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Woodville Road Medical & Dental Privacy Policy

Current as of: 1/06/2020

Introduction

This privacy policy is to provide information to you, our patient, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties. 

Why and when your consent is necessary 

When you register as a patient of our practice, you provide consent for our GPs 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 (eg staff training). 

What personal information do we collect? 

The information we will collect about you includes your:

  • 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 may collect your personal information in several different ways.

  1. When you make your first appointment our practice staff will collect your personal and demographic information via your registration. 
  2. During the course of providing medical services, we may collect further personal information. 
  3. We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media. 
  4. 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 Veterans’ Affairs (as necessary). 

When, why and with whom do we share your personal information?

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 (eg 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 (eg some diseases require mandatory notification)
  • during the course of providing medical services, through eTP, My Health Record (eg via Shared Health Summary, Event Summary).

Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.

Our practice may use your personal information for marketing any of our goods or services directly to you without your express consent. If you do not consent, you may opt out of direct marketing at any time by notifying our practice in writing. 

The practice may at its discretion, share personal information to 3rd parties only in the event where the practice deems it necessary to obtain better health outcomes for the patients. 

How do we store and protect your personal information?

Your personal information may be stored at our practice in various forms. Critical medical information such as paper records, electronic records, visual records (X-rays, CT scans, videos and photos), audio recordings. will only be stored digitally on our secure servers located within our practice.

Our practice stores all personal information securely. All electronic data are stored within protected information systems. Passwords are used by all members of staff. Woodville Rd Medical and Dental will try to protect your information; however breaches from inside/outside are not the liability of Woodville Rd Medical and Dental. By accepting treatment of any of our practitioners for any reason, means you accept this risk and potential of loss of privacy and information, as per initial patient form.

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.

Our practice acknowledges patients may request access to their medical records. We require you to put this request in writing and our practice will respond within a reasonable time. The process to handover critical documents of a patient may take upto 30 days and may incur a fee as well.

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 that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to [email protected]

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. Any such complaints can be made via our email( [email protected]) or through the phone((02) 9681 7886)

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 on 1300 363 992

Privacy and our website 

The following statement is added onto the patient agreement, as an acknowledgement of the use of personal data :-”Personal information is collected in order to provide you with certain content, products and services and, unless you opt-out or unsubscribe, contact you in the future with information on products and services and to provide you with marketing materials via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) or any other form of electronic, emerging, digital or conventional communications channel whether existing now or in the future.

We may also collect and use passively collected anonymous information or personal information from various third party sources and may combine this anonymous information or personal information with other personal information collected from you, to provide better service to Website users, customise a Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve its Websites for your use.”

Woodville Rd Medical and Dental will try to protect your information; however breaches from inside/outside are not the liability of Woodville Rd Medical and Dental. By accepting treatment of any of our practitioners for any reason, means you accept this risk and potential of loss of privacy and information, as per initial patient form.

Policy review statement

This policy will be reviewed on a biannual basis in accordance with any changes that may occur. Patients will be informed via email or sms  of any major changes within the practice.

Disclaimer

The Privacy policy template for general practices is intended for use as a guide of a general nature only and may or may not be relevant to particular practices or circumstances. The Royal Australian College of General Practitioners (RACGP) has used its best endeavours to ensure the template is adapted for general practice to address current and anticipated future privacy requirements. Persons adopting or implementing its procedures or recommendations should exercise their own independent skill or judgement, or seek appropriate professional advice. While the template is directed to general practice, it does not ensure compliance with any privacy laws, and cannot of itself guarantee discharge of the duty of care owed to patients. Accordingly, the RACGP disclaims all liability (including negligence) to any users of the information contained in this template for any loss or damage (consequential or otherwise), cost or expense incurred or arising by reason of reliance on the template in any manner.

Woodville Rd Medical and Dental Centre Internet and Email policy 

Current as of: 19/10/2020

Woodville Rd Medical and Dental recognises the practice team requires access to email and the internet to assist in the efficient and safe delivery of healthcare services to our patients.Woodville Rd Medical and Dental supports the right of staff to have access to limited personal use of the internet and email communications in the workplace using the devices and networks provided by the practice.

Purpose and objectives

This policy sets out guidelines for acceptable use of the internet and email by the practice team, contractors and other staff of Woodville Rd Medical and Dental .  Internet and email is provided primarily to assist the team carry out their duties of employment. 

Scope

This internet and email policy applies to the practice team, contractors and other staff of Woodville Rd Medical and Dental  who access the internet and email on practice owned devices, including, but not limited to desk phones, smartphones, tablets, laptops, desktop computers, iPads and other tablet devices to perform their work.

Use of the internet by the practice team, contractors and other staff is permitted and encouraged where this supports the goals and objectives of Woodville Rd Medical and Dental. Access to the internet is a privilege and the practice team, contractors and other staff must adhere to this policy.

Violation of these policies could result in

  •         disciplinary and/or legal action
  •         termination of employment
  •         the practice team, contractors and other staff being held personally liable for damages caused by any violations of this policy

All employees are required to confirm they have understood and agree to abide by this email and internet policy verbally and on the start of their contract. 

Policy content

The practice team, contractors and other staff may use the internet and email access provided by Woodville Rd Medical and Dental  for: 

  • any work and work-related purposes
  • limited personal use
  • more extended personal use under specific circumstances (see below)

Limited personal use of email and internet

 Limited personal use is permitted where it:

  • infrequent and brief use
  • does not interfere with the duties of the practice team, contractors and other staff
  • does not interfere with the operation of your general practice
  • does not compromise the security of your general practice
  • does not impact on your general practice electronic storage capacity
  • does not decrease your general practice network performance (eg large email attachments can decrease system performance and potentially cause system outages) 
  • does not incur any additional expense for your general practice
  • does not violate any legislation
  • does not compromise any confidentiality requirements of your general practice

Examples of what could be considered reasonable personal use could be included in your policy and could include:

  • sending a brief personal email, similar to making a brief personal phone call

Unacceptable internet and email use

The practice team, contractors and other staff may not use internet or email access provided by Woodville Rd Medical and Dental  to:

  • creating or exchanging messages that are offensive, harassing, obscene or threatening
  • visiting web sites containing objectionable (including pornographic) or criminal material
  • exchanging any confidential or sensitive information held by your general practice
  • creating, storing or exchanging information in violation of copyright laws
  • using internet-enabled activities such as gambling, gaming, conducting a business or conducting illegal activities
  • creating or exchanging advertisements, solicitations, chain letters and other unsolicited or bulk email
  • playing electronic or online games in work time.

Definitions

Policy review statement

This policy will be reviewed regularly to ensure it reflects the current processes and procedures ofWoodville Rd Medical and Dental  and current legislation requirements.

You can set a specific review date for your policies 19/10/2021

Disclaimer

The policy template for general practices is intended for use as a guide of a general nature only and may or may not be relevant to particular practices or circumstances. The Royal Australian College of General Practitioners (RACGP) has used its best endeavours to ensure the template is adapted for general practice to address current and anticipated future privacy requirements. Persons adopting or implementing its procedures or recommendations should exercise their own independent skill or judgement, or seek appropriate professional advice. While the template is directed to general practice, it does not ensure compliance with any privacy laws, and cannot of itself guarantee discharge of the duty of care owed to patients. Accordingly, the RACGP disclaims all liability (including negligence) to any users of the information contained in this template for any loss or damage (consequential or otherwise), cost or expense incurred or arising by reason of reliance on the template in any manner.

Woodville Rd Medical and Dental Centre Social Media policy 

Current as of: 3/12/2020

Name of social media officer: [Dr Saideepan Mohanadas | Practice Manager]

Introduction

This policy provides guidance for members of the practice on using social media internally and externally. The policy helps identify and mitigate risks associated with social media use.

Definition

For the purposes of this policy, ‘social media’ is online social networks used to disseminate information through online interaction.

Purpose

Regardless of whether social media is used for business-related activity or for personal reasons, the following policy requirements apply to all GPs and practice staff of the practice. GPs and practice staff are legally responsible for their online activities, and if found to be in breach of this policy could result in:

  •         disciplinary and/or legal action
  •         termination of employment
  •         the practice team, contractors and other staff being held personally liable for damages caused by any violations of this policy

Use of practice social media accounts

The practice will appoint a staff member as a social media officer responsible for managing and monitoring the practice’s social media accounts. All posts on the practice’s social media website must be approved by this staff member. The practice reserves the right to remove any content at its own discretion.

Staff conduct on social media

When using the practice’s social media, practice staff will not:

  •   post any material that

-   is unlawful, threatening, defamatory, pornographic, inflammatory, menacing or offensive

-   infringes or breaches another person’s rights (including intellectual property rights) or privacy, or misuses the practice’s or another person’s confidential information (eg do not submit confidential information relating to our patients, personal information of staff, or information concerning the practice’s business operations that have not been made public)

-   is materially damaging or could be materially damaging to the practice’s reputation or image, or another individual

-   is in breach of any of the practice’s policies or procedures

  •   use social media to send unsolicited commercial electronic messages, or solicit other users to buy or sell products or services or donate money
  •   impersonate another person or entity (eg by pretending to be someone else or another practice employee or other participant when you submit a contribution to social media) or by using another’s registration identifier without permission
  •       tamper with, hinder the operation of, or make unauthorised changes to the social media sites
  •       knowingly transmit any virus or other disabling feature to or via the practice’s social media account, or use in any email to a third party, or the social media site
  •       attempt to do or permit another person to do any of these things

-   claim or imply that you are speaking on the practice’s behalf, unless you are authorised to do so

-   disclose any information that is confidential or proprietary to the practice, or to any third party that has disclosed information to the practice

  •       be defamatory, harassing or in violation of any other applicable law
  •       include confidential or copyrighted information (eg music, videos, text belonging to third parties)
  •       violate any other applicable policy of the practice.

Monitoring social media sites

The practice’s social media channels are part of our customer service and should be monitored and dealt with regularly. Response times for social media can be indefinite, however we will attempt to reply within 30 days on a particular response. Complaints are taken seriously, and when brought to our attention are attempted to have immediate action. All Platforms are updated ASAP, but within reason. 

Testimonials

The practice complies with AHPRA national law and takes reasonable steps to remove testimonials that advertise their health services (which may include comments about the practitioners themselves). The practice is not responsible for removing (or trying to have removed) unsolicited testimonials published on a third-party website or in social media accounts over which they do not have control.

Personal social media use

Staff are free to personally engage in social media outside of work hours, as long as their actions do not have the potential to bring the practice into disrepute. Employees may not represent personal views expressed as those of this practice.

Any social media posts by staff on their personal social media platforms must not reveal confidential information about the practice or a person who uses the practice (eg staff should not post information relating to patients or other staff, or information concerning the practice’s business operations that have not been made public).

Staff should respect copyright, privacy, fair use, financial disclosure and other applicable laws when publishing on social media platforms.

Woodville Rd Medical and Dental require staff to include a disclaimer if they identify themselves as a practice employee on any social media platforms, when in discussion about the medical centre. ‘The views expressed in this post are mine and do not reflect the views of the practice/business/committees/boards of which I am a member’.

Breach of policy

All social media activities must be in line with this policy.

Policy review statement

The policy will be reviewed regularly to ensure it is up to date with changes in social media or relevant legislation. We update this document which staff needs to check on a regular basis (every 3 months at a minimum), when changes are made. 

 

 Woodville Rd Medical and Dental Centre Debt Collection policy - From PRO COLLECT

All Collections are outsourced to PRO COLLECT, and their collection policies are outlined below. By Signing the new patient form you agreed to the conditions below. All collection fees and legal fees are payable by the debtor.

CASH FLOW MANAGEMENT SERVICES (under $1000)

This system is ideal for managing the collection of smaller debts (of usually under $1,000.00), where legal action may not be considered a viable alternative.

It is a low cost and effective way of communicating with your slow paying debtors and prompting them to bring their accounts up to date.

HOW WE OPERATE

The collection procedure is as follows:

Day 1 – Soft Reminder:

Requests the payment of your account in a firm but friendly manner.

Day 14- Second Reminder:

Informs the debtor this is the second occasion we have needed to write to them. In a definitely firmer tone than the first letter, we require that your account is paid by a specific deadline and further advises the debtor that instructions for legal action will be sought should payment not be made.

Day 28 – 41 –Telephone Contact:

In the absence of a satisfactory response to the above letters and subject to you holding telephone details for your debtor, we will endeavour to make personal contact with your debtor and require immediate payment of your account. We will inform your debtor this is an alternative to further action that may include the commencement of legal proceedings. Telephone contact includes both phone calls and SMS communication.

Where we are unable to induce the lump sum payment of your full debt, we will negotiate a satisfactory payment arrangement on your behalf and will continue to monitor this plan until the debt is paid in full. Where an arrangement is not maintained, we will again contact the debtor to prompt further instalments.

 COSTS

Each of the below options carries a one-off account loading fee of $30.00 (plus GST) where 10 or less debts are first received for collection on the first occasion. This fee does not apply to subsequent instructions for collection.

Option 1: Pay a fee for the letters, emails, SMS and all necessary telephone attendances upon your debtor, of only $60.00 (plus GST) per account.

Option 2: Rather than paying a fee for each account provided for collection, we will pursue collection of your debts on a no result, no cost basis, for a commission of 30% (or a minimum commission of $30.00 on the first payment) which is solely resultant on the recovery of monies from each of your debtors.

Should you not confirm your selection to use either Option 1 or Option 2 at the time of providing your debt(s) for collection, we will action your accounts in accordance with Option 2.

No other fees are payable for either Option 1 or Option 2 above, unless the account is referred to the below Debt Collection Services system, or the account is collected as a “Bad Debt” as set out below.

Discounts are available for bulk lodgements of accounts at any one time.

 Day 42

Accounts remaining unpaid after the above “How We Operate” courses of action above are genuine “won’t pays/ refuse to pay”, or are debtors who are un-contactable, due to having moved their address and/or changed telephone numbers.

 At this point those accounts that are “won’t pays/ refuse to pay” or un-contactable, are automatically transferred for more concentrated collection at our cost. Where your debtor has left the address, at our expense we will conduct basic enquiries for your debtor’s location. If as a result of tracing your debtor’s whereabouts or our concentrated collection action we are able to induce payment, we will recover your debt less a commission on collection only, of 30%.              

For accounts that still refuse to pay after the above concentrated action, you can elect to move these to our Debt Collection Services system, as discussed below. We will contact you at this point for your instructions, or alternatively, when initially providing your debts for collection, you can advise us to automatically pursue the Debt Collection Services option, should the Cash Flow Management system not induce payment.                                                                                                                        

As the Debt Collection Services option involves legal action and the outlay of recoverable Court fees, even though all Court fees are added to the amount your debtor is liable to pay, this option is usually only recommended for debts over $1000.00, or where you hold details of your debtor’s employment, which can assist in forcing early payment of your debt via a Wages Garnishee Order

A commission is charged on the collection of your debt and any interest we have since been able to add on your behalf. All recoverable Court fees are reimbursed to you in full out of the monies collected off your debtor, in priority to collection of the debt itself.

 Should you desire further information on our Debt Collection Services product and if not already additionally attached to our email to you, upon request we would be pleased to provide our full proposal to you.

STATEMENTS

Statements and Tax Invoices are forwarded to you via email at each end of month.

Each statement will either itemise the direct deposit details of funds remitted from our Trust account to your nominated account, after deduction of any costs or commission incurred and not previously reimbursed by you, or alternatively may request payment of disbursements outlaid on your behalf. 

All costs and commission (other than court filing fees and exempt government fees) are subject to GST. 

All debit Statements are payable within 14 days of issue to you.

DEBT COLLECTION SERVICES (over $1000)

No matter which of our debt collection services you choose, unlike other collection agencies you do not pay for;

*      Membership or annual subscription fees

*      Account loading fees or administration fees

         *      Fees for replying to correspondence or telephone calls

         *      Solicitor’s Professional fees incurred on the issue of most legal proceedings

HOW WE OPERATE

Unless otherwise instructed by you, upon receipt of your account for collection, we will immediately issue a letter of demand to your debtor, for payment within seven (7) days.

Where we consider it beneficial to make direct contact with your debtor, in order to emphasise the urgency of the situation and entice payment, then we will do so by telephone or in person. We find this personal touch will often produce positive results, which would otherwise not be obtained in the early stages of collection.

Automatically upon expiry of the letter of demand, where no payment has been received or negotiated with your debtor and after conducting any necessary business name or Company searches, your acceptance of the terms of this proposal via our Debt Collection Instructions Sheet, authorise us to immediately engage Solicitors on your behalf, to prepare and file a Summons into Court for issue and prompt service on your debtor.

Wherever possible, we will add interest to the amount owed to you. This will either occur as a result of the terms of your contract with the debtor, or in the absence of such terms, the Courts allow interest  (currently a minimum of 5.5% p.a.) to accrue on any debt of $1,000.00 or more, from the date it fell due until the date it is eventually paid.

Should we be able to add sufficient interest to your claim, this may recover more for you than the amount of our commission. This means your debt will be collected for free.

Once your Summons is issued by the Court, we will quickly attend to service, noting at that time any apparent assets, details of employment or other means of recovering your debt, and when possible, once again taking this opportunity to seek payment.

Of course, should you wish us to waive the letter of demand and have a Summons immediately issued, then these instructions will be efficiently carried out on your behalf.

In the absence of any satisfactory response within the statutory 28 days after service of the Summons, on your behalf we will further instruct Solicitors to file for Judgement to be granted by the Court in your favour, include any accrued interest and concurrently issue and pursue all possible and appropriate enforcement proceedings that we consider viable to maximise recovery of your debt, via the Court system in the shortest possible time.

Where the debtor makes a payment direct to you after the account is provided for collection, you must immediately advise us of this payment to avoid the possibility of unnecessary further costs being incurred.

Naturally, our funding of disbursements does not extend to actions in the Supreme or Federal Court jurisdictions, nor beyond the point of a matter becoming formally disputed and therefore requiring the intervention of solicitors to act directly on your behalf, until verdict or settlement is obtained in your favour, at which point we will re-activate collection of the debt or account to you for our costs on monies recovered.

Should you withdraw an account from collection (which includes failing to provide your instructions for the further prosecution of your debt(s) within 30 days of our written request for you to do so), we will be entitled to charge you commission (at the rate set out under the below “Costs” section of this proposal) on the full debt and any accrued interest.

COSTS

Costs payable by you are limited to those disbursements actually incurred by us in lodging business name or Company searches, the preparation (if your debtor is interstate), filing, service or re-service at a new address, of your Court documents, our attendance at an Examination or Instalment Order Hearing, our agents attendance to filing some interstate court documents or time actually spent in location of your debtors, should they vacate their address. These costs only come into existence should legal action be necessary. A list of the majority of such costs for New South Wales is attached to this submission.

Solicitors’ professional fees which are included as part of the amount claimed in the issue from court of most legal process, are added to and are legally recoverable from your debtor. In New South Wales, Victoria, Queensland and Western Australia we fund these fees on your behalf and then deduct them from the first payments(s) recovered from your debtor. They are only ever payable by you should you withdraw an account from collection or fail to provide your instructions, when requested, for the further prosecution of your debt(s).

All court filing fees and the first court recoverable service fee as reimbursed by you, are added to the amount claimed and are legally recoverable from your debtor. They are fully reimbursed to you after collection of any Solicitors professional fees.

Once your debt is received by us, a commission of 15% on the first $10,000.00 and 10% on the balance of any one debt, is charged on all monies recovered (or compromise, contra arrangement, return of goods, or in the event the debt is defended and then paid) against the original debt and any interest we have since been able to accrue on your behalf. An additional 5% commission would be added to any debts over 18 months of age due to the additional complexity of collecting such accounts.

No commission is payable on the collection of Solicitors professional fees.

No commission is payable on the collection of your recoverable Court filing fees, service fees or other disbursements.

 

STATEMENTS

Statements and Tax Invoices are forwarded to you via email at each end of month.

Each statement will either itemise the direct deposit details of funds remitted from our Trust account to your nominated account, after deduction of any costs or commission incurred and not previously reimbursed by you, or alternatively may request payment of disbursements outlaid on your behalf.

All costs and commission (other than court filing fees and exempt government fees) are subject to GST.

All debit Statements are payable within 14 days of issue to you.

It is at the discretion of Woodville Rd Medical and Dental to pursue debts owed. The third party company that debts are outsourced to may change, and may not be updated in this policy. The policy outlined above may not be current. By signing the patient declaration form, you agree to indemnify us about any lack update in this document or an inaccuracies in the information above.

Woodville Rd Medical and Dental Centre E-waste policy 

Current as of: 19/10/2020

Introduction

This policy provides information on e-waste management within our practice.

Woodville Rd Medical and Dental is committed to addressing the following issues in relation to e-waste in the practice:

Promoting awareness

We will inform and motivate all of our staff and encourage them to play an active role in Woodville Rd Medical and Dental commitment to its e-waste disposal/environmental policy.

Securely and safely erasing data

Prior to discarding electronic equipment, we will ensure all records stored on this equipment are removed and destroyed in such a way as to render them unreadable and leave them in a form which they cannot be reconstructed in whole or in part. We will use Mednology to complete this process.

Reusing and recycling e-waste

We will donate any redundant electronic equipment to Mednolog. If electronic equipment is beyond repair, we will utilise the services of Mednology to recycle this equipment. We will favour suppliers and contractors that are reputable and adopt best environmental practices.

Waste management

We will continue to promote, develop and implement waste prevention, reduction, reuse and recycling on-site in a systematic and cost effective manner. We will use appropriately regulated waste management contractors to ensure safe management of hazardous and non-hazardous waste sent off-site in accordance with best environmental practice.