This policy supports the privacy and confidentiality of clients at Sport and Spinal Health (SASH) in line with the requirements of the Australian Privacy Principles (APPs).
This policy aims to ensure SASH is compliant with the requirements of the Australian Privacy Principles (APPs), which establish standards for the collection and handling of 'personal information' (as defined by the Act) by Commonwealth agencies.
SASH’s privacy and confidentiality policy provides information to you, our client, 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 client with SASH, you provide consent for our staff to access and use your personal information so they can provide you with the best possible health care. 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?
SASH will need to collect your personal information to provide allied health 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 (e.g. staff training).
WHAT PERSONAL INFORMATION DO WE COLLECT?
The information we will collect about you includes your:
names, date of birth, address, email address, contact details and next of kin
medical information including medical history, social history, family history and risk factors
Medicare number, DVA number and other government identifiers (where available) for identification and claiming purposes.
Private health fund details
Other health information about you, including:
Notes of your symptoms or diagnosis and treatment given to you
Your specialist reports and test results
Scan images, results and diagnosis
Your appointment and billing details
Any other information about your ethnicity, sexuality or religion, when collected by a health service provider.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
SASH 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 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 health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).
WHEN, WHY AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
SASH may share your personal information:
with third parties who work with us 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 a client’s life, health or safety or public health or safety, or it is impractical to obtain the client’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 (e.g. some diseases require mandatory notification)
Only people who need to access your information will be able to do so. Other than in the course of providing services or as otherwise described in this policy, SASH will not share personal information with any third party without your consent.
SASH will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
SASH 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.
SASH may use your personal information to improve the quality of the services we offer to our clients through research and analysis of our client data.
We may provide de-identified data to other organisations to improve population health outcomes. The information is secure, clients cannot be identified and the information is stored within Australia. You can let our administrative 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 SASH in various forms including paper records, electronic records, visual records (X-rays, CT scans, videos and photos).
SASH stores all personal information securely to ensure it is protected. Information in electronic format is stored in a secure cloud that is password protected in encrypted systems; information in hard copy format is stored in lockable cabinets in a secure environment. SASH staff are bound by confidentiality agreements and understand their obligations in accordance with the Australian Privacy Principles.
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.
SASH acknowledges clients may request access to their medical records. We require you to put this request in writing (hardcopy or electronic via email to email@example.com or fax 08 8166 0477) and we will respond within 30 days.
SASH 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 the Clinical Manager via email firstname.lastname@example.org or fax 08 8166 0477.
HOW CAN YOU LODGE A PRIVACY-RELATED COMPLAINT, AND HOW WILL THE COMPLAINT BE HANDLED AT OUR PRACTICE?
SASH takes complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing, addressed to the Clinical Manager. We will respond within 14 days and attempt to resolve the matter within 30 days, in accordance with our grievance and dispute resolution procedure.
Contact details for SASH are listed below:
Sport & Spinal Health
15 Nile Street,
Glenelg SA 5045
P 08 8166 0488
F 08 8166 0477
You may also contact the Office of the Australian Information Commissioner (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. You may also contact the South Australian Health and Community Services Complaints Commissioner (HCSCC) on 08 8226 8666 or www.hcscc.sa.gov.au
ANONYMITY AND PSEUDONYMS
The Privacy Act provides that individuals must have the option of not identifying themselves, or of using a pseudonym, when dealing with our practice, except in certain circumstances, such as where it is impracticable for us to deal with you if you have not identified yourself.
You consent to receiving direct marketing communications from us via post, email, phone or SMS in order for us to provide you with information on products or services that you may be interested in or complimentary SASH service offerings. SASH will not provide your personal information to any third party for marketing purposes.
We will not use your sensitive information for direct marketing purposes without your express consent. If you no longer wish to receive marketing information from us you can notify us by:
Contacting your service delivery nominated contact or the Privacy Officer;
Submitting a request via the contact us function on our Sites; or
Clicking the “Unsubscribe” function in any electronic communications.
PRIVACY AND OUR WEBSITE
SASH also collects personal information via our website www.sash.clinic and via digital means including email and social media (Facebook/Instagram). This information is securely encrypted and, as with all other personal information, SASH staff understand their obligations regarding this information in accordance with the Australian Privacy Principles.
AUTOMATIC COLLECTION OF INFORMATION
Visitors to the SASH website (www.sash.clinic) do not disclose personal information unless they provide such information through the enquiry form or an online booking. When individuals visit our website, non-personal information may be collected including but not limited to browser type, version and language, operating system, pages viewed while browsing the site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to individuals while they are at this site.
SASH may engage third parties to perform functions on our behalf. Some of these third parties are the Google Display Network and Google Analytics. SASH and third-parties make use of ‘cookies’ to gather non-personally identifiable information.
POLICY REVIEW STATEMENT
SASH will review its Privacy and Confidentiality Policy regularly to ensure it is compliant with any changes that may occur to the Australian Privacy Principles. If SASH’s Privacy and Confidentiality Policy is updated, clients will be notified via the SASH website and the Client Privacy Pamphlet.