To ensure clients who receive care from Ford Health are comfortable in entrusting their health information to Ford Health. This policy provides information to our clients as to how their personal information (which includes health information) is collected and used within Ford Health, and the circumstances in which we may disclose it to third parties.
2. Related Standards
RACP Compliance indicators for the Australian Privacy Principles (APP): an addendum to the computer and information security standards (Second edition).
Personal information includes name and address, bank account details or credit card information, photos and information about opinions and what you like.
Health information includes personal information collected to provide, or in providing, a health service.
Sensitive information means information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political, professional or trade association or trade union, religous beliefs or affiliations, philosophical believs, sexual preferences or practices, or criminal record, as well as health information.
4. 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 Ford Health’s existing obligation and commitment to manage personal information in a regulated, open and transparent manner.
This policy will guide Ford Health staff in meeting legal obligations. It also details to clients how Ford Health uses their personal information. The policy will be made available to clients upon request.
5. Ford Health procedure
Ford Health 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 (including sensitive information) for the primary purpose of managing a client’s healthcare and for financial claims and payments.
6. Staff responsibility
Ford Health staff will take reasonable steps to ensure clients 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
- Ford Health’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.
7. Client consent
Ford Health will only interpret and apply a client’s consent for the primary purpose for which it was provided including the use of a client’s data in de-identified, aggregate datasets for analysis. Ford Health staff must seek additional consent from the client if the personal information may be used for any other purpose.
8. Collection of information
Ford Health will need to collect personal information as a provision of its clinical services to a client at the practice. Collected personal information will include the client’s:
- name, address and contact details (including work company/organisation, marital status, ethnicity and country of birth, GP name and address)
- medical information including medical history, medications, allergies, adverse events
- any other information including occupation and work habits for the purpose of completing a health assessment.
A client’s personal information may be held at Ford Health in various forms:
- as paper records
- as electronic records
- as visual records – x-rays, CT scans, videos and photos
- as audio recordings
Ford Health’s procedure for collecting personal information is set out below.
- Ford Health may be the recepient of client contact details from their employer, this includes name, contact details and date of birth.
- Practice staff collect personal and demographic information via registration when clients present to Ford Health. This information is also collected when completing a health assessment in the form of either an electronic or hard copy questionnaire. Clients are encouraged to pay attention to the consent statement included in the form and information about (i) consent to participate, (ii) consent to data release, (iii) understanding of medical limitations and (iv) medical standards.
- During the course of providing medical services, Ford Health’s healthcare staff will consequently collection further confidential information.
Personal information may also be collected from any other involved healthcare specialists.
- Ford Health holds all personal information securely, whether in electronic format, in protected information systems or in hard copy format in a secure environment.
9. Use and disclosure of information
De-identified, aggregated client data may be utilised for the purpose of corporate reporting when the health service has been completed as part of an employer sponsored program involving health assessments, health coaching, skin checks and other services provided by Ford Health. De-identified, aggregate data may also be utilised by Ford Health for research purposes which may be published. Minimum numbers apply for any statistical analysis to ensure anonymity and confidentiality of personal and sensitive health information.
Personal information will only be used for the purpose of providing medical services (including recall, referral follow-up and health coaching programs) and for claims and payments, unless otherwise consented to. Some disclosure may occur to third parties engaged by or for Ford Health for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy. Ford Health will inform the client where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).
Ford Health will not disclose personal information to any third party (including the employer) other than in the course of providing medical services, without full dislosure to the client or the recipient, the reason for the information transfer and full consent of the client. Ford Health will not disclose personal information to anyone outside Australia without need or without client consent.
Exceptions to disclose without client consent are where the information is:
- required by law
- 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 a confidential dispute resolution process.
Ford Health will not use any personal information in relation to direct marketing to a client without that client’s express consent. Ford Health may use personal information (not sensitive information) for the purpose of newsletters and recall, however the client may opt out of direct marketing at any time by notifying Ford Health in a letter or email.
Ford Health evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.
10. Use and disclosure of information
Ford Health acknowledges clients may request access to their medical records. Clients are encouraged to make this request in writing, and Ford Health will respond within a reasonable time.
Ford Health will take reasonable steps to correct personal information where they are satisfied they are not accurate or up to date. From time to time, Ford Health will ask clients to verify the personal information held by Ford Health is correct and up to date. Client’s may also request Ford Health corrects or updates their information, and clients should make such requests in writing.
Ford Health takes complaints and concerns about the privacy of client’s personal information seroiusly. Clients should express any privacy concerns in writing. Ford Health will then attempt to resolve it in accordance with its complaints resolution procedure.
11. Further Information: