FAMILY HEALTH CLINIC PRIVACY POLICY.

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.

[Information can also be collected through electronic transfer of prescriptions (eTP), My Health Record, eg via Shared Health Summary, Event Summary.
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.

1. 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 (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 (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 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.
We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
Our practice will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.
Our practice may use your personal information to improve the quality of the services we offer to our patients through research and analysis of our patient data.
We may provide de-identified data to other organisations to improve population health outcomes. The information is secure, patients cannot be identified, and the information is stored within Australia. You can let our reception staff know if you do not want your information included.

How do we store and protect your personal information?
Your personal information may be stored at our practice in various forms, most of which is electronic records, but may include paper records, and photos if appropriate in your clinical records.
Our practice stores all personal information securely in an electronic format, in protected information systems. We use passwords, secure cabinets, and confidentiality agreements for staff and contractors.

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 via letter or email, and our practice will respond within a reasonable time which may be up to 30 days from date request is received. There will be a minimum administrative fee of $50 for release of these records, but this may vary based on the amount of information and size of files requested.
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 the practice manager via email at [email protected] or in person at the clinic.

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. Kindly send all complaints in writing, including details of the complaint in writing to the practice manager via email at [email protected] or via mail addressed to the Practice Manager, Family Health Clinic Gatton, 25-27 Railway Street, Gatton, Qld 4343. We will try to respond within 30 days from date of receipt.
 
If you do not receive a response or still have concerns make an appointment to discuss in person with the Practice Manager or the Practice Principal and should the outcome, not be to your satisfaction then you may 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.
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Privacy and our website
Our Clinic has a Facebook page and uses Google reviews, we request that you do not share any personal health information via these social media platforms.
We also use online forms via a third-party service provider – “Hotdocs Online”. HotDocs confirms that any personal information provided is secure and that your information is never to any third party at any time.
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OUR Communication Policy:

1. Purpose
Family Health Clinic Gatton is committed to providing respectful, timely, confidential, and effective communication with all patients and carers. This policy outlines the standards and procedures for communication between the practice and patients to ensure:

• Safe and high-quality patient care
• Continuity of care
• Protection of patient privacy and confidentiality
• Compliance with RACGP Standards
• Appropriate use of telephone, electronic, and written communication
• Clear expectations for staff and patients

This policy supports the RACGP Standards for General Practices, including:

• C2 – Partnering with Patients
• C3 – Business Systems
• C5 – Clinical Governance
• GP1 – Communication and Patient Health Information

2. Scope
This policy applies to:

• All doctors
• Nurses
• Reception and administration staff
• Allied health providers
• Contractors and students
• Patients and carers interacting with the practice

The policy covers all forms of communication including:

• Face-to-face communication
• Telephone communication
• SMS messaging
• Email communication
• Website and online forms
• Recall and reminder systems
• Telehealth consultations
• Social media interactions
• Written correspondence

3. Principles of Communication
Family Health Clinic Gatton will ensure communication is:

• Respectful and culturally sensitive
• Patient-centred
• Confidential and secure
• Clear and understandable
• Timely and appropriate
• Accessible to patients with diverse needs
• Documented where clinically relevant

The practice recognises the importance of effective communication with:

• Aboriginal and Torres Strait Islander peoples
• Patients from culturally and linguistically diverse backgrounds
• Elderly patients
• Patients with disabilities
• Patients with low health literacy

Interpreter services and support persons may be used where appropriate.

4. Reception and Front Desk Communication
Reception staff are expected to:

• Greet patients courteously and professionally
• Maintain patient confidentiality at all times
• Speak discreetly when discussing personal information
• Confirm patient identity using approved identifiers
• Escalate concerns or complaints appropriately
• Avoid providing clinical advice beyond their scope
• Communicate delays and appointment issues respectfully

Reception staff must not:

• Discuss patient information in public areas
• Provide medical opinions or diagnoses
• Release confidential information without appropriate consent

5. Telephone Communication Policy

5.1 Incoming Calls
The practice aims to answer telephone calls promptly and professionally.
Staff will:

• Identify the clinic and themselves
• Confirm patient identity before discussing information
• Document clinically relevant messages in the patient record
• Forward urgent concerns to a clinician immediately

5.2 Telephone Advice
Administrative staff must not provide clinical advice.
If a patient requires clinical advice:

• The call will be referred to a nurse or GP
• The patient may be offered an appointment or telehealth consultation
• Emergency symptoms will be directed to 000 or the nearest emergency department

Examples of urgent symptoms include:

• Chest pain
• Severe shortness of breath
• Stroke symptoms
• Severe bleeding
• Altered consciousness

5.3 Return Calls from Clinicians
Doctors and nurses may return patient calls where clinically appropriate.
All clinically significant telephone communication must be documented in the patient health record, including:

• Date and time
• Nature of discussion
• Advice provided
• Follow-up arrangements

6. SMS Communication Policy
The practice may use SMS messaging for:

• Appointment reminders
• Recall and reminder notifications
• Health promotion messages
• Follow-up instructions
• Practice announcements

Patients consent to SMS communication upon registration unless they opt out.
SMS messages:

• Must not contain highly sensitive clinical information
• Should be concise and professional
• Must include clinic identification
• Must protect patient confidentiality where possible

Examples:

• “Reminder: You have an appointment at Family Health Clinic Gatton tomorrow at 10:30am.”
• “Please contact Family Health Clinic Gatton regarding your recent test results.”

The practice acknowledges SMS is not a fully secure communication method.

7. Email Communication Policy
Email communication may be used for:

• Administrative correspondence
• Forms and documents
• Non-urgent communication
• Patient education material

The practice will not use email for:

• Emergency communication
• Urgent clinical matters
• Time-critical advice

Patients using email communication are advised:

• Email may not be fully secure
• Response times may vary
• Urgent concerns should be directed via telephone or emergency services

Emails containing clinical information should:

• Be sent only with patient consent
• Use secure systems where available
• Be documented in the patient record where clinically relevant

The practice aims to respond to non-urgent emails within 2 business days.

8. Telehealth Communication

Telehealth consultations may be provided in accordance with current Medicare and professional guidelines.
The practice will:

• Verify patient identity
• Obtain verbal consent for telehealth
• Ensure privacy and confidentiality
• Document consultations appropriately
• Escalate to face-to-face review where clinically indicated

Patients are encouraged to:

• Participate from a private location
• Ensure reliable phone or internet access
• Provide updated contact details

9. Results Communication Policy
9.1 Test ResultsPatients are advised that:

• They are responsible for following up their results
• Not all results will be communicated automatically
• An appointment may be required to discuss results

Doctors determine:

• The urgency of follow-up
• Appropriate communication methods
• Recall requirements

Reception staff must not interpret results.

9.2 Critical Results
Urgent or clinically significant results are managed according to the practice’s Results Management Policy.
The practice will make reasonable attempts to contact patients regarding urgent results.
Attempts may include:

• Telephone calls
• SMS reminders
• Registered letters
• Contacting emergency contacts where appropriate
• Welfare checks in extreme circumstances

All attempts are documented.

10. Recall and Reminder Communication
The practice operates a recall and reminder system for:

• Preventive health activities
• Abnormal test results
• Chronic disease reviews
• Immunisations
• Cervical screening
• Care plans

Patients may receive:

• SMS reminders
• Telephone calls
• Letters
• Electronic reminders

Patients may opt out of reminder systems, except where required for significant clinical safety concerns.

11. Communication with Carers and Family Members
Patient information will only be disclosed:

• With patient consent
• Where legally authorised
• Where clinically necessary and permitted by law

Staff must verify:

• Identity of the person requesting information
• Scope of consent

Special consideration applies to:

• Minors
• Patients lacking decision-making capacity
• Guardianship arrangements
• Enduring power of attorney documentation

12. Interpreter and Accessibility Services
The practice supports equitable communication access.
Interpreter services may be arranged for patients with limited English proficiency.
Where appropriate, the practice may utilise:

• Professional interpreters
• National Translating and Interpreting Service (TIS)
• Hearing assistance services
• Written communication aids

Family members should generally not be used as interpreters for sensitive clinical matters unless requested by the patient and clinically appropriate.

13. Social Media and Online Communication
The practice’s social media platforms are intended for general information and community engagement only.
The practice will not:

• Provide personal medical advice via social media
• Discuss confidential patient matters online
• Engage in public discussions regarding patient complaints

Patients are advised not to post personal medical information on public platforms.
Online reviews and feedback are monitored professionally and respectfully.

14. Website CommunicationThe practice website may include:

• Clinic hours
• Appointment booking information
• Health education resources
• Practice policies
• Contact information

Website forms must not be used for emergencies.
Patients experiencing emergencies are instructed to call 000.

15. Privacy and Confidentiality
All communication must comply with:

• Privacy Act 1988 (Cth)
• Australian Privacy Principles
• RACGP confidentiality requirements
• Relevant Queensland legislation

Patient information will only be accessed by authorised personnel.
Staff are required to:

• Maintain confidentiality during all communications
• Secure electronic devices and records
• Use passwords and secure systems
• Avoid discussing patient information in public areas

Confidentiality breaches may result in disciplinary action.

16. Communication of Fees and Billing
Patients will be informed about:

• Consultation fees
• Billing arrangements
• Cancellation policies
• Out-of-pocket costs where possible

Fee information should be:

• Clearly displayed
• Explained respectfully
• Consistent and transparent

17. Complaints and Feedback Communication
Patients are encouraged to provide feedback.
Feedback may be provided:

• In person
• By telephone
• Via email
• Through written forms
• Via the practice website

Complaints will be:

• Acknowledged respectfully
• Managed confidentially
• Investigated appropriately
• Responded to within reasonable timeframes

Patients may also contact:

• Office of the Health Ombudsman (Queensland)
• Australian Health Practitioner Regulation Agency (AHPRA)

where appropriate.

18. Staff Training and Responsibilities
All staff receive orientation and ongoing training regarding:

• Communication standards
• Privacy and confidentiality
• Cultural awareness
• Telephone etiquette
• Managing difficult conversations
• De-escalation techniques
• Documentation requirements

Managers are responsible for monitoring compliance with this policy.

19. Documentation Requirements
Clinically relevant communications must be documented in the patient health record.
Documentation should include:

• Date and time
• Person involved
• Summary of communication
• Advice or information provided
• Follow-up actions

Examples include:

• Telephone advice
• Significant emails
• Test result discussions
• Telehealth interactions
• Complaints relating to care

20. Review and Continuous Improvement
This policy will be reviewed:

• Annually
• Following incidents or complaints
• Following legislative or accreditation changes
• As part of quality improvement activities

Patient feedback and incident reports may inform improvements to communication systems.