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Privacy Policy

MMC Privacy – Policy

This following document sets forth the Privacy Policy for MAYFIELD MEDICAL CONNECTION

MAYFIELD MEDICAL CONNECTION, on behalf of the professionals consulting from our premises is committed to providing you with the best possible customer service experience. MAYFIELD MEDICAL CONNECTION is bound by the Privacy Act 1988 (Crh), which sets out a number of principles concerning the privacy of individuals.

MMC understands the importance of and complies with the APPs, endeavouring to maintain transparency in a systematic manner thereby supporting the patients’ of the practitioners working from our site, our team’s and our community’s confidence in us, in our administration of quality healthcare and our astute management of private information including health information. In compliance with APP 1 Open and Transparent Management of Personal Information, MMC has a document that clearly sets out its policies on the collection, storage, protection, use and handling of personal information, including health information. This document is made readily available in both hard copy and digital format. The document content follows in PSPHI 6.3 procedure under the title MAYFIELD MEDICAL CONNECTION PRIVACY POLICY.

MMC Privacy – Procedure

MMC’s privacy policy outlines how we handle personal information collected (including health information) and how we protect the security of this information. It is made available to anyone who asks for it and those attending our site for health services are made aware of this.
The collection statement informs how health information will be used including other organisations to which MMC usually discloses patient health information and any law that requires the particular information to be collected. Consent to the handling and sharing of health information is sought at an early stage in the process of clinical care and individuals are made aware of the collection statement when giving consent to share health information.

In general, quality improvement or clinical audit activities in order to improve the delivery of a particular treatment or service would be considered a directly related secondary purpose for information use or disclosure so we do not need to seek specific consent for this use of health information, however we include information about quality improvement activities and clinical audits in the MMC policy on managing health information.

In order to retrieve health information from past or collaborative providers, MMC supplies a Medical Information Request form which is available from our AT and is kept in BP templates. Prior to signing consent to the release of health information individuals are made aware that they may request a full copy of our privacy policy and collection statement. If required, consent for the transfer of health information to other providers or agencies is obtained on the first visit, once signed this form is scanned into the patient’s record and its completion noted.

All email or SMS communications include an opt out function. Individuals who opt out receive all important information by mail, through direct contact or by self-sourcing from our website.

We inform individuals about MMC’s policies regarding the collection and management of personal health information via:

  • the MMC Information Sheet
  • new patient forms – ‘Consent to share information’
  • verbally if appropriate
  • the MMC website

MMC has adopted the RACGP developed and recommended Practice Privacy Policy, it follows:

RACGP APP privacy policy – adopted by MMC: Managing patient health information

PURPOSE:
To ensure patients who receive care from practitioners who consult from MMC are comfortable in entrusting their health information to the MMC team. This policy provides information to individuals as to how their personal information, which includes their health information, is collected and used within MMC, and the circumstances in which we may disclose it to third parties.

RELATED STANDARDS:
RACGP Compliance indicators for the Australian Privacy Principles: an addendum to the computer and information security standards (Second edition).

BACKGROUND AND RATIONALE:
The APP provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APP consist of 13 principle-based laws and apply equally to paper-based and digital environments. The APP complement the long-standing general practice obligation to manage personal information in a regulated, open and transparent manner.

This policy will guide MMC staff in meeting these legal obligations. It also details to individuals how MMC uses their personal information. The policy is made available upon request.

PRACTICE PROCEDURE
MMC will:

  • provide a copy of this policy upon request
  • ensure staff comply with the APP 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 APP and deal with inquiries or complaints
  • collect personal information for the primary purpose of managing a patient’s healthcare and for financial claims and payments on behalf of the patient’s GP.

Staff responsibility
MMC’s staff will take reasonable steps to ensure individuals 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
  • MMC’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.

CONSENT
MMC will only interpret and apply consent for the primary purpose for which it was provided. MMC staff must seek additional consent if the personal information collected may be used for any other purpose.

COLLECTION OF INFORMATION
MMC will need to collect personal information as a provision of clinical services to patients at MMC on behalf of the patient’s health care provider.
Collected personal information will include:

  • names, addresses and contact details
  • Medicare number, where available for identification and claiming purposes
  • healthcare identifiers
  • medical information including history, medications, allergies, adverse events, immunisations, social history, family history and risk factors.

Personal information may be held by MMC in various forms:

  • as paper records
  • as electronic records
  • as visual – x-rays, CT scans, videos and photos
  • as audio recordings

MMC’s procedure for collecting personal information is set out below:

  1. AT collect personal and demographic information via registration when individuals present to MMC for the first time. Individuals are encouraged to pay attention to the collection statement attached to/within the form and information about the management of collected information and privacy.
  2. During the course of providing medical services, the MMC’s healthcare practitioners will consequently collect further personal information.
  3. Personal information may also be collected from the individual’s guardian or responsible person (where practicable and necessary), or from any other involved healthcare specialists.

MMC holds all personal information securely, whether in electronic format, in protected information systems or in hard copy format in a secured environment.

USE AND DISCLOSURE OF INFORMATION
Personal information will only be used for the purpose of the health care provider providing medical services and for claims and payments, unless otherwise consented to. Some disclosure may occur to third parties engaged by or for MMC for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy. MMC will inform where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).

MMC will not disclose personal information to any third party other than in the course of assisting the professionals attending from our site to provide medical services, without full disclosure of the reason for the information transfer and full consent. MMC will not disclose personal information to anyone outside Australia without need and without consent.

Exceptions to disclose without consent are where the information is:

  • required by law
  • necessary to:
    • lessen or prevent a serious threat to a patient’s life
    • health or safety
    • public health or safety
    • 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 a confidential dispute resolution process.

MMC will not use any personal information in relation to direct marketing express consent. Individuals may opt-out of direct marketing at any time by notifying MMC in a letter or email.

MMC evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.

ACCESS, CORRECTIONS AND PRIVACY CONCERNS
MMC acknowledges individuals may request access to their medical records. Individuals are encouraged to make this request in writing, and MMC will respond within a reasonable time.

MMC will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, MMC will ask individuals to verify the personal information held by MMC is correct and up to date. Patients may also request MMC corrects or updates their information, and individuals should make such requests in writing.

MMC takes complaints and concerns about privacy of personal information seriously.

Individuals should express any privacy concerns in writing. MMC will then attempt to resolve it in accordance with its complaint resolution procedure.

RELATED RESOURCES
Compliance indicators for the Australian Privacy Principles: An addendum to the computer and information security standards (Second edition)
www.racgp.org.au/ehealth/privacy
RACGP Computer and information security standards (CISS) and templates (2013)
www.racgp.org.au/your-practice/e-health/protecting-information/ciss/
The RACGP Privacy handbook & patient pamphlet
www.racgp.org.au/ehealth/privacy

MMC also provides significant privacy information in the forms used to enroll new patients for the practitioners consulting from our site and in our Consent and Permissions form which follows:

MAYFIELD MEDICAL CONNECTION (MMC) PRIVACY POLICY

Current as of: April 2016

INTRODUCTION

This privacy policy is to provide information to you on how your personal information (which includes your health information) is collected and used within MMC, 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 a practitioner working from MMC, you provide consent for your GP and when necessary, their colleagues and MMC staff to access and use your personal information so they can assist you to engage 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.

When you sign your health practitioner’s New Patient Consent Form you are agreeing to our sharing your information with people necessary to your healthcare.

WHY DO WE COLLECT, USE, HOLD AND SHARE YOUR PERSONAL INFORMATION?

MMC will need to collect your personal information to assist your health practitioner to provide healthcare services to you. Our main purpose for collecting, using, holding and sharing your personal information is to assist your health practitioner to manage your health. We also use it for directly related business activities, such as financial claims and payments, MMC audits and accreditation, and business processes (e.g. staff training). The ease of assisting your health practitioner to provide you with quality healthcare is lessened if we are not given access to your personal health information this may in turn, compromise your health outcomes.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The information we will collect about you includes:

  • name, 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 – Australian Privacy Principle APP2.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

MMC will collect your personal information:

  • When you make your first appointment with a health practitioner consulting from MMC, MMC’s staff will collect your personal and demographic information via your registration.
  • During the course of providing medical services, your health practitioner may collect further personal information, and some of this information may be obtained through:
    • Electronic Transfer of Prescriptions (eTP)
  • Electronic Health (eHealth) services such as:
    • MyHealth Record/Personally Controlled Electronic Health Record (PCEHR) system
  • Shared Health Summary
  • Event Summary
  • 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 past providers, specialists, allied health professionals, complimentary health professionals, hospitals, community health services and pathology and diagnostic imaging services, your health fund, Medicare, or the Department of Veteran’s Affairs

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We sometimes share your personal information:

  • with third parties who work with MMC 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 (e.g. court subpoenas)
  • when it is necessary to lessen or prevent a serious threat to life, health or safety or public health or safety, or it is impractical to obtain 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 (e.g. some diseases require mandatory notification)
  • during the course of providing medical services, through eTP, MyHealth Record/PCEHR system (e.g. via Shared Health Summary, Event Summary).

Only people that need to access your information will be able to do so. Other than in the course of administering medical services or as otherwise described in this policy, MMC 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.

MMC 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 MMC in writing, or by using the opt out option in the SMS or email presented.

HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?

Your personal information may be stored at MMC in various forms e.g. as paper records, as electronic records, as visual (X-rays, CT scans, videos and photos), or as audio recordings.

MMC stores all personal information securely
Your records are maintained within BP which is password protected and protected by firewalls and security software managed by Healthtech Solutions as per RACGP requirements. Paper records from pre 30 May 2012 are securely stored onsite. Hard copies of records that are no longer required are either shredded onsite or shredded by an accredited secure document destruction company.

All staff have signed a confidentiality agreement that prohibits them from divulging any information about you that they may have learnt through working with us.

How can you access and correct your personal information at MMC?
You have the right to request access to, and correction of, your personal information.

MMC acknowledges that individuals may request access to their medical records. In order to comply with privacy legislation it is necessary to adhere to the following procedure:

We require you to put this request in writing and addressed to your GP. We can provide you with a standard request form for this purpose.

MMC will respond within 30 days or sooner, which by industry standards is considered to be a reasonable time. We will always act as quickly as possible.

If it is not possible for access to be granted, you will be notified in writing. If access is refused to your medical file, you will be advised of the reasons in writing. You may contact us if you wish to discuss this further. You will not be permitted to remove any of the contents of your medical file from MMC, nor will you be permitted to alter or erase information contained in that medical record.

Where practicable, a GP will be present when access is granted to your file, to address any concerns you may have. A fee of $40 will be charged in relation to this attendance. No Medicare rebate applies to this fee.

There is a fee of $1 per page for copies of your file.

When collecting records, individual are requested to do so in person; however, in some limited circumstances (Illness or incapacity) individuals may request another person to collect same. Photo identity is required to collect medical records and a letter of authority is required to collect on another’s behalf.

CORRECTION OF INFORMATION

MMC takes 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 your personal information held by MMC is correct and up-to-date. You may also request that we correct or update your information, and you should make such requests in writing to: The Business Manager:

Mayfield Medical Connection, PO Box 109, Mayfield, NSW 2304
or by email to: mmc@mayfieldmedicalconnection.com.au

HOW CAN YOU LODGE A PRIVACY RELATED COMPLAINT, AND HOW WILL THE COMPLAINT BE HANDLED AT MMC?

We take complaints and concerns regarding privacy seriously. Please express any privacy concerns you may have in writing to:

The Business Manager, Mayfield Medical Connection, PO Box 109, Mayfield, NSW 2304
or by email to: mmc@mayfieldmedicalconnection.com.au

We will then attempt to resolve it in accordance with our resolution procedure. You will receive a response within 30 days; however we will make every effort to respond as quickly as possible. In our response we will endeavour to explain our view of the incident and any remedies we may offer. We will also explain any improvements in our processes that may have occurred due to the incident.

You may also contact the OAIC. Generally, the OAIC will require time to respond, before they will investigate. For further information, visit www.oaic.gov.au or call the OAIC on 1300 336 002. You may also contact the NSW Health Care Complaints Commission (HCCC) on:

1800 043 159
or by going to their website
http://www.hccc.nsw.gov.au/Complaints/How-to-make-a-complaint/Default

PRIVACY, OUR WEBSITE AND SOCIAL MEDIA

Our website collects your private information for three purposes:

  • To enable us to respond to you if you use our contact form which requires your name and email and requests your phone number
    • To allow you to make an appointment via our appointment plugin AMS Connect. Their privacy policy can be found at: https://automedsystems.com.au/patient-privacy/. Generally, it states that the use of their system is completely voluntary and collects only enough information to verify your identity so that you can make an appointment in BP. The information that AMS Connect may collect is your name, email address, date of birth, address, mobile phone number and if available, your Medicare number and your payment details for tokenised payments.
  • For Google Analytics to enhance the effectiveness of our website. More information about Googles privacy policy can be found here: https://support.google.com/analytics/answer/6004245?hl=en. The information Google takes is: The city you are visiting from (taken from your IP address), what kind of device you are using, what pages you visit and how long you spend on each page. Google Analytics does use first-party cookies to do this but all information is non-personally identifiable.

MMC utilises Facebook, LinkedIn, Twitter and Instagram to varying degrees we use social media to share health information and tips and to connect with our community. MMC does not collect data from our social media. Our social media pages are public forums therefore anything added to them are available to the public. Like any social media page, ours are subject to the data collection as standard to the specific social media provider. Their policies including what, why and how they collect your data is available by visiting:

POLICY REVIEW STATEMENT

MMC’s privacy policy is reviewed regularly to ensure it is in accordance with any changes that may occur. New versions will be posted on our website and available in hard copy onsite. When we make changes we will announce these changes online and in MMC’s Information Sheet.

RACGP 4th edition Standards 4.2.1, 4.2.2

Contacting us

MAYFIELD MEDICAL CONNECTION welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday.

Call: (02) 4968 2157
Post: Attn: Website Privacy Policy

55 Hanbury St,
Mayfield NSW 2304
Australia