PART A: OVERVIEW AND PURPOSE
Dr David Sharp Plastic Surgery and the PRAHS Cosmetic and Rejuvenation Clinics respects your rights to privacy and takes our privacy obligations very seriously. We comply with the Australian Privacy Principals, found under the Privacy Act 1988 (Cth) (Privacy Act).
When you first register as a patient, our Patient Registration Form requests your consent so that we can collect, use, hold and share your personal information in order to provide you with high quality healthcare and allow us to manage our practice. If we intend to use your personal information for any other purpose, we will seek your consent first.
- How we manage your personal information (including your health information), including the collection, use, disclosure, quality and security of your personal information.
- The kinds of information we collect and how that information is held.
- The purposes for which we collect, hold, use and disclose personal information.
- How you can access your personal information and how you can request to correct such information.
- How you can complain about a breach of your privacy and how we will handle your complaint.
“Personal Information” as defined in the Privacy Act. This means: information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- Whether the information or opinion is true or not.
- Whether the information or opinion is recorded in a material form or not
“Health Information” as defined in the Privacy Act. This is a 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
- A health service provided or to be provided to an individual.
Personal information also include “sensitive information” which is information such as your race, religion, political opinions, sexual preferences and/or “health information”. Information which is “sensitive information” attracts a higher privacy standard under the Privacy Act and is subject to additional mechanisms for your protection.
“We”, “Us”, “Our”, shall meanDr David Sharp Plastic Surgery and PRAHS Cosmetic and Rejuventation Clinics
PART B: COLLECTION OF PERSONAL INFORMATION
Dr David Sharp Plastic Surgery and PRAHS Cosmetic and Rejuventation Clinic collects information which is necessary to provide you with healthcare services and to appropriately manage and conduct our business. This includes collecting personal information, such as your name and contact details, medical history, family history, past and current treatments, lifestyle factors and any other information which is necessary to assist us in providing you appropriate care. We will also collect your Medicare number, Department of Veterans Affairs Number and Private Health Insurance details (where applicable).
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 authorized by law to only deal with identified individuals. It is important to be aware that if you provide incomplete or inaccurate information or withhold information we may not be able to provide with you complete healthcare services.
We will usually collect your personal information directly from you, including from patient registration forms, medical records and consultations with you, or from another health service provider. Sometimes we need to collect information about you from third parties, such as relatives and friends and private health insurers.
We will only collect information from third parties where:
- You have consented to such collection.
- Such collection is necessary to enable us to provide you with appropriate healthcare services (such as emergency medical treatment or where your health is at risk).
- Such collection is reasonably necessary to enable us to appropriately manage and conduct our business.
- It is legally permissible for us to do.
Dr David Sharp Plastic Surgery and PRAHS Cosmetic and Rejuventation Clinics outsources to third party suppliers the storage of your personal information. These suppliers include:
- Dropbox – falls under US jurisdiction for Privacy Regulations where the standard is similar to that of the Privacy Act.
- Crisalix – falls under the EU jurisdiction for Privacy Regulations. This standard is higher than that of the Privacy Act
PART C: HOW WE USE YOUR INFORMATION
We only use your personal information to provide you with healthcare services, to facilitate the provision of healthcare services by other provider, or to enable us to appropriately manage and conduct our business, unless:
- There is a secondary purpose which directly relates to the primary purpose, and you would reasonably expect, or we have informed you, that your information will be used for that secondary purpose, or you have given your consent for your personal information to be used for a secondary purpose.
- The disclosure of your information is 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 your information will prevent or lessen a serious and imminent threat to somebody’s lift or health.
- Dr David Sharp Plastic Surgery and PRAHS Cosmetic and Rejuventation Clinics is required or authorized by law to disclose your information for another purpose.
For example, Dr David Sharp Plastic Surgery and PRAHS Cosmetic and Rejuventation Clinics uses your personal information:
- To provide healthcare services to you.
- To appropriately manage our practice, such as conducting audits, manage billings and training staff.
- Effectively communicate with third parties, including private health insurers, Medicare Australia, Department of Veterans Affairs and other government departments.
PART D: DISCLOSING YOUR PERSONAL INFORMATION
We disclose your personal information to our employees, contractors and service providers in order for us to provde healthcare services to you and to allow us to manage our business. We will also disclose your personal information to healthcare professionals directly involved in your treatment. Where your medical records are required in the case of a medical emergency, we will provde these to the relevant medical professional without waiting for your consent, where we believe this is in your interests.
You personal information may also be provided to third parties if we are legally obligated to do so by a court subpoena, statutory authority, search warrant, coronial summons or to defend a legal action.
We may provide your personal information to third parties involved in your care, such as:
- Your parents, children, realtives and close friends, guardians or a person exercising a power of attorney or enduring power of attorney. Please advise us if it is your wish no third party as stated is to have access to your personal information.
- Government departments and agencies, such as Defence of Department of Veterans Affairs, or departments responsible for health, aged care and disability where we are required to do so.
- Private health insurers and Medicare Australian.
- Anyone authorized by you to receive your personal information.
PART D: OVERSEAS RECIPIENTS
- Dropbox – located in USA
- Crisalix – located in the EU
PART E: DATA STORAGE, QUALITY AND SECURITY
We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. All personal information, whether stored as a hard copy or electronic form is protected from unauthorised access, misuse, interference, loss, modification or disclosure. Some of the steps we take to ensure your personal information is secure include:
- We maintain physical security over our paper and electronic data and premises with a back to base monitored security system.
- We train our staff on privacy and we have detailed internal processes and systems to protect your privacy.
- Our IT security includes virus controls, firewalls, encryption, user identifiers and passwords to control access to computer systems where your information is stored and other IT security measure.
- We have a clean desk policy and any physical records are stored in a locked area.
- We use and Australian hosted data centre to store and back up our data. This is managed by professional IT consultations and we have written agreements with them which includes requirements for backup, security and that they abide by the Australian Privacy Principals.
Dr David Sharp Plastic Surgery and PRAHS Cosmetic Rejuventation Clinic website and email is linked to the internet. No data transfer over the internet is 100% secure. Accordingly, any information which you may transmit to us online or via email is transmitted at your own risk.
PART F: DESTROYING YOUR PERSONAL INFORMATION
Subject to applicable laws, Dr David Sharp Plastic Surgery and PRAHS Cosmetic Rejuventation Clinic may destroy records containing personal information when the record is no longer required by Dr David Sharp Plastic Surgery and PRAHS Cosmetic Rejuventation Clinics.
It is likely your medical records held by us contain sensitive information. We are required to abide by relevant legislation in the retention and disposal of your medical records.
We are an electronic medical records practice. When you first register as a patient we will ask you to complete our new patient registration form and return to reception. We will enter the details and scan into our system and then securely destroy the hard copy on-site. We ask that you take with you any hard copy scans or images as we only retain on file electronic copies.
As we are an electronic medical records practice, all electronic records are kept indefinitely – as you may require your record in the future. If you are no longer an active patient we will archive your record.
Any paper records are destroyed by a secure shredding service as required by law after any statutory periods are met.
PART G: ACCESSING AND AMENDING YOUR PERSONAL INFORMATION
We encourage you to contact us if you have a query regarding your personal information. You may request an amendment to your personal information if you consider that it contains inaccurate, incorrect or incomplete information.
You have a right to request access to any information we hold about you. If you make a request to access personal information that you are entitled to access, we will provide you suitable means of accessing it. We will not charge you for making the request, In circumstances where you request we provide a copy of your personal information to you, we may charge you a fee to cover our reasonable costs for complying with the request for access.
There may be instances where we cannot grant you access to some of the information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others. If that is the case, we will provide you with a written explanation of those reasons.
You can contact us about any privacy issues as follows:
PART H: COMPLAINTS
If you have a complaint about how we have dealt with your personal information or believe we have breached your privacy, please contact us on the details below so that we may investigate it. We will deal with your complaint fairly and confidentially. On receipt of your complaint we will contact you within 10 businees days to confirm what investigation action will occur. We will then communicate the outcome to you in writing and invite a response to our conclusion about the complaint. If we receive a response from yo, we will also assess it and advise if we have changed our view.
If you are unsatisfired with our response, you may refer the complaint to the Office of the Australian Inforamtion Commissioner (http://www.oaic.gov.au).