This privacy policy is to provide information to you, our patient, on how your personal information (which includes your health information) is collected, stored, and used within our practice, and the circumstances in which we may share it with third parties.
In handling your personal information, we are required to comply with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles (APPs) under the Privacy Act. Further, as a health services provider, SkinSafe is required to comply with the Health Care Act 2008 (SA) and the associated Health Care (Confidentiality) Amendment Act 2009 (SA).
Why and when your consent is necessary
When you register as a patient of our practice, you provide consent for our doctors and practice staff to access and use your personal information so they can provide you with the best possible healthcare. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do this.
Why do we collect, use, hold and share your personal information?
Our practice will need to collect your personal information to provide healthcare services to you. Our main purpose for collecting, using, holding, and sharing your personal information is to manage your health. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (e.g. staff training, quality improvement, marketing and research purposes).
What personal information do we collect?
The information we will collect about you includes:
● Names, date of birth, addresses, contact details;
● Medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors;
● Medicare number (where available) for identification and claiming purposes;
● Healthcare identifiers;
● Health fund details.
Dealing with us anonymously
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 authorised by law to only deal with identified individuals.
How do we collect your personal information?
Our practice will collect your personal information directly from you:
● When you book an appointment (either online or via telephone), our practice staff will collect your personal and demographic information via your registration;
● During the course of providing medical services, we may collect further personal information;
● When you interact with us over the phone, in person, or online;
● When you participate in surveys, questionnaires, or subscribe to our mailing list;
● When you apply for a position with us as an employee or contractor.
In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:
● Your guardian or responsible person;
● Other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services;
● Your health fund, Medicare, or the Department of Veteran'sAffairs (as necessary);
● Your “MyHealth” record.
Who do we share your personal information with?
We sometimes share your personal information:
● With third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers–these third parties are required to comply with APPs and this policy;
● With other healthcare providers;
● When it is required or authorised by law (e.g. court subpoenas);
● When it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety, or public health or safety, or it is impractical to obtain the patient’s consent;
● To assist in locating a missing person;
● To establish, exercise or defend an equitable claim;
● For the purpose of confidential dispute resolution process;
● When there is a statutory requirement to share certain personal information (e.g. some diseases require mandatory notification);
● During the course of providing medical services, through Electronic Transfer of Prescriptions (eTP), MyHealth Record/PCEHR system (e.g. via Shared Health Summary, Event Summary).
Only people that need to access your information will be able to do so. Other than while providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.
Transfer of information overseas
Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia. Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:
● You have given us your consent to disclose personal information to that third party; or
● We reasonably believe that:
○ the overseas recipient is subject to a law or binding scheme that is, substantially similar to the APPs; and
○ the law or binding scheme can be enforced; or
● The disclosure is required or authorised by an Australian law or court/tribunal order.
We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
Direct marketing
We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication / contacting us using the details set out in the “Contact Us” section below.
How do we store and protect your personal information?
Your personal information may be stored at our practice in various forms. As electronic record, paper record, photos, and for some training purposes videos (for a short time)
SkinSafe will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:
● Having a robust physical security of our premises and databases/records;
● Taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;
● Having technological measures in place (for example, anti-virus software, fire walls).
Retention of personal information
We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.
How can you access and correct your personal information at our practice?
You have the right to request access to, and correction of, your personal information. SkinSafe acknowledges patients may request access to their medical records. We require you to put this request in writing and our practice will respond within 5-10 working days. We will need to verify your identify first and there may be an administrative fee for providing the information.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time-to-time, we will ask you to verify your personal information held by our practice is correct and up to date. You may also request that we correct or update your information, and you should make such requests in writing.
Online activity
The SkinSafe website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website before, so we can distinguish you from other users of the website. This improves your experience and the SkinSafe websites. We do not use cookies to identify you, just to improve your experience on our website. If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.
Website analytics
Our website uses analytics to help us better understand visitor traffic so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.
Links to third party sites
SkinSafe website contains links to websites operated by third parties. If you access a third party website through our website, personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.
How can you lodge a privacy related complaint, and how will the complaint be handled at our practice?
We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure. Samuel Laidlaw is the privacy officer for the practice, he can be contacted atadmin@skinsafe.au if you have any questions. Note we may require proof of your identity and full details of your request before we can process your complaint. Please allow up to 30 days for SkinSafe to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction.
You may also contact the OAIC. Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on1300 336 002
Policy review statement
This privacy policy will be reviewed regularly to ensure it is in accordance with any changes that may occur.
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