AUSTRALIAN PRIVACY PRINCIPLES (APP) POLICY
 
Part A – Purpose and Context

1. Sunnybank Centre for Women is committed to ensuring the privacy and confidentiality of all personal information affiliated with the Sunnybank Centre for Women’s business undertakings. 
2. Sunnybank Centre for Women 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’).  
3. The purpose of this Privacy Policy is to clearly communicate how Sunnybank Centre for Women collects and manages personal information.  
4. The point of contact regarding any queries regarding this policy is[Kathie Carlyon, Practice Manager, 07 33454947, reception@scfw.com.au.

 
Part B – Australian Privacy Principles

1. As a private sector health service provider and under permitted health situations, Sunnybank Centre for Women is required to comply with the APPs as prescribed under the Act.
2. The APPs regulate how Sunnybank Centre for Women may collect, use, disclose and store personal information and how individuals, including Sunnybank Centre for Women’s patients may:
   • address breaches of the APPs by Sunnybank Centre for Women;
   • access their own personal information; and,
   • correct their own personal information.   
3. In order to provide patients with adequate health care services, Sunnybank Centre for Women 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 Sunnybank Centre for Women may not be able to provide the patient with the services they are requesting.   
4. In this Privacy Policy, common terms and definitions include:​
   • "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 opinion about the health or disability (at any time i.e. past, present or future) of an individual that can be classified as personal information;
     • Information or opinion about an individual’s expressed wishes about the future provision of health services that can be classified as personal information;
     • Information or opinion about health service provided, or to be provided, to an individual, that can be classified as personal information;
     • Other personal information collected to provide, or in providing, a health service;
     • Other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
     • Genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.
   • Personal information also includes 'sensitive information' which is information including, but not limited to a patient’s:
     • race;
     • religion;
     • political opinions;
     • sexual preferences; and or,
     • health information.
   • 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

1. Sunnybank Centre for Women collects information from each individual patient that is necessary to provide the patient with adequate health care services.  
2. This may include collecting information about a patient’s health history, family history, ethnic background or current lifestyle to assist the Sunnybank Centre for Women in diagnosing and treating a patient’s condition. 

 
Part D – collection & Retention

1. This information will in most circumstances be collected directly from the patient through but not limited to the following mediums:  
   • Sunnybank Centre for Women patient consent form;
   • medical treatment form; and or,
   •  face to face consultation.
2. In other instances, Sunnybank Centre for Women may need to collect personal information about a patient from a third party source. This may include:
   • relatives; or,
   • other health service providers.   
3. This will only be conducted if the patient has provided consent for Sunnybank Centre for Women to collect his/her information from a third party source; or, where it is not reasonable or practical for Sunnybank Centre for Women to collect this information directly from the 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. Sunnybank Centre for Women endeavours to store and retain a patient’s personal & health information in [hard copy on site, transferred electronically onto a domestic server etc].  

 
 Part E – Purpose of collection, Use & Disclosure

1. Sunnybank Centre for Women 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 Sunnybank Centre for Women to use his/her information for an alternative or additional purpose;
   • the disclosure of the patient’s information by Sunnybank Centre for Women 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 Sunnybank Centre for Women will prevent or lessen a serious and imminent threat to somebody's life or health; or,
   • Sunnybank Centre for Women is required or authorised by law to disclose the patient’s information for another purpose.

1. Health Professionals to provide treatment

During the patient’s treatment at Sunnybank Centre for Women he/she may be referred to alternative medical treatment/services (i.e. pathology or radiology) where Sunnybank Centre for Women’s staff may consult with senior medical experts when determining a patient’s diagnosis or treatment. 
 
Sunnybank Centre for Women’s staff may also refer the patient to other health service providers for further treatment during and following the patient’s admission.  These services include, but are not limited to:  

• Physiotherapy; or,
• Outpatient or community health services.

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.
 

1. 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 Sunnybank Centre for Women 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.
 

1. Other Third Parties

Sunnybank Centre for Women may provide the patient’s personal information regarding a patient’s treatment or condition to additional third parties. These third parties may include:

• parent(s);
• child/ren;
• 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.

1.  Other Uses of Personal Information

In order to provide the best possible environment to treat patients, Sunnybank Centre for Women 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.

If at any point or for any of the aforementioned reasons Sunnybank Centre for Women uses or discloses personal/ health information in accordance with the APPs, Sunnybank Centre for Women will provide written notice for the patient’s consent for the use and/or disclosure.  

Part F – Access and changes to personal information

1. If an individual patient reasonably requests access to their personal information for the purposes of changing the information he/she must engage with the relevant practice manager.  
2. The point of contact for patient access to personal information is:
   Kathie Carlyon
   Practice Manager
   07 33454947
3. Once an individual patient requests access to his/her personal information Sunnybank Centre for Women will respond within a reasonable period of time to provide the information.  
4. All personal information will be updated in accordance to any changes to a patient’s personal circumstances brought to Sunnybank Centre for Women’s attention. All changes to personal information will be subject to patient’s consent and acknowledgement.  
5. If an individual requests access to his/her personal information Sunnybank Centre for Women will charge $50. Please note that this fee is associated with administrative costs only.  

Part G – Complaints handling

1. 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  

1. Use of Overseas Parties:  
   • Sunnybank Centre for Women does not engage with any overseas entities, with which personal or health information would be transferred, appointed or disclosed.
   • Sunnybank Centre for Women at this stage does not engage with overseas entities, with which personal or health information would be transferred, appointed or disclosed.

Part i – Disposal of personal/health information

1. If Sunnybank Centre for Women receives any unsolicited personal information that is not deemed appropriate for the permitted health situation, Sunnybank Centre for Women will reasonably de-identify and dispose of the information accordingly.  
2. If Sunnybank Centre for Women holds any personal or health information that is no longer deemed relevant or appropriate for the permitted health situation, Sunnybank Centre for Women will reasonably de-identify and dispose of the information accordingly.

Part J – Access to policy

1. Sunnybank Centre for Women provides free copies of this Privacy Policy for patients and staff to access, which can be/will be located/provided:

          [www.sunnybankwomens.com.au]
          [Manual]
          [Hard Copies provided upon request]
 
Part K – Review of Policy

1. Sunnybank Centre for Women 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.   
2. Notification of any additional review(s) or alteration(s) to this policy will be provided to patients and staff within 4 weeks notice. If change occurs patients and staff are required by Sunnybank Centre for Women to acknowledge in writing this Privacy policy.

Part L – Patient Acknowledgement
 
I Patient Name, acknowledge that I have read the aforementioned Privacy and Confidentiality Policy and understand the requirements of Sunnybank Centre for Women and myself in how to manage my personal information whilst attending Sunnybank Centre for Women