Since 12 March 2014, FlindersFertility has applied the 13 Australian Privacy Principles, as set out in the Privacy Act 1988 (Cth) (Privacy Act), to the way it collects, holds, uses, and discloses personal information.
The Privacy Principles focus on the consideration and the collection of personal information, dealing with personal information, the integrity of personal information, access to personal information and the correction of personal information. This Policy sets out information relating to the Privacy Act that Flinders Fertility has in place in relation to patients' personal information.
What information do we collect?
The personal information that we collect and hold may include:
- Patient contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;
- details of services we supply at a patients' request;
- data relating to your activity on our websites via tracking technologies such as cookies;
- details of any survey responses you provide;
- for job applicants or staff, employment history and educational qualifications; and medical indemnity if applicable, and
- private health insurance, concession cards and Medicare details.
We may also collect and hold sensitive information about you, including:
- health information;
- racial or ethnic origin;
- sexual orientation;
- religious beliefs or affiliations; and
- genetic information.
How personal information is collected
We only collect sensitive information about patients with their consent, or otherwise in accordance with the Privacy Act, noting that Flinders Fertility is a health service provider.
We will only collect personal information where it is necessary to do so for the conduct of our business. Any collection of personal information by us will be fair and lawful and will not be intrusive. We only collect health information if this is neccessary for the delivery of healthcare services.
We will collect personal information about you in the following ways:
- if it is provided to us by patients in a consultation with one of our staff;
- if it is provided to us by patients or referrers by telephone or facsimile; and/or
- if patients contact us via email or submit information through our website.
If it is reasonable and practical do so, we will collect personal information about patients only from themselves. In the course of operating our business, however, we may collect personal information from third parties such as other medical professionals. If we collect personal information about patients from a third party we will, where appropriate, request that the third party to inform patients that we are holding such information, explain how we will use and disclose it, and inform patient that they may contact us to gain access to and correct and update the information.
How do we hold patient information?
We will hold personal information as either physical records, records on our servers, and in some cases, records on third party servers. We take active steps to hold all hard copy and electronic records of personal information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure.
We have procedures in place to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
How do we use and disclose patient information?
In general, we will collect, hold, use and disclose personal information for the purposes of providing or offering fertility services to patients.
By providing us with personal information, patients consent to us using and disclosing their personal information for the following purposes:
- to improve the quality of care;
- to provide news and information about the goods and services we offer;
- to send marketing and promotional material that we believe may be of interest;
- for job applicants, assessing your eligibility for employment with Flinders Fertility.
Patients may opt out of receiving marketing and promotional material from us at any time by contacting our Privacy Officer, using the contact details set out at the end of this Policy.
We may use or disclose personal information in circumstances in which we are required or authorised by law to do so. For example,
- to avoid, lessen or prevent a serious emergency or crime;
- where necessary to obtain Medicare payments and other health insurance rebates;
- to report assisted reproductive technology treatments and pregnancy data to the Australia and New Zealand Assisted Reproductive Database. This information (when collected) is reviewed by the Reproductive Technology Accreditation Committee.
We may disclose personal information between our related bodies corporate or to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act.
Any disclosure that is required to be made to any third party will be made primarily for the purpose of providing services to you. If we disclose information to a third party, we take reasonable steps to ensure that the third party protects the information to the same extent that we do.
How can patients access or correct information?
Patients may request access to or correction of their personal information at any time by sending a written request to our Privacy Officer, using the contact details set out at the end of this Policy.
Patients do not need to provide a reason for the request to access their personal information. We may charge a small fee for providing access to personal information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form. We will not charge a fee to correct personal information that we hold in our records.
We will respond to all requests for access to or correction of personal information within a reasonable time. We will take reasonable steps to ensure that the personal information about you that we hold is accurate and up-to-date.
Please note there may be circumstances in which we are not able to provide patients with access to their information, such as where the requested access will have an unreasonable impact upon the privacy of others or where we are required by law to withhold the information. If we deny a request to provide access to information, or make any correction requested, we will provide patients with reasons for this decision.
Flinders Fertility assigns its own identifiers, being a unique number to identify individuals, and will not adopt government related identifiers in respect of patients' personal information.
Where practicable, we will allow patients to deal with us anonymously or under a pseudonym. This option will not be available where we are required or authorised by law to deal with individuals who have properly identified themselves, or if we need to verify your identity in order to provide services to you. Further, if patients refuse to give us personal information that we request, we may not be able to provide any of the goods or services requested.
Cross Border Disclosures of Information
As at the date of this Policy, Flinders Fertility is not likely to disclose personal information to overseas recipients. If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act.
Questions or complaints?
We take all complaints seriously, and will respond within a reasonable period.
If patients are dissatisfied with the handling of a complaint, they may contact the Office of the Australian Information Commissioner.
See www.oaic.gov.au for further information.
Our Privacy Officer can be contacted as follows:
Flinders Fertility Privacy Officer