AUSTRALIAN PRIVACY PRINCIPLES (APP) POLICY
Part A – Purpose and Context
1.0. Cole Dental is committed to ensuring the privacy and confidentiality of all personal information affiliated with the Cole Dental’s business undertakings.
1.1 Cole Dental follows the terms and conditions of privacy and confidentiality in accordance to the Australian Privacy Principles (APPs) as per schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), forming part of the Privacy Act 1988 (‘the Act’).
1.3. The point of contact regarding any queries regarding this policy is Andrea, Practice Manager, firstname.lastname@example.org
Part B – Australian Privacy Principles
2.0 As a private sector health service provider and under permitted health situations, Cole Dental is required to comply with the APPs as prescribed under the Act.
2.1 The APPs regulate how Cole Dental may collect, use, disclose and store personal information and how individuals, including Cole Dental’s patients may:
- address breaches of the APPs by Cole Dental;
- access their own personal information; and,
- correct their own personal information.
2.2 In order to provide patients with adequate health care services, Cole Dental will need to collect and use personal information. It is important to be aware that if the patient provides incomplete or inaccurate information or the patient withholds personal health information Cole Dental may not be able to provide said patient with the services they are requesting.
- "personal information" as defined by the Privacy Act 1988 (Cth). Meaning "information or an opinion including information or an opinion forming part of a database, whether true or not, and whether recorded in a material format or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion"; and,
- "health information" as defined by the Privacy Act 1988 (Cth). This is a particular subset of "personal information" and means information or an opinion about:
- the health or a disability (at any time) of an individual;
- an individual's expressed wishes about the future provision of health services to him or her; or,
- a health service provided or to be provided to an individual.
2.3.1 Personal information also includes 'sensitive information' which is information including, but not limited to a patient’s:
- political opinions;
- sexual preferences; and or,
- health information.
2.3.2 Information deemed 'sensitive information' attracts a higher privacy standard under the Act and is subject to additional mechanisms for the patient’s protection.
Part C – Types of personal information
3.0 Cole Dental collects information from each individual patient that is necessary to provide said patient with adequate health care services.
3.1 This may include collecting information about a patient’s health history, family history, ethnic background or current lifestyle to assist the health care team in diagnosing and treating a patient’s condition.
Part D – Collection & Retention
4.0 This information will in most circumstances be collected directly from you via treatment form, medical consult form, face to face consultation etc.
4.1 In other instances, Cole Dental may need to collect personal information about a patient from a third party source. This may include:
- relatives; or,
- other health service providers.
4.2 This will only be conducted if the patient has provided consent for Cole Dental to collect his/her information from a third party source; or, where it is not reasonable or practical for Cole Dental to collect this information directly from said patient. This may include where:
- the patient’s health is potentially at risk and his/her personal information is needed to provide them with emergency medical treatment.
4.3 Cole Dental endeavours to store and retain a patient’s personal & health information in on site, off site on a hard drive carried by the Practice Manager and off site on a secure server provided by our IT Company.
Part E – Purpose of Collection, Use & Disclosure
5.0 Cole Dental only uses a patient’s personal information for the purpose(s) they have provided the information for unless one of the following applies:
- the patient has consented for Cole Dental to use his/her information for an alternative or additional purpose;
- the disclosure of the patient’s information by Cole Dental is reasonably necessary for the enforcement of criminal law or a law imposing a penalty or sanction, or for the protection of public revenue;
- the disclosure of the patient’s information by Cole Dental will prevent or lessen a serious and imminent threat to somebody's life or health; or,
- Cole Dental is required or authorised by law to disclose your information for another purpose.
i. Health Professionals to provide treatment
During the patient’s treatment at Cole Dental he/she may be referred to alternative medical treatment/services (i.e. pathology or radiology) where Cole Dental’s staff may consult with senior medical experts when determining a patient’s diagnosis or treatment.
Cole Dental’s staff may also refer the patient to other health service providers for further treatment (i.e. allied health or GP).
These health professionals will be designated health service providers appointed to use the patient’s health information as part of the process of providing treatment. Please note that this process will be conducted whilst maintaining the confidentiality and privacy of the patient’s personal information.
ii. Alternative Health Services
At any point a patient wishes to be treated by an alternative medical practitioner or health care service that requires access to his/her personal/health information Cole Dental requires written authorisation. This written authorisation is to state that the patient will be utilising alternative health services and that these health services have consented for a transfer of personal/health information.
iii. Other Third Parties
Cole Dental may provide your personal information regarding a patient’s treatment or condition to additional third parties. These third parties may include:
- other relatives;
- close personal friends;
- guardians; or,
- a person exercising a patient’s power of attorney under an enduring power of attorney.
Where information is relevant or reasonable to be provided to third parties, written consent from the patient is required.
Additionally, the patient may at any time wish to disclose that no third parties as stated are to access or be informed about his/her personal information or circumstances.
iv. Other Uses of Personal Information
In order to provide the best possible environment in which to treat patients, Cole Dental may also use personal/health information where necessary for:
- activities such as quality assurance processes, accreditation, audits, risk and claims management, patient satisfaction surveys and staff education and training;
- invoicing, billing and account management;
- to liaise with a patient’s health fund, Medicare or the Department of Veteran's Affairs, as necessary; and,
- the purpose of complying with any applicable laws – i.e. in response to a subpoena or compulsory reporting to State or Federal authorities.
5.1 If at any point or for any of the aforementioned reasons Cole Dental uses or discloses personal/ health information in accordance with the APPs, Cole Dental will provide written notice for the patient’s consent for the use and/or disclosure.
Part F – Access and Changes to Personal Information
6.0 If an individual patient reasonably requests access to their personal information for the purposes of changing said information he/she must engage with the relevant practice manager.
6.1. The point of contact for patient access to personal information is:
The Practice Manager
07 3205 5811
Monday to Friday
07 3205 5811
Monday to Friday
6.2 Once an individual patient requests access to his/her personal information Cole Dental will respond within a reasonable period of time to provide said information.
6.3 All personal will be updated in accordance to any changes to a patient’s personal circumstances brought to Cole Dental’s attention. All changes to personal information will be subject to patient’s consent and acknowledgement.
Part G – Complaints Handling
7.0 How an individual patient may complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint.
Part H – Personal Information and Overseas Recipients
8.0. Use of Overseas Parties:
- (a) Cole Dental does not engage with any overseas entities, with which personal or health information would be transferred, appointed or disclosed.
Part I – Disposal of Personal/Health Information
9.0 If Cole Dental receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Cole Dental will reasonably de-identify and dispose of said information accordingly..
9.1 If Cole Dental holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Cole Dental will reasonably de-identify and dispose of said information accordingly.
Part J – Access to Policy
Part K – Review of Policy
11.1 Cole Dental in accordance with any legislative change will review the terms and conditions of this policy to ensure all content is both accurate and up to date.
Part L – Patient Acknowledgement
I,_______________________________________, acknowledge that I have read the aforementioned Privacy and Confidentiality Policy and understand the requirements of Cole Dental and myself in how to manage my personal information whilst attending Cole Dental.