment details are securely stored via Automed Systems. Personal information is not collected through social media platforms. Information will be stored in accordance to relevant privacy legislation.

Policy review statement

This policy will be reviewed regularly (at least on annual basis) to ensure it is in accordance with any changes that may occur. Patients will be notified of any changes to our privacy policy by our website and on display in our waiting room on our digital board.

All Saints Medical Centre Communication Policies

Communication with patients by electronic means

Policy

Our practice is mindful that even if patients have provided electronic contact details, they may not be proficient in communicating via electronic means and patient consent needs to be obtained before engaging in electronic communication. Electronic communication includes email, facsimile and Short Message Service (SMS).

Communication with patients via electronic means is conducted with appropriate regard to privacy.

Procedure

Our practice’s primary reason for communicating electronically to patients is to issue appointment reminders and we verify the correct contact details of the patient at the time of the appointment being made.

Whilst not encouraged, our practice allows patients an opportunity to obtain advice or information related to their care by electronic means, but only where the general practitioner determines that a face-to-face consultation is unnecessary and that communication by electronic means is suitable. Our practice will only provide information that is of a general, non-urgent nature and will not initiate electronic communication (other than SMS appointment reminders) with patients. Any electronic communication received from patients is also used as a method to verify the contact details we have recorded on file are correct and up-to-date.

Communication with patients via electronic means is conducted with appropriate regard to privacy. Before obtaining and documenting the patient’s consent, patients are fully informed through information contained in our practice information sheet of the risks associated with electronic communication in that the information could be intercepted or read by someone other than the intended recipient. Our practice also has an automatic email response system set up so that whenever an email is received into the practice, the sender receives an automated message reinforcing information regarding these risks.

When an email message is sent or received in the course of a person’s duties, that message is a business communication and therefore constitutes an official record. Patients are informed of any costs to be incurred as a result of the electronic advice or information being provided, and all electronic contact with patients is recorded in their health record.

All members of the practice team are made aware of our policy regarding electronic communication with patients during induction, and are reminded of this policy on an ongoing basis. They are made aware that electronic communications could be forwarded, intercepted, printed and stored by others. Each member of the practice team holds full accountability for emails sent in their name or held in their mailbox, and they are expected to utilise this communication tool in an acceptable manner. This includes, but is not limited to:

• Limiting the exchange of personal emails
• Refraining from responding to unsolicited or unwanted emails 
• Deleting hoaxes or chain emails
• Email attachments from unknown senders are not to be opened
• Virus checking all email attachments
• Maintaining appropriate language within electronic communications
• Ensuring any personal opinions are clearly indicated as such, and
• Confidential information (e.g. patient information) must be encrypted.

Our practice reserves the right to check an individual’s email accounts as a precaution to fraud, viruses, workplace harassment or breaches of confidence by members of the practice team. Inappropriate use of the email facility will be fully investigated and may be grounds for dismissal.

The practice uses an email disclaimer notice on outgoing emails that are affiliated with the practice stating:  CONFIDENTIALITY AND PRIVILEGE NOTICE

Disclaimer
This email and any attachments transmitted with it may be confidential and are intended solely for the use of the individual or entity to whom they are addressed.

Any confidentiality is not waived or lost if this email has been sent to you by mistake.

If you are not the intended recipient, you must not read, print, store, copy or forward or use this email for any reason.

If this email has been sent to you by mistake, please delete this message from your mailbox, and do not forward it or any part of it to anyone else.

Thank you for your cooperation and understanding trees.

Practice information sheet

Policy

Our practice information sheet provides patients with information about our practice facilities and how to access care. It is also a useful way to inform patients of current practice information or changes to our services. We endeavour to ensure all patients, new and existing, are provided with the most up-to-date version to ensure the information they have is accurate.  

Procedure

The practice information sheet is kept at reception and is handed to each new patient on their first visit. A supply of information sheets is also available in the waiting room for existing patients to take.

Where patients are unable to read or understand our written information sheet, we use other means to communicate the essential information which may include:

• Verbal communication
• Larger font versions of materials
• Gaining support through the National Relay Service or AUSLAN for patients who are deaf
• Gaining support through the Translating and Interpreter Service (TIS) for patients who speak languages other than English, and

To maintain the accuracy of our information sheet, it is reviewed regularly and updated as required. When the information sheet is updated, the date is inserted in the footer to denote the latest version and our reception staff are encouraged to bring this new version to the attention of our patients.

Our practice information sheet contains at a minimum:

• Our practice address and telephone numbers
• Consulting hours and arrangements for care outside normal opening hours, including a contact telephone number
• The names and qualifications and special interests of our practitioners, nurses, allied health and other practice team members
• The medical, clinical and other services available
• Our billing principles such as bulk billing arrangements, accounts settlement and what services incur additional out-of-pocket expenses and details of these expenses
• Our communication policy including receiving and returning telephone calls and electronic communication
• Our policies for the management of patient personal health information, including details on how patients can obtain a copy of their health information and where our practice’s full privacy policy can be obtained
• The process for the following up of test results, and
• How to provide feedback or make a complaint to the practice, including the name of the person of the practice who is responsible for receiving feedback and complaints, and the contact details for the statehealth complaints agency.

Where information on the practice information sheet, website or in general interest health articles and posters contains advertising within our practice, we ensure any advertising complies with the Medical Board of Australia’s Good medical practice: A code of conduct for doctors in Australia. We include a disclaimer on the advertisement stating that the practice does not endorse the advertised services or products.

As a best practice process, we also display Consumer friendly messages promoting our status of accreditation.

Telecommunication System

Policy

Our practice’s telecommunication system facilitates patient access to the practice services and aims to adequately meet the needs of patients and team members. The auditory privacy and confidentiality need of patients have been considered when locating our telephones and facilities for electronic communication.

Procedure

Our telephone system provides sufficient inward and outward call capacity and has the functionality for electronic communication (Fax-E-fax). The practice has 5 lines dedicated for telephone calls and 1 line for electronic communication.

A telephone line is available for the practice team to summon assistance in an emergency.

All Saints Medical Centre Complaints Policy

Complaints Policy

Opportunities are available for patients and other visitors to tell us, “How we are doing” and we collect systematic patient experience feedback at least every three (3) years.

The practice information sheet provides patients with information on how to provide feedback, including how to make a complaint. 

We have a complaints resolution process which all members of the practice team can describe, and we also make the contact details for NSW health complaints agency readily available to patients if we are unable to resolve their concerns.

Patients have a ‘right to complain’ and where possible, patients and others are encouraged to raise any concerns directly with the practice team who are all trained to make sure patients of the practice feel confident that any feedback or complaints made will be handled appropriately. We believe most complaints can be responded to and resolved at the time the patients or other people such as carers, relatives, friends, or other consumers make them known to our team. 

Under national and NSW state privacy laws, our practice provides and adheres to a complaints process for privacy issues and those related to the Australian Privacy Principles (APPs).

All members of our practice team are educated to be prepared to address complaints as they arise. Depending on the nature of the complaint and any advice received from our medical indemnity insurers where required, complaints are recorded and actioned with a copy placed in the patient’s health record if related to patient care.

All clinical and medical staff, as well as administration staff, are aware of the professional and legal obligations regarding the mandatory reporting of unprofessional conduct.

Procedure

Patients and others have opportunities to register their complaints either verbally, in writing (letter) or via our suggestion box.  Patients or others are able to complain anonymously if desired.

All members of our practice team are educated to be prepared to address complaints as they arise. 

When receiving complaints, our practice keeps in mind the following in order to minimise further patient anxiety and hostility:

• Handle all complaints seriously, no matter how trivial they may seem.
• Verbal complaints made in person should be addressed in a private area of the practice where possible.
• Use tactful language when responding to complaints.
• Do not blame others; patients may not have all the facts or they may distort them.
• Address the patient’s expectations regarding how they want the matter resolved.
• Assure the patient that their complaint will be investigated and the matter not disregarded.
• Offer the person an opportunity to complete a formal complaint form (they may accept or decline).
• Document all complaints and other relevant information and place this in the complaint folder so the person designated to manage complaints is informed of the complaint (even if the matter appears to have been resolved).
• Alert the general practitioner about disgruntled or hostile patients so they can diffuse the situation immediately – often patients are reluctant to make a complaint directly to a general practitioner.
• Always inform the person designated to manage complaints if you become aware of any significant statements made by the patient or significant change in patient attitude.

The practice has appointed Evelin Gerges – Practice Manager with designated responsibility for seeking, collecting, analysing, investigating, resolving and managing all feedback and complaints. She can be contacted on 95832999. Any investigation and resolution of complaints is undertaken using an open disclosure process, incorporating the following:

• Acknowledge the patient’s right to complain.
• Acknowledge receipt of the complaint as soon as possible, but within two (2) working days using the Acknowledgment of Complaintletter template.
• Respond to all complaints as soon as reasonably practicable, but within thirty (30) days in an open and constructive manner including an explanation and if appropriate an apology.
• If a resolution of the matter is to take longer than thirty (30) days, an update of the resolution activities will be provided to the patient, with an anticipated revised timeframe for resolution.
• Work with the patient to resolve the complaint and communicate the outcome with the patient, including any changes made as a result of the complaint.
• As a routine, contact the practice’s insurer when there is a complaint about a member of the medical or clinical team in order to seek advice on resolving the complaint before any action .
• Where a complaint is made against a practice team member, provide the team member with an opportunity to discuss the details in a private setting.
• Ensure the complaint does not adversely affect the patient’s care.
• Record the complaint, investigation and actions in the dedicated complaints file and, if related to patient care, include a copy in the patient’s health record.
• Ensure, where appropriate, complaints are reviewed at practice team meetings; analyse trends and discuss the methods of resolution.
• Review other types of patient feedback (i.e. feedback surveys, suggestion box) during practice team meetings.
• Keep a record of improvement(s) made in response to feedback or complaints.
• Where appropriate, inform the patient about practice improvements made as a result of their input.

If the matter cannot be resolved, the patient is advised about how to contact the external health complaints agency for our state.

New South Wales

Health Care Complaints Commission (HCCC)

Telephone: (02) 9219 7444 / 1800 043 159 (Toll Free in NSW)

Web: www.hccc.nsw.gov.au   

Complaints that relate to privacy issues or concerns that cannot be resolved internally are to be directed to the Office of the Australian Information Commissioner (OAIC).

Office of the Australian Information Commissioner

Telephone: 1300 363 992

Postal Address: GPO Box 5218, Sydney NSW 2001

Web: www.oaic.gov.au 

Members of the public may make a notification to the Australian Health Practitioner Regulation Agency (AHPRA) – www.ahpra.gov.au – about the conduct, health or performance of a practitioner or the health of a student. Practitioners, employers and education providers are all mandated by law to report notifiable conduct relating to a registered practitioner or student to AHPRA.