TGPN Privacy Policy

Introduction

Townsville General Practice Network (TGPN) is committed to complying with National Privacy Principles in the Privacy Amendment (Private Sector) Act 2000, which commenced in December 2001, the Health Records Act 2001 and the privacy provisions of all applicable legislation.

This privacy policy covers all personal information we hold; that is, information or an opinion, about an individual, whose identity is apparent, or can be reasonably ascertained, from that information or opinion.

The policy also covers personal information that we have sourced from third parties.

In compliance with the Privacy Amendment (Private Sector) Act 2000, TGPN has prepared this Privacy Policy to describe the way and circumstances under which personal information is collected, stored, used and disclosed by the Division. The Policy is intended as a guide to Division staff and members, and for the advice of the broader community.

Any enquiry regarding this Policy should, in the first instance, be directed to the Division’s Privacy Officer on (07) 4725 8915 or email: contact@tgpn.com.au

This policy is freely available to all members of staff and new staff are made familiar with it at induction.

This policy is a public document and access to it will be granted on request. It is also available on the Division’s web site: www.tgpn.com.au, where the current version will be maintained.

Definitions

Complaints Handling

Any complaints in relation to this Division’s handling of personal information should be directed to the Privacy Officer. In most cases the complainant will be asked to lodge their complaint in writing.

Unless a complaint can be dealt with immediately to the satisfaction of both parties, the Division will provide a written response to the complaint within 30 days of its being received.

If an individual believes their complaint has not been appropriately handled by the Division, they should contact the Office of the Federal Privacy Commission, Privacy Hotline 1300 363 992 (local call charge) or via the internet, www.privacy.gov.au

1. COLLECTION

TGPN will only collect personal information necessary to undertake our programs, activities or functions.

1.1 Personal information about an individual will only be collected by lawful and fair means and directly from the individual wherever possible.

1.2 The name and role of the appropriate member of staff will be provided to every individual who provides personal information.

1.3 We will ensure that each individual providing personal information is informed about and understands the purpose of collecting the information, to whom or under what circumstances their personal information may be disclosed to another party, and how they can access the information held about them by the Division.

1.4 We will ensure that individuals providing personal information understand the consequences, if any, of providing incomplete or inaccurate information.

2. USE AND DISCLOSURE

TGPN will ensure that personal information will only be used for the purpose it was collected, or that would reasonably be accepted by the individual providing the information.

2.1 If the identified information is to be used for a secondary or unrelated purpose, such as data analysis or research.

    2.1.1 Individuals will be given the opportunity to refuse such use or disclosure.

    2.1.2 If an individual is physically or legally incapable or providing consent, a responsible person (as described under the Act) may do so.

2.2 We will only disclose personal information without consent where such disclosure is required by law, or for law enforcement, or in the interests of the individual’s or the public’s health and safety

    2.2.1 We will keep records of any such use and disclosure.

    2.2.2 Information may be disclosed to a responsible person (as described under the Act).

3. DATA QUALITY

This Division will take reasonable steps to ensure that personal information kept, used or disclosed by the Division is accurate, complete and as up to date as practicable.

4. DATA SECURITY

4.1 All personal information held by this Division will be:

• If in paper form, received and stored in a secure, lockable location;
• If in electronic form, password and firewall protected;
• Accessible by staff only on a “need to know” basis;
• Not taken from the Division offices unless authorised and for a specific purpose.

4.2 We will destroy or permanently de-identify personal information that is no longer required by the Division.

5. OPENNESS

This policy will be made available to any person requesting access to it.

5.1 A general statement describing our approach to privacy will be available on the TGPN web site: www.tgpn.com.au

6. ACCESS AND CORRECTION

Under normal circumstances this Division will provide an individual with access to their personal information within 30 days of receiving a written request for access.

6.1 There will be no fee associated with lodging a request for access, however, a small but reasonable administration fee may be charged,

6.2 Provision of access to a person’s personal information will be undertaken in a way that is appropriate to the person’s particular circumstances eg: use of interpreters etc.

6.3 If an individual believes that information held by the Division is inaccurate or incomplete, the Division will take steps to amend or correct the information.

6.4 The Division may refuse access if it reasonably believes that:

    6.4.1 A person’s health, safety or well being may be compromised by releasing the information; or

    6.4.2 Providing access would be unlawful or would prejudice a legal investigation.

6.5 Under circumstances other than 6.4.1 and 6.4.2 where information is withheld, the division will ensure that its practices are consistent with the provisions of NPP6.

6.6 If information is withheld under 6.4, the Division will provide an explanation to the individual as to the reasons why this was the case.

7. IDENTIFIERS

Except where circumstances allow (NPP7.2) TGPN will not use individuals’ identifiers such as Medicare numbers or identifiers of other agencies.

8. ANONYMITY

Where it is lawful and practicable to do so, TGPN will allow individuals to interact with the Division anonymously.

9. TRANSBORDER DATA FLOWS

TGPN will only transfer personal information about an individual to someone who is in a foreign country if

• The individual consents to the transfer; or
• The recipient is bound by legislation that is substantially similar to the NPP’s; or
• We are reasonably sure that the information will not be held, used or disclosed inconsistently with the NPP’s

10. SENSITIVE INFORMATION

• TGPN will only collect sensitive information (as defined under the Act) about an individual if:
• The individual consents; or
• The collection is required by law; or
• Such collection is consistent with the provisions of NPP10.

Adapted from  the Privacy Policy of Ballarat and District Division of General Practice.

Revised 1 February 2006

Page last modified: 29 Oct 2007


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© 2007 Townsville Division of General Practice Ltd trading as Townsville General Practice Network
ABN 87 063 397 231
3/106 Dalrymple Service Road, Townsville, Qld
PO Box 7780, GARBUTT BC, Qld 4814
Tel: +61 7 4725 8915 — Fax: +61 7 4725 8921
E-Mail: contact@tgpn.com.au
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