Envoi - Privacy Policy
Updated July 2020
Clouston Pathology Pty Ltd trading as Envoi Specialist Pathologists (and its related entities and related bodies corporate) (Envoi) is committed to upholding the Australian Privacy Principles (APPs), meeting our statutory obligations, and protecting the privacy of individuals. Privacy and confidentiality are integral parts of Envoi's professional ethics. We are committed to ensuring all personal information collected and received by Envoi is handled and protected in accordance with the requirements set out in the APPs.
Envoi considers the collection of relevant personal information as fundamental to the provision of individualised, quality care. This Privacy Policy provides information about how personal information is collected and used within the practice and circumstances in which we may disclose it to third parties.
1. Collection of personal information:
Patients
1.1. Health information is classified as 'sensitive information' for the purposes of the APPs and will be collected via referring medical practitioners and disclosed to Envoi with the consent of the patient or as otherwise permitted by law. Personal information may also be collected from:
1.1.1. Data that is recorded on the pathology request form your doctor gives you when recommending that you obtain pathology services, or providing surgical treatment;
1.1.2. Other persons or entities who ask us to perform pathology services on your behalf (for example, the hospital/nursing home where you are a patient, a government department, an insurance agency or your employer);
1.1.3. Someone who has legal responsibility for you (your parent, carer or guardian);
1.2. The types of personal information collected by Envoi includes, but is not limited to, information about:
1.2.1. Your medical history;
1.2.2. Family medical history;
1.2.3. Test results;
1.2.4. Ethnic background;
1.2.5. Medicare details, including your Medicare card number;
1.2.6. Health fund and insurance details;
1.2.7. Billing/account details;
1.2.8. Current lifestyle as it may relate to your health;
1.2.9. Activities;
1.2.10. Next of kin;
1.2.11. Emergency contacts and,
1.2.12. Other information that may be relevant to your diagnoses, treatment or health care.
1.3. Envoi may request further information about your medical history, via referring medical practitioners, or by directly contacting you.
1.4. Your personal information may be collected by Envoi directly from you, and also from third parties, including family members, health professionals and other health service provider organisations.
Non-patients
1.5. If you are a visitor to our premises or interacting with us other than as a patient, such as a family member, guardian or support person of a patient or an external medical professional, then the types of personal information we may collect about you includes your name, contact details, identification information, qualifications and any relationship you may have to a patient.
2. Use and Disclosure
2.1. Envoi uses the personal information collected to facilitate an accurate diagnosis, provide health care services to patients, provide appropriate treatment recommendations and to be proactive in patient health care.
2.2. Envoi may collect, hold, use and disclose personal information for the following purposes:
2.2.1. Providing our health care services and other services;
2.2.2. Administrative purposes for running our medical practice, including maintaining and updating our records and training our people;
2.2.3. Exchanging information between Envoi group entities;
2.2.4. Communicating with other specialists, general practitioners / referring doctors and their administrative staff, and health service providers such as other pathologists, radiologists, allied health professionals, pharmacists, in relation to relevant individual diagnostic services or treatment;
2.2.5. Quality assurance, practice accreditation and licensing, management, funding, service-monitoring, complaint handling, planning, evaluation and audit activities;
2.2.6. To comply with statutory and public health reporting requirements, such as notification of diagnosis of certain communicable diseases;
2.2.7. Communicating with medical defence organisations, insurers, medical experts or lawyers for medical indemnity purposes and anticipated or existing legal proceedings;
2.2.8. Disclosure to an individual's close relatives, close friends, and personal representatives, as permitted by the individual;
2.2.9. Disclosure to an individual's lawyers and insurance companies that have been authorised by the individual to obtain personal information from us;
2.2.10. Conducting surveys (e.g. for the purpose of improving services);
2.2.11. For research and development projects which may include undertaking research feasibility, benchmarking, clinical indicator reporting, guideline adherence and treatment evaluation/compliance. Envoi may enter into commercial relationships with external entities using de-identified, aggregated data where individuals cannot be identified;
2.2.12. For internal teaching purposes or to monitor, evaluate, plan and improve the services we provide;
2.2.13. To provide to entities undertaking research (such as Cancer Councils, universities and pharmaceutical companies) who periodically request data from our medical records. We will only provide identified data in response to these requests when authorised to do so by the Privacy Act 1988 (Cth);
2.2.14. To provide to university students undertaking clinical placements with us, who may have access to and use your personal information;
2.2.15. Billing, payment processing and debt recovery;
2.2.16. Processing of clinical transcription files;
2.2.17. Reviewing the accuracy, upgrading and testing of patient medical record systems;
2.2.18. Where we engage service providers, such as providers of archival, auditing, accounting, legal, banking, payment, debt collection, delivery, data processing, document management, research, investigation, insurance, website or technology services;
2.2.19. To the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights;
2.2.20. In response to orders of a court or tribunal, such as producing records in relation to court proceedings; and
2.3. Purposes consented to by you.
By continuing to engage with us after this Privacy Policy is provided to you, you expressly consent to our collection, use and disclosure of your personal information in the manner detailed above.
3. Data Security
3.1. Envoi holds medical and personal information electronically and in hard copy form, both at our own premises and with the assistance of service providers who provide data storage, hosting and cloud computing services.
3.2. It is necessary for Envoi to keep patient information for as long as is required by law or is prudent, having regard to administrative and medical requirements.
3.3. Where Envoi discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this Privacy Policy.
4. Securing your data
4.1. Envoi will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
4.2. Envoi will store all the personal information you provide on its secure servers.
4.3. Information relating to electronic transactions entered into via Envoi’s website will be protected by encryption technology during transit.
5. Our Websites
5.1. Envoi operates various websites including:
5.1.1. Envoi.com.au
5.1.2. and other websites on which this Privacy Policy is posted with our authority, (collectively, our Websites).
5.2. If a user visits any of our Websites to read, browse or download information, our system may record information such as the user's IP address, browser type, domain names, access times and referring website addresses. This information is used by Envoi for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of our Websites.
5.3. Envoi encourages individuals to review the privacy statements of third-party websites they choose to access via links from our Websites so that they can understand how those third party websites collect, use and share your personal information. Envoi is not responsible for, and has no control over, the collection by third parties of your personal information via websites other than our Websites.
5.4. Our Websites may use cookies to help identify and interact more effectively with users' devices. A cookie is a text file that is placed on a user's device by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. The cookie helps us to maintain the continuity of users' browsing sessions and remember their details and preferences for when they return.
5.5. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Websites.
5.6. Our Websites may use Google services such as Google Analytics from time to time. For more about how Google collects and processes data, please see Google's privacy policy and their information at www.google.com/policies/privacy/partners/.
5.7. If you are considering sending us any other personal information through our Website or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP). We are subject to laws requiring us to protect the security of personal information only once it comes into our possession.
6. Access and Correction
6.1. You may request access to your personal information held by Envoi by contacting the Practice Manager as set out below. You may also request that personal information held about you is corrected or updated. Patients wanting access to their medical records may apply in writing to the Practice Manager and must be able to provide proof of identity.
6.2. There are some circumstances in which access is restricted, or where Envoi may decide not to correct personal information in the manner requested, and, in these cases, reasons for denying access or not amending the personal information will be explained. If we decide not to make your requested amendment, you may ask us to make a note of your request with the personal information we hold about you.
6.3. Envoi acknowledges the right of children to privacy of their health information. Based on the professional judgment of the treating doctor and consistent with applicable laws, it might at times be necessary to restrict access to personal health information by parents or guardians.
6.4. Patients may also request that their health information held by Envoi be made available to other health service providers.
7. Complaints
7.1. All complaints related to a breach by Envoi of the APPs should be directed to the Practice Manager via the details below.
7.2. Envoi will manage any breaches of the APP’s and Envoi’s Privacy Policy as follows:
7.2.1. All complaints will be reported to the Practice Manager;
7.2.2. The complaint is entered into our Corrective Action Report (CARs) register for investigation and consideration of further action;
7.2.3. Any identified breach of the APPs or Envoi Privacy Policy will result in remedial action being taken as required (including notification to affected parties, notification to Australian Information Commissioner);
7.2.4. Outcomes of complaints will be responded to within 30 days of notification of complaint.
7.3. If the complaint is not satisfactorily resolved, you have the right to contact the appropriate regulatory authority, such as the Information Commissioner (in relation to the Privacy Act 1988 (Cth):
Office of the Australian Information Commissioner
1300 363992
privacy@privacy.gov.au
www.privacy.gov.au/complaints
7.4. Envoi’s Practice Manager may be contacted as follows:
The Practice Manager
Envoi Specialist Pathologists
5/38 Bishop Street
Kelvin Grove QLD 4059
07 3552 6400