How we collect your information

We primarily collect information about you through correspondence we engage in with you, for example, through new patient forms, telephone conversations and emails, and information from sources that are publicly available such as websites and telephone books.  Wherever practicable, we will only collect information from you personally. However, we may also receive information from your employer or health fund (where relevant), and may need to collect information from other sources such as your referring doctor, other treating specialists, radiologists, pathologists, hospitals and other health care providers, as it relates to your care. In emergency situations, we may also need to collect information from your relatives or friends.

Kinds of information that we hold about you

We only hold information about you if it is relevant to providing the services and products that we provide.  Such information generally includes your name, contact details, date of birth, sex, occupation, Medicare number, health fund membership, referring doctor, payment details, records of correspondence and billing statements, and information about your health status, which may include clinical photographs.  In certain circumstances, we may also hold sensitive information about you, such as information about your race, ethnic origins, or religious beliefs, however, we will only do so if it has been collected with your express consent.

If you are one of our suppliers, we may collect other information about you that we feel is necessary, such as the nature of the products or services that you supply, quotes that you provide and your direct credit details.  

If you are a non-profit organisation that we have agreed to assist, we may collect information about how you make use of the products or services that we provide to you. 

How we hold your information

Depending on the circumstances, we may hold your information in either hardcopy or electronic form or both. Generally, a copy of all correspondence is held in electronic format.

How we use your information

We use your personal information:

• to provide you with our products and services;
• to administer our customer relationship with you;
• for internal purposes such as procedural assessments, risk management, product and service reviews, staff training, accounting and billing.

If you are one of our suppliers, we may use your information to facilitate our business relationship with you, for example, to assess goods or services that you supply or to review a commercial proposal that you have put to us.

How we disclose your information

We will disclose your personal and health information for a purpose that is related to the product or service that we are providing to you, for instance, providing health services or facilitating your care by other clinicians, and making billing arrangements with Medicare or your health fund.  Disclosure may also be made to organisations that provide us with professional advice in resolving legal or commercial complaints, and to contractors to whom we out-source certain functions, such as mailing houses, network administrators and debt collection agencies.

Where possible, we take contractual and other reasonable measures with our contractors to ensure that they comply with the privacy standards set out in the Privacy Act 1988(Cth).    We may also disclose information where it is expressly permitted under the Privacy Act 1988(Cth), for example, where it is with your consent or where we are legally required to do so, such as pursuant to a Court Order.

How we secure your information

We hold all hardcopy and electronic records of personal information in a secure manner to ensure that they are protected from unauthorised access, modification or disclosure.  Our staff follows strict information handling procedures and we only permit those staff whose tasks require use of your information to access it.  Our computers are password protected and run regular anti-virus software. We will check with you that your contact details are up to date. 

In the event that there may be a breach of security or data related to your personal or health information, we will adhere to the requirements of the Privacy Amendment (Notifiable Data Breaches) Act 2017(the NDB Scheme). The NDB Scheme came into effect on 22 February 2018. The Scheme requires us to report an “eligible data breach” to you and to the Australian Information Commissioner. An eligible data breach occurs when :

• There is unauthorized access to, or disclosure of, information held by a health provider, and a reasonable person would conclude that the access or disclosure would likely result in serious harm to individuals to whom such information relates; or
• Information is lost in circumstances where unauthorized access to, or unauthorized disclosure of, information is likely to occur, and if it did occur, a reasonable person would conclude that access or disclosure would be likely to result in serious harm to any of the individuals to whom the information relates. 

Notification to the Australian Information Commissioner is not necessitated if an entity takes remedial action prior to any serious harm occurring from a data breach or from loss, access or disclosure of information.

Your right to lodge a complaint

If you are not satisfied with how we have handled your personal or health information, you may lodge a complaint with our Privacy Officer either by mail at Adelaide Plastic Surgery, Level 4, 18 North Terrace, Adelaide SA 5000, by telephone on (08) 8213 1800, or by email to admin@apsa.com.au  

We will inform you of who will handle your complaint and you may contact our Privacy Officer to enquire about its progress at any time.  We will go to lengths to ensure that complaints are resolved satisfactorily.

If you continue to be dissatisfied, however, you may also lodge a complaint with the Office of the Australian Information Commissioner. Information regarding how to lodge a complaint is available from the Commissioner’s website at www.oaic.gov.auor by ringing the Commissioner’s information line on 1300 336 002.  

Your right of access

You may request access to your personal information at any time by sending a written request to our Privacy Officer – Adelaide Plastic Surgery, Level 4, 18 North Terrace, Adelaide   SA 5000, by facsimile on (08) 8213 1811 or by email to admin@apsa.com.au

You do not need to provide a reason for your request.   Once our Privacy Officer has verified your indentity, we will endeavor to arrange for access to be provided to you in an appropriate manner within 14 days.  We may charge a small fee for providing access if it requires a significant amount of time to locate your information or to collate or present it in an appropriate form.   Our Privacy Officer will follow up your request to ensure that the level of access with which you have been provided is to your satisfaction.

In rare circumstances, and only where it is permitted under the Privacy Act 1988(Cth), we may not be able to provide you with access to your information; for example, where it will have an unreasonable impact upon the privacy of others, where it relates to legal proceedings between us through which information would not otherwise be available, where it would be prejudicial to negotiations we are holding with you, where we are required by law to withhold the information or where it would reveal information relating to our commercially sensitive decision making processes.  If we are unable to provide you with access, we will state why this is so and consider whether the use of an intermediary would be appropriate to provide you with an explanation of your personal information.

You may correct your information

If your personal or health information is out-of-date or incorrect, you may inform us of this and we will correct it for you.  In the unlikely event that we disagree about the accuracy of the information and are unable to change it, you may provide us with a statement indicating that you dispute its accuracy and we will associate the statement with your information in such a manner that it will be brought to the attention of each person who uses the information.

Promotional information

We occasionally email information to all patients who have provided their email addresses for this express purpose.  If you have received such material in error please inform us either by email to admin@apsa.com.au, by telephone (08) 8213 1800, by facsimile on (08) 8213 1811 or mail to our Privacy Officer at Adelaide Plastic Surgery, Level 4, 18 North Terrace, Adelaide SA 5000

Transfer of your information overseas

We will only transfer your personal or health information overseas if the transfer is to you, or to one of your authorised representatives, or it is with your express consent.   We will not send your information outside of Australia in any other circumstances.

We may need to change our privacy policy from time to time

We may need to change our Privacy Statement from time to time to reflect legislative updates or community expectations.  If we do, we will endeavour to ensure that your over all level of privacy protection is not diminished and will publish the changes on our website.  Any actions that we have taken before the change will continue to be regulated by the Privacy Statement that existed before the changes were made.

Further information

We are happy to provide you with further information regarding your privacy. If you have any queries or requests in this respect, please contact our Privacy Officer either by mail at Adelaide Plastic Surgery, Level 4, 18 North Terrace, Adelaide   SA 5000, by telephone on (08) 8213 1800, by facsimile on (08) 8213 1811 or by email to admin@apsa.com.au

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