Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act 2009 and any other relevant law.
We take the privacy of our clients we assist very seriously.
- We won’t use your personal data for any purposes that you have not agreed to, without first obtaining
- permission from you, as well advising how and why we’d like to use your details.
- We won’t discuss your personal data to any company, organisation or individual outside of CPtherapy
- unless you’ve provided us with your consent.
- We would never sell or trade your personal data to third party list brokers or direct marketing companies.
- We will do our very best to ensure that your personal data is kept safe and secure for as long as your details are in our care.
COLLECTION AND HOLDING (Australian Privacy Principle/s - APP 1, 3, 5)
CPtherapy aims to collect information in a useful, fair, lawful and non-intrusive manner. Your therapist will only collect information which is relevant to your medical care. Where reasonable and practical we will collect your personal information only directly from you - at face to face consultation, via email, via phone conversation or via mail. If you are uncertain as to why information is being requested, feel free to ask your therapist. With permission, video and audio information for assessment or intervention purposes is also taken.
In some instances, information may need to be sought from your Medical Practitioner (GP/Specialist), family or other health professionals eg. Radiologist, Physiotherapist and case manager, to ensure high quality health care. Consent will be gained from you prior to this occurring.
By law, we hold useful information electronically or in hard copy for 7 years after discharge.
Process of intervention/data gathering:
- On receipt of a referral, contact is made with the client/guardian to discuss consent to commence services with CPtherapy. If consent gained, discussion is held to determine an appropriate time and location to commence services.
- Initial personal data, included on the referral such as name, contact details, NOK, is entered into an electronic database.
- An individual client record is set-up which will hold all client documents during the time of intervention by CPtherapy.
- Where relevant, contact is made with the relevant funding body to determine eligibility for services
- Contact is made with the client face to face whereby additional information is gathered in order to guide intervention.
- A receipt of referral letter is sent to the referrer & GP as well as funding body, if relevant, outlining a brief summary of the initial contact, including date that contact was made with the client, the intervention commenced and what is planned.
ANONYMITY (APP 2)
Clients/Parents/Guardians may choose to withhold information about themselves/their child/their client, and to attend anonymously or with pseudonyms, with the understanding that this will likely jeopardize the quality of provided service. Clients wishing to be anonymous or use a pseudonym will be ineligible to receive funding via Medicare, DVA, TAC, WorkCover and Private Health insurance.
UNSOLICITED & SENSITIVE INFORMATION (APP 4)
Unsolicited information refers to information that is received by CPtherapy staff that is not requested – this may be via another health professional, family members etc. If such information is received, CPtherapy will determine if this information could have been received solicited. If not, appropriate measures will be made to de-identify and destroy.
Sensitive information relates to individuals’ racial or ethnic origins, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record. CPtherapy does not routinely collect such information about you and if required, consent will be obtained to collect.
USE AND DISCLOSURE (APP 6,7,8)
All information gathered is used or disclosed solely for the original purpose of collection: to facilitate best practice service provision for the client.
The information CPtherapy collects from you may be used for:
- The administrative purposes of running the practice
- Billing, either directly or through a third party
- Use within this organisation, when passing information to other clinical staff for your ongoing treatment and care
- Disclosure of treatment, advice or medical information to you or other clinical providers
- Electronic means such as SMS and email reminders for appointment reminders and information about CPtherapy products, services and programs (an opt-out option will be made available to you)
It is important that other people involved in your care, such as specialists, your GP, TAC or WorkCover, are informed of relevant parts of your medical history/intervention/therapy so they can best care for you. After discussion with you, your therapist may write a letter to the referring doctor/health professional, which will be posted/faxed or given to you to take to them. If you have any concerns about this discuss them with your therapist.
Your therapist will not disclose your personal health information to a third party, including overseas, unless:
- you have consented to the disclosure; or
- this disclosure is necessary because you are at risk of harm without treatment and you are unable to give consent - for example you might be unconscious after an accident: or
- your therapist is legally obliged to disclose the information (eg, notification of certain infections/diseases or suspected child abuse, or a subpoena or court order).
Using health information for quality improvement and research:
- We use patient health information to assist in improving the quality of care we give to all our patients by reviewing the treatments used in the practice.
- We may also use information that cannot be identified with you in research projects to improve health care in the community. You will normally be informed if your information is to be used for this purpose and will have the opportunity to refuse to have your identified information used in this way.
- In some circumstances, where the research serves an important public interest; identifiable medical records can be used for medical research without your consent under guidelines issued by the National Health and Medical Research Council. An official ethics committee must approve this research.
- Wherever practicable, the information used for research will not be in a form that would enable you or your child to be identified. The publication of research results, which use your information, will never be in a form that enables you to be identified.
IDENTIFIERS (APP 9)
CPtherapy does not use or disclose an identifier that has been assigned by a Commonwealth government ‘agency’ i.e. Tax File Number, Medicare Number, NDIS number – each CPtherapy client has a unique client number specific to CPtherapy only.
QUALITY (APP 10, 13)
CPtherapy takes all reasonable care to ensure that the personal information we collect or disclose is up to date, accurate, complete, relevant and not misleading.
During the course of our relationship with you we will ask you to inform us if any of your personal information has changed. If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
Your therapist will do her/his best to make sure your medical records:
- are accurate, comprehensive, well-organised and legible;
- have enough information to allow another therapist to care for you;
- do not contain offensive or irrelevant comments about you;
- contain a summary of your care;
SECURITY (APP 11)
All files are confidential with access limited to therapists. CPtherapy staff have been instructed on the principles of the Privacy Legislation and are committed to protecting privacy rights. Electronic information is encrypted and stored in Cliniko which stores and processes your data in Australia. Access requires two factor authentication. Clinko is compliant with compliant with important privacy legislation, such as the Australian Privacy Principles and GDPR
We will take reasonable steps to protect your personal information by storing it in a secure environment, and when the information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
ACCESS (APP 12)
You have access to the information contained in your medical record. You may ask your therapist about any aspect of your health care including information in your record. We believe that sharing information is important for good communication between you and your therapist and for good health care.
Information in your record can be provided to you by way of an accurate and up to date summary of your care, for instance if you are moving away and are transferring to a new health care provider. If you request a summary or direct access to your full medical record, your therapist may need to take out any information provided by others on a confidential basis. Your therapist will also need to consider the risk of any physical or mental harm to you or any other person which may result from disclosure of your health information. Depending on what is involved, you may be asked to contribute to the cost of providing the information. Your therapist will be pleased to provide a full explanation of the health summary or medical record provided.
BREACH OF PRINCIPLES/COMPLAINTS
If you believe that CPtherapy has breached any of the above principles please advise the Director, Brian Hoare in writing. The information you provide will then be handled through formal procedures.
If you are not satisfied with the way I work to resolve the breach you may contact:
- Officer of the Australian Information Commissioner. www.oaic.gov.au T: 1300 363 992
- Occupational Therapy Australia www.otaus.com.au
- Australian Health Practitioners Regulation Agency (AHPRA) www.ahpra.gov.au