CONTENTS

1. PART 1 - ABOUT THIS POLICY

1.1 Purpose

1.2 Multi-layered approach

1.3 Contents of this Privacy Policy

2.PART 2 – HOW Sapphire Clinic HANDLES YOUR PERSONAL INFORMATION 2.1 Sapphire Clinic's Legal Obligations

2.2 What information does Sapphire Clinic collect?

2.3 How does Sapphire Clinic use your information?

  • Use among health professionals to provide your treatment
  • Your local doctor
  • Other health service providers
  • Relatives, guardian, close friends or legal representative
  • Other Sapphire Clinic entities
  • Other common uses
  • Contractors
  • Other uses with your consent
  • Pastoral Care

2.4 Access to and correction of your health information

  • Data Quality
  • Data Security
  • If you have a complaint about privacy issues
  • How to contact us
  • Currency

3.PART 3 – HOW Sapphire Clinic HANDLES YOUR PERSONAL INFORMATION WHEN YOU VISIT OUR WEBSITE

  • Collection
  • Cookies
  • Links to third party websites
  • Use and disclosure
  • Data quality
  • Data Security

3.7 Access and correction

4. SCHEDULE 

4.1 The Sapphire Clinic

PART 1 - ABOUT THIS POLICY

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1.1 Purpose

Sapphire Medical Clinic Pty Ltd (Sapphire Clinic) is committed to ensuring the privacy and confidentiality of your personal information.

Sapphire Clinic must comply with the National Privacy Principles (NPPs) under the Privacy Act 1988 (Cth) and other privacy laws that govern how private sector health service providers like Sapphire Clinic handle your personal information (including your health information). 

The purpose of this Privacy Policy is to clearly communicate to you how Sapphire Clinic handles your health information. It will give you a better and more complete understanding of the type of personal information that Sapphire Clinic holds about you and the way Sapphire Clinic handles that information. 

This Privacy Policy applies to companies in the Sapphire Clinic group which are associated with the facilities listed at the end of this Privacy Policy

1.2 Multi-layered approach

This Privacy Policy has been developed in accordance with a 'layered policy' format endorsed by the Office of the Federal Privacy Commissioner.  This means that it offers you the ability to obtain more or less detail about Sapphire Clinic's information handling practices – depending on how much you wish to read, what you need to know and how quickly you need to obtain the relevant

information. 

If you only require basic information about Sapphire Clinic's information handling practices, you can view our 'condensed' privacy policy.  This is a summary of how Sapphire Clinic collects, uses and discloses your personal information and how you can contact Sapphire Clinic if you would like to access or correct any personal information which Sapphire Clinic holds about you. 

If you require more detailed information about Sapphire Clinic's information handling practices, then you will need to read this document. 

1.3 Contents of this Privacy Policy

PART 2 – How Sapphire Clinic Handles Your Personal Information

PART 3- How Sapphire Clinic  Handles Your Personal Information When You Visit Sapphire Clinic's Website 

PART 2 – HOW Sapphire Clinic HANDLES YOUR PERSONAL INFORMATION

2.1 Sapphire Clinic's Legal Obligations

As foreshadowed in Part 1 of this Privacy Policy, as a private sector health service provider, Sapphire Clinic is required to comply with the NPPs under the Privacy Act 1988 (Cth). 

The NPPs regulate how Sapphire Clinic may collect, use, disclose and store personal information and how individuals (such as Sapphire Clinic patients) may access and correct personal information which Sapphire Clinic holds about them. 

In order to provide you with the health care services that you have requested, Sapphire Clinic will need to collect and use your personal information.  If you provide incomplete or inaccurate information to us or withhold personal health information from us we may not be able to provide you with the services you are seeking. 

In this Privacy Policy, we use the terms:

•“personal information” as it is defined in the Privacy Act 1988 (Cth).  This means:

“information or an opinion (including information or an opinion forming part of a database, whether true or not, and whether recorded in a material format or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion”; and

•'health information“ as it is defined in the Privacy Act 1988 (Cth).  This is a particular subset of “personal information” and means information or an opinion about:

◦the health or a disability (at any time) of an individual; or

◦an individual's expressed wishes about the future provision of health services to him or her; or

◦a health service provided or to be provided to an individual,

• that is also personal information.

Personal information also includes 'sensitive information' which is information such as your race, religion, political opinions or sexual preferences and health information.  Information which is 'sensitive information' attracts a higher privacy standard under the Privacy Act 1988 (Cth) and is subject to additional mechanisms for your protection.

2.2 What information does Sapphire Clinic collect?

We collect information from you that is necessary to provide you with health care services. 

Often this may include collecting information about your health history, family history, your ethnic background or your current lifestyle to assist the health care team in diagnosing and treating your condition. 

We will usually collect your health information directly from you.  Sometimes, we may need to collect information about you from a third party  (such as a relative or another health service provider).  We will only do this if you have consented for us to collect your information in this way or where it is not reasonable or practical for us to collect this information directly from you, such as where your health may be at risk and we need your personal information to provide you with emergency medical treatment. 

2.3 How does Sapphire Clinic use your information?

Sapphire Clinic only uses your personal information for the purpose you have given the information to us unless one of the following applies:

•The other purpose is directly related to the purpose for which you have given us the information and you would reasonably expect, or we have told you, that your information is usually disclosed for another purpose or to other individuals, organisations or agencies (see paragraphs (a) – (g) below);

•you have consented for us to use your information for another purpose;

•Sapphire Clinic is required or authorised by law to disclose your information for another purpose (see paragraph (f) below);

•the disclosure of your information by Sapphire Clinic will prevent or lessen a serious and imminent threat to somebody's life or health; or

•the disclosure of your information by Sapphire Clinic is reasonably necessary for the enforcement of the criminal law or a law imposing a penalty or sanction, or for the protection of public

revenue. 

(a) Use among health professionals to provide your treatment

Modern health care practices mean that your treatment will be provided by a team of health professionals working together.

You may be referred for diagnostic tests such as pathology or radiology and our staff may consult with senior medical experts when determining your diagnosis or treatment.  Our staff may also refer you to other health service providers for further treatment during and following your admission (for example, to a physiotherapist or outpatient or community health services).

Further, if you require a prosthetic as part of your treatment, we may disclose your personal information to the manufacturer of that prosthesis.

These health professionals will share your health information as part of the process of providing your treatment.  We will only do this while maintaining confidentiality of all this information and protecting your privacy in accordance with the law. 

Your health information will only be disclosed to those health care workers involved in your treatment. 

(b) Your local doctor

Sapphire Clinic will usually send a discharge summary to your referring medical practitioner or nominated general practitioner following an admission to one of our facilities. 

This is in accordance with long-standing health industry practice and is intended to inform your doctor of information that may be relevant to any ongoing care or treatment provided by them. 

If you do not wish us to provide a copy of your discharge summary to your nominated general practitioner you must let us know.  Alternatively, if your nominated general practitioner has changed or your general practitioner's details have changed following a previous admission, you must let us know. 

© Other health service providers

If in the future you are being treated by a medical practitioner or health care facility who needs to have access to the health record of your treatment in one of our facilities we will require an authorisation from you to provide a copy of your record to that medical practitioner or health care facility.

The only time we would provide information about your health records to another medical practitioner without your consent is in the event of an emergency where your life is at risk and you are not able to provide consent. 

(d) Relatives, guardian, close friends or legal representative

We may provide information about your condition to your parent, child, other relatives, close personal friends, guardians, or a person exercising your power of attorney under an enduring power of attorney, unless you tell us that you do not wish us to disclose your health information to any such person. 

(e) Other Sapphire Clinic entities

Sapphire Clinic may share your health information amongst its facilities listed at the end of this Privacy Policy.  For example, this may occur where you are transferred between any of Sapphire Clinic's facilities or to coordinate your care. 

(f) Other common uses

In order to provide the best possible environment in which to treat you, we may also use your health information where necessary for:

• activities such as quality assurance processes, accreditation, audits, risk and claims management, patient satisfaction surveys and staff education and training;

• invoicing, billing and account management;

• to liaise with your health fund, Medicare or the Department of Veteran's Affairs, as necessary; and

• the purpose of complying with any applicable laws – for example, in response to a subpoena or compulsory reporting to State or Federal authorities (for example, for specified law enforcement or public health and safety circumstances). 

(g) Contractors

Where we outsource any of our services or hire contractors to perform professional services within our hospitals or health services we require them to also comply with the Privacy Act 1988 (Cth)

(or other relevant privacy legislation) and our Privacy Policy.

(h) Other uses with your consent

With your consent we can also use your information for other purposes such as including you on a marketing mail list, fundraising or research.   Please note, however, that unless you provide us

with your express consent for this purpose, we will not use your information in this way.

(i) Pastoral Care

We may provide your information to chaplains accredited with our hospitals in order that you may receive pastoral care during your admission.  However, we will only provide your information for this purpose with your express consent. 

Please note, Sapphire Clinic may use or disclose your personal information as specified above via electronic processes, where available or relevant. 

2.4 Access to and correction of your health information

You have a right to have access to the health information that we hold in your health record.  You can also request an amendment to your health record should you believe that it contains inaccurate information. 

Sapphire Clinic will allow access or make the requested changes unless there is a reason under the Privacy Act 1988 (Cth) or other relevant law to refuse such access or refuse to make the requested changes. 

If we do not agree to change your medical record/personal information in accordance with your request, we will permit you to make a statement of the requested changes and we will enclose this with your record. 

Should you wish to obtain access to or request changes to your health record you can ask for our Privacy Officer (see details below) who can give you more detailed information about Sapphire Clinic's access and correction procedure.

Please note that Sapphire Clinic may recover reasonable costs associated with supplying this information to you. 

2.5 Data Quality

Sapphire Clinic will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date.

2.6 Data Security

Sapphire Clinic will take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.  We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect your privacy.

Sapphire Clinic will destroy or permanently de-identify any of your information which is no longer needed. 

2.7 If you have a complaint about privacy issues

If:

(a) you have questions or comments about this Privacy Policy;

(b) Sapphire Clinic does not agree to provide you with access to your personal information; or

© you have or a complaint about our information handling practices,

(d) you can lodge a complaint with or contact our Privacy Officer on the details below or directly with the Federal Privacy Commissioner.

2.8 How to contact us

• By letter: Practice Manager 44 Merimbula Drive Merimbula • By telephone: (02) 6495 4700 • By facsimile: (02) 6495 4701

2.9 Currency

This Privacy Policy was last updated in 2014 and may change from time to time.  The most up-to-date copy can be obtained by contacting us using the above-mentioned details.

PART 3 – HOW Sapphire Clinic HANDLES YOUR PERSONAL INFORMATION WHEN YOU VISIT OUR WEBSITE

This section of our Privacy Policy explains how we handle your personal information which is collected from our website:  www.Sapphire Clinichealth.com.au. 

This Privacy Policy applies to your use of our website and the use of any of the facilities on our website. 

3.1 Collection

When you use our website, we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us. 

Sometimes, we may collect your personal information if you choose to provide this to us via an online form or by email, for example, if you:

•submit a general enquiry via our contacts page;

•register to receive share market reports; or

•send a written complaint or enquiry to our Privacy Officer. 

When you use our website, our Internet Service Provider (ISP) will record and log for statistical purposes the following information about your visit:

•your computer address;

•your top level name (for example, .com,.gov, .org, .au etc);

•the date and time of your visit;

•the pages and documents you access during your visit; and

•the browser you are using.

Our web-site management agent may use statistical data collected by our ISP to evaluate the effectiveness of our web-site.

We are, however, obliged to allow law enforcement agencies and other government agencies with relevant legal authority to inspect our ISP logs, if an investigation being conducted warrants such inspection.

3.2 Cookies

A “cookie” is a device that allows our server to identify and interact more effectively with your computer.  Cookies do not identify individual users, but they do identify your ISP and your

browser type. 

This website uses temporary cookies.  This means that upon closing your browser, the temporary cookie assigned to you will be destroyed and no personal information is maintained which will identify you at a later date. 

Personal information such as your email address is not collected unless you provide it to us. We do not disclose domain names or aggregate information to third parties other than agents who assist us with this website and who are under obligations of confidentiality.  You can configure your browser to accept or reject all cookies and to notify you when a cookie is used.  We suggest that you refer to your browser instructions or help screens to learn more about these functions.  However, please note that if you configure your browser so as not to receive any cookies, a certain level of functionality of the Ramay website and other websites may be lost.

3.3 Links to third party websites

We may create links to third party websites. We are not responsible for the content or privacy practices employed by websites that are linked from our website. 

3.4 Use and disclosure

We will only use personal information collected via our website for the purposes for which you have given us this information.

We will not use or disclose your personal information to other organisations or any one else unless:

•you have consented for us to use or disclose your personal information for this purpose;

•you would reasonably expect or we have told you that your information is usually used or disclosed to other organisations or persons in this way;

•the use or disclosure is required or authorised by law;

•the use or disclosure will prevent or lessen a serious or imminent threat to somebody's life or health; or

•the disclosure is reasonably necessary for law enforcement functions or for the protection of public revenue. 

If we receive your email address because you sent us an email message, the email will only be used or disclosed for the purpose for which you have provided and we will not add your email address to an emailing list or disclose this to anyone else unless you provide us with consent for this purpose. 

3.5 Data quality

If we collect your personal information from our website, we will maintain and update your information as necessary or when you advise us that your personal information has changed.

3.6 Data Security

Sapphire Clinic is committed to protecting the security of your personal information.  We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of information.  We will take all reasonable steps to prevent your information from loss, misuse or alteration. 

If you choose to complete our online forms or lodge enquiries via our website, we will ensure that your contact details are stored on password protected databases.

Staff members associated with website maintenance have access to our website's backend system.  This is password protected.  Our website service is also password protected. 

3.7 Access and correction

If you wish to obtain information about how to access or correct your personal information collected via our website, please refer to Access and Correction at Item 2.4 of Part 2 of this document.