Does Your Privacy Policy Measure Up?
09 Jan 2015
- are clearly expressed
- are up to date
- cover the required topics
- reflect the use of Personally Controlled Electronic Health Records (PCEHR), where relevant.
Clear expression
- Think about your audience and word it accordingly.
- Keep it simple and easy to read.
- Use the terms “you” and “us/we”, rather than “patient” and “the practice”.
- Don’t just repeat the words in the Australian Privacy Principles (APPs) – make it specific to your practice.
- Arrange information in a way that makes sense for your patients.
- Be as specific as possible.
- Provide more detail about areas of information handling that patients are most concerned about, are unaware of, won’t reasonably expect or may not understand easily.
- Seek input from your staff.
- Contact your medical indemnity insurer.
- Test it out on readers – it should be able to be easily read and understood by a 14-year-old.
Up to date
Changes to Australian privacy law came into effect on 14 March 2014, with the APPs replacing the National Privacy Principles. Your policy must reflect the current law.
A summary of the APPs is available in the OAIC’s Privacy Fact Sheet 17.3
Your policy must outline how your practice currently deals with personal information – if procedures change, your policy should also change accordingly. Regularly review and update your policy. Include the date and version number on the document.
Required topics
- the kinds of information collected or held
- how it is collected
- for what purposes it is collected, held or used
- disclosure to any other persons or agencies – identity of agencies, what is disclosed, for what purpose(s)
- the process for an individual to access the information
- where access is withheld, why and how the individual is notified
- the consent process for collection of information
- situations where consent is not required, e.g. an emergency
- the process for individuals to complain about a breach of privacy
- whether information is disclosed to overseas recipients and to what countries.
Use of Personally Controlled Electronic Health Records (PCEHR)
- what information you add to and access from patients’ eHealth record and what you do with the information
- procedures to ensure compliance with the Personally Controlled Electronic Health Records Act 2012
- how an eHealth record may be used in an emergency situation.
References
- The Privacy Act 1988 (Cth).
- Office of the Australian Information Commissioner. Guide to Developing an APP Privacy Policy. Canberra: OIC, 2014.
- Privacy Fact Sheet 17: Australian Privacy Principles. 2014. Available at: oaic.gov.au/privacy/privacy- resources/privacy-fact-sheets/other/privacy-fact- sheet-17-australian-privacy-principles.
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