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Privacy Policy – Practice

Purpose


To ensure patients who receive care from the Saratoga Medical Centre are comfortable in entrusting their health information to the practice and sharing personal and sensitive information with our clinical staff.

This policy provides information to patients as to how their personal information (which includes their health information) is collected and used within Saratoga Medical Centre, and the circumstances in which we may disclose it to third parties.

This policy explains to patients how we collect and use their personal information in the Practice and in the event that their information needs to be shared with others outside the Practice.

Related Standards


RACGP Compliance indicators for the Australian Privacy Principles: an addendum to the computer and information security standards (Second edition).

Background and Rationale


The APPs provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APPs consist of 13 principle-based laws and apply equally to paper-based and digital environments. The APPs complement the long-standing general practice obligation to manage personal information in a regulated, open and transparent manner.

The privacy policy is put in place to ensure that our patients’ privacy is protected at all times and throughout various stages including consultations, referral for diagnostic tests and specialists, as well as billing. Saratoga Medical Centre uses document automation technologies so that only the relevant information is included in referral letters and any outgoing correspondence.

This policy will guide our staff in meeting these legal obligations. The policy is available to our patients upon request from the front desk and located on our website.

Practice Procedure


Saratoga Medical Centre will:

  • Provide a copy of this policy upon request.
  • Ensure staff and trained on handling patients documents to comply with the APPs and deal appropriately with inquiries or concerns.
  • Collect personal information for the primary purpose of managing a patient’s healthcare and for financial claims and payments.

Staff Responsibility


The staff will take reasonable steps to ensure patients 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.
  • The practice’s procedures for access and correction of information, and responding to complaints of information breaches, including by providing this policy.

Patient Consent


Saratoga Medical Centre will only interpret and apply a patient’s consent for the primary purpose for which it was provided. Staff must seek additional consent from the patient if the personal information collected may be used for any other purpose. Patients have the right to deal with us anonymously unless it is deemed necessary to identify the individual by law.

Collection of information


Saratoga Medical Centre will need to collect personal information as a provision of clinical services to a patient at the Practice. Collected personal information will include patients':

  • Names, addresses and contact details.
  • Medicare number (where available – for identification and claiming purposes).
  • Healthcare card or pension card.
  • DVA card.
  • Date of birth.
  • Medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors.

A patient’s personal information may be held at Saratoga Medical Centre in various forms:

  • As paper records – that are scanned to the patients records and original copies are shredded.
  • As electronic records.
  • As visual — x-rays, CT scans, videos and photos.
  • As audio recording.

The procedure for collecting personal information is set out below:

  1. Staff collect patients’ personal and demographic information via registration when patients present to the Practice for the first time. Patients are encouraged to pay attention to the collection statement attached to/within the form and information about the management of collected information and patient privacy. Patients are encouraged to update contact details by advising receptionists when attending the Practice or in writing.
  2. During the course of providing medical services, Saratoga Medical Centre’s healthcare practitioners will consequently collect further personal information.
  3. Personal information may also be collected from the patient’s guardian or responsible person (where practicable and necessary), or from any other involved healthcare specialists.

Saratoga Medical Centre holds all personal information securely, in electronic format, in protected information systems or in hard copy format in a secured environment. The staff take strict measures to ensure patient records are safe and secure, by applying timed locks on computers and asking all staff to lock their computers when leaving their desks. The Practice also follows a backup policy that protects the patients’ policy.

Use and Disclosure of Information


Personal information will only be used for the purpose of providing medical services and for claims and payments, unless otherwise consented to. Some disclosure may occur to third parties engaged by or for the Practice for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy. Saratoga Medical Centre will inform the patient where there is a statutory requirement to disclose certain personal information (for example, some diseases require mandatory notification).

Saratoga Medical Centre will not disclose personal information to any third party other than in the course of providing medical services, without full disclosure to the patient or the recipient, the reason for the information transfer and full consent from the patient. The Practice will not disclose personal information to anyone outside Australia without need and without patient consent.

Exceptions to disclose without patient consent are where the information is:

  • Required by law.
  • 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 a confidential dispute resolution process.

Saratoga Medical Centre will not use any personal information in relation to direct marketing to a patient without that patient’s express consent. Patients may opt-out of direct marketing at any time by notifying the practice in a letter or email.

Saratoga Medical Centre evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.

Electronic Health Record


Saratoga Medical Centre takes part in the transfer of patient information via the PCEHR (personally controlled electronic health record). The patient information contained in their PCEHR may be either uploaded or downloaded after seeking patient approval to do so. This benefits the patient by allowing easier access to medical information that might be vital to treating the patient particularly in a time sensitive situation like emergency departments and after hour care.

Saratoga Medical Centre has procedures in place to prevent any data breach to patient record and that all information is sent electronically and encrypted.
Patients have access to the information on their individual PCEHR and can ask clinical staff to edit and correct.
Further information about PCHER is available at the Practice,  please feel free to ask your doctor/nursing staff or reception for more information or a brochure.

Access, Corrections, and Privacy Concerns


Saratoga Medical Centre acknowledges patients may request access to their medical records. Patients are encouraged to make this request in writing, and the practice will respond within a reasonable time.
Saratoga Medical Centre will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, patients may be asked to verify the personal information held by Saratoga Medical Centre is correct and up to date. Patients may also request their information to be updated or corrected, and should make such requests in writing. The reception staff will always use the three patient identifier to validate patients’ information.

Complaints


Saratoga Medical Centre takes complaints and concerns about the privacy of patients’ personal information seriously. Patients should express any privacy concerns in writing.

Saratoga Medical Centre acknowledges the patients’ right to complain and is encouraged to address their concerns to practice staff. The staffnare trained to deal with all complains and feedback provided in a professional and timely manner. The patients’ concern should be acknowledged and addressed as soon as possible.

All complaints are reviewed by the business manager and appropriate measures are taken. The patient is contacted and actions are taken to prevent any breaches happening in the future.

Complaints can be delivered in writing to our business address shop1/10 village road Saratoga, NSW, 2251 marked to business manager (confidential).

If our complaint management process doesn’t resolve your matter of concern you may wish to contact the complaints commission office at 323 Castlereagh St, Haymarket NSW 2000 or call them on 02 9219 7444.

 

Privacy Policy – Website

This Privacy Policy applies to the Saratoga Medical Centre website. The Saratoga Medical Centre website is provided for information and educational purposes and may contain links to other sites. Once you enter another website (whether through an advertisement, service, or content link), be aware that Saratoga Medical Centre is not responsible for the privacy practices of such other sites. We encourage you to look for and review the privacy statements of each and every website that you visit.

We believe that transparency is the key to any healthy relationship. At Saratoga Medical Centre, we’re all about healthy. We appreciate that you are trusting us with information that is important to you, and we want to be transparent about how we use it. Here we describe the privacy practices for our website and you will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

Specifically, we’ll cover:

Information We Collect and How We Use Information


We collect the following personal information from you on the Saratoga Medical Centre website forms.

  • First and Last name
  • Email address
  • Phone number

By entering this information, you are providing personal information that will be used by Saratoga Medical Centre for the sole purpose of scheduling your appointment or returning your contact request.

If you choose to enroll as a subscriber of our website or subscribe to our blog, you will receive recurring practice newsletters, announcements and occasional promotional information via email. These emails will be of a general nature and will in no way disclose your unique health characteristics. At the time you subscribe or any time thereafter, you can choose to opt-out of receiving these emails from us.

To subscribe to our website, we need certain contact information, such as your name and email address. We may also store any provided demographic information (such as gender, birth date and address), but it is not required. You can unsubscribe from the newsletters by simply clicking on the “unsubscribe” link at the bottom of our emails; you will be immediately unsubscribed.

Passive Information We Collect

Like many other websites, we also automatically collect and log other non-identifying information when you interact with the Saratoga Medical Centre website:

Device data. We collect data from the device and application you use to access the Saratoga Medical Centre website, such as your Internet protocol (IP) addresses, operating system, device type, browser type and timestamps.

Usage data. We collect usage data that may include which Saratoga Medical Centre webpages you visit, what you click on, when you performed those actions, and so on. Emails sent by Saratoga Medical Centre collect information about who opened those emails and clicked on links in them. We do this to measure the performance of the Saratoga Medical Centre email messaging and to monitor and improve email deliverability and open rates.

How Information Is Shared


Except as set forth in this Privacy Policy or as specifically agreed to by you, Saratoga Medical Centre will not disclose any Personally Identifiable or Personal Health Information it gathers from you on our website. We will only release Personally Identifiable or Personal Health Information to third parties:

(i) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order.

(ii) in special cases, such as a physical threat to you or others. In the event that we are legally compelled to disclose your Personally Identifiable or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personal Information as described below.

Your Rights To Access and Control Your Personal Data


You may ask us at any time for information about any personal data we hold about you, or ask us to correct or delete that information. We will complete this request within 30 days of the initial request for information being received. Please complete this form to start this process. If you need further assistance regarding your rights, please contact our Data Protection Officer at dataprotection@vortala.com, and we will consider your request in accordance with applicable laws.

Data Retention


We keep the information we have about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, historical research and to prevent harm, including as described in the How We Use Information and How Information Is Shared sections.

Analytics and Advertising Services Provided by Others


  • Google Analytics. In addition, our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Further information may be obtained by visiting Google’s privacy policy.
  • AdWords Remarketing. We use Google AdWords Remarketing to advertise Saratoga Medical Centre across the Internet, in particular on the Google Display Network. We use a Google AdWords Remarketing code to log when website visitors view specific pages or take specific actions on our website. Google AdWords Remarketing can display ads to you based on what parts of the Saratoga Medical Centre website you have viewed by placing a cookie on your web browser. This does not in any way identify you or give access to your computer or mobile device.

    Google AdWords Remarketing allows us to tailor our online marketing to better suit your needs and only display ads that are relevant to you. If you do not wish to see ads from Saratoga Medical Centre you may opt out in the following ways:

    1. Opt out of Google’s use of cookies by visiting Google’s Ads settings.
    2. Opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
  • Facebook Remarketing. We use the Facebook pixel for occasional remarketing advertising. We do this to understand and deliver ads and make them more relevant to you. Facebook may use cookies, web beacons, and other storage technologies to collect or receive information on the Smile Marketing website and elsewhere on the internet and use that information to provide measurement services and target ads. If you do not wish to see ads from Smile Marketing on Facebook you may opt out by visiting Facebook’s Ad Preferences settings.

    To learn more about your choices and the steps you can take to protect your privacy on the internet visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/.

We use this information to conduct research and analysis to better understand how visitors are using the Saratoga Medical Centre website, so that we can improve our website experience. From time to time, Saratoga Medical Centre or it’s operations contractors acting on their behalf, conduct online research in order to gather feedback about our site through online or email surveys.

Participation in these surveys is completely voluntary and you may choose whether or not to participate and disclose information. Personally Identifiable Information collected through market research will only be used by Saratoga Medical Centre and its operations contractors and will never be given or sold to a third party.

Cookie Policy


We use cookies and other technologies to ensure that everyone who uses Saratoga Medical Centre website has the best possible experience. By continuing to visit or use our services, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy. You can find more information about cookies at: cookiesandyou.com.

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you.

Our cookie table lists some of the third party cookies on our sites. Please note that the names of cookies, pixels and other technologies may change over time. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

List of cookies used by Saratoga Medical Centre

Cookie Name Purpose Expiration Privacy
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New Patient Tracker. Collects device data such as your Internet protocol (IP) address, operating system, device type, browser type and timestamps. Persistent https://www.saratogamedicalcentre.com.au/info/privacy
Set By Or On Behalf Of Purpose Expiration Privacy
Google Analytics Website analytics cookie for visitor information and source. 2 years https://policies.google.com/privacy
responsivevoice.org Used by the content network, Cloudflare, to identify trusted web traffic. 1 year https://www.cloudflare.com/security-policy
Userway Accessibility widget remembers which accessibility features were enabled. Persistent https://userway.org/privacy
Hotjar Video Recording and Heatmap testing tool. 1 year https://www.hotjar.com/privacy
Wistia Embedding interactive videos on our website and measuring engagement. 1 year https://wistia.com/privacy/
MaxCDN Content Delivery Network. 1 year https://www.maxcdn.com/legal/
Facebook To enable the visitors to share the page in Facebook and stores page share count. Persistent https://www.facebook.com/about/privacy/
YouTube Embedding videos on our website and measuring engagement. 1 year https://policies.google.com/privacy
Formstack Provides embedded online form functionality. 1 year https://www.formstack.com/privacy

Our Policies for Children


We are committed to protecting the privacy of children. Neither Saratoga Medical Centre nor any of its services are designed or intended to attract children under the age of 13.

Information Security


We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data. This includes using Transport Layer Security (“TLS”) to encrypt many of our Services. No method of transmitting or storing data is completely secure, however, if you have a security-related concern, please contact customer support at dataprotection@vortala.com.

Our International Operations and Data Transfers


Our website hosting company, Vortala, operate internationally and transfer information to the United States for the purposes described in this policy. They rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US and EU Commission approved model contractual clauses, which require certain privacy and security protections.

Vortala complies with the Privacy Shield principles regarding the collection, use, sharing, and retention of personal information as described in Privacy Shield certifications. Learn more about Privacy Shield here.

Changes to This Policy


We will inform you if a material change to the Privacy Policy is made that involves the use of your Personally Identifiable Information. Your continued use of the Saratoga Medical Centre site will indicate acceptance of the changes. Please exit the site immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Who We Are and How To Contact Us


If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us.

Saratoga Medical Centre
1/10 Village Road
Saratoga New South Wales 2251
(02) 4363 1066


This Privacy Policy does not protect you when you send content, questions or ideas to Saratoga Medical Centre via email. If you want to keep them private or proprietary, do not send them in an email. We try to answer every email within 48 business hours, but are not always able to do so.

Last Updated: May 21, 2018