Purpose

St Vincent’s Private Hospital Toowoomba (SVPHT) is committed to protecting the privacy of the personal information and sensitive information which it collects and holds. 

SVPHT must comply with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and other privacy laws which govern the way in which organisations (such as SVPHT) hold, use and disclose personal information (including your sensitive information). 

The purpose of this Privacy Policy is to explain: 

• The kinds of information that SVPHT may collect about you and how that information is held; 
• How SVPHT collects and holds personal information;
• The purposes for which SVPHT collects, holds, uses and discloses personal information; how you can access the personal information SVPHT holds about you and seek to correct such information; and
• The way in which you can complain about a breach of your privacy and how SVPHT will handle that complaint.

Definitions

In this Privacy Policy the following terms have the following meanings: 

Health information is personal information or an opinion about: 

1. An individual’s physical or mental health or disability (at any time); 
2.  An individual’s express wishes about the future provision of health services for themselves; or 
3.  A health service provided, or to be provided, to an individual;
4.  Other personal information collected to provide, or in providing, a health service; 
5.  Other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances;
6.  Genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual;
7.  Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
   i) Whether the information or opinion is true or not; and
   ii) Whether the information or opinion is recorded in a material form or not. 

Sensitive information means personal information or opinion about an individual’s: 

i) Racial or ethnic origins; 

ii) Political opinions or political associations; 

iii) Philosophical beliefs or religious beliefs or affiliations; 

iv) Sexual preferences or practices; or 

v) Criminal record; or 

vi) Health information about an individual; or 

vii) Genetic information about an individual that is not otherwise health information. 

Principles

Apply to: 

Delegation of Authority and Responsibilities: 

Manager – to implement this policy and ensure that all staff are informed of what is expected of them, are provided with or have access to this and related policies / procedures and to monitor, discuss and document the implementation of the policy. To address ongoing issues with implementation of the policy as they arise. 

Staff – to be familiar with the policy and related policies / procedures. If clarification is required on any aspect of the policy staff should seek advice from either their manager or other nominated staff. 

Policy

1. Collection and use of personal information 

1.1 Types of personal information collected by SVPHT 

a) SVPHT Patients/residents/clients/research participants 

SVPHT collects information from you that is necessary for us to provide you with health care services or to enable you to participate in research studies. This includes collecting personal information such as your name, address, your health history, family history, past and current treatments lifestyle factors, and any other information which is necessary to assist the health care team in providing appropriate care, or our research team in conducting its research. 

b) VMOs, students, contractors and volunteers 

SVPHT collects information from you that is necessary to properly manage and operate its business. This includes collecting personal information such as your name, address, professional experience, qualifications and past employers, and any other information which may be necessary to appropriately conduct its business. 

c) Job applicants 

SVPHT collects information from you that is necessary to assess and engage applicants. This includes collecting personal information such as your name, address, professional experience, qualifications, references and past employers, and any other information which is necessary to process your job application. 

d) Donors 

Where you have consented, SVPHT collects information from you for the purposes of fundraising and managing donations. This includes collecting personal information such as your name and address.

1.2 How we collect personal information 

We will usually collect your personal information directly from you; however, sometimes we may need to collect information about you from third parties, such as: 

a) relatives 

b) another health service provider 

c) past employers and referees 

d) related entities (being those listed in the annexure). 

We will only collect information from third parties where: 

a) you have consented to such collection; 

b) such collection is necessary to enable us to provide you with appropriate health care services (e.g. in the case of a emergency medical treatment); 

c) such collection is reasonably necessary to enable us to appropriately manage and conduct our business (such as in assessing applications for accreditation from VMOs); 

d) it is legally permissible for us to do; 

e) SVPHT will only collect information which is necessary to provide you with health care services or appropriately manage and conduct our business.  

1.3 How SVPHT uses your personal information 

SVPHT only uses your personal information for the primary purpose for which it was collected, unless:

a) there is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or SVPHT has informed you, that your information will be used for that secondary purpose; 

b) you have given your consent for your personal information to be used for a secondary purpose; or 

c) SVPHT is required or authorised by law to use your personal information for a secondary purpose. 

For example, SVPHT may use your personal information to: 

a) provide health care services to you; 

b) provide any ongoing health related services to you; 

c) appropriately manage our business, such as assessing insurance requirements; 

d) assist in running our hospital business, including quality assurance programs and billing; 

e) effectively communicate with third parties, including Medicare Australia, private health insurers and Department of Veterans’ Affairs; conducting audits and undertaking accreditation processes; improving services; implementing appropriate security measures; conducting research and training personnel (including for research and quality improvements within SVPHT).

1.4 Complete and accurate details 

Where possible and practicable, you will have the option to deal with SVPHT on an anonymous basis or by using a pseudonym; however, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the services or support you are seeking, or deal with you effectively. 

1.5 CCTV 

SVPHT uses camera surveillance systems (commonly referred to as CCTV) for the purposes of maintaining safety and security of its patients, personnel, visitors and other attendees. These CCTV systems may also collect and store personal information and SVPHT will comply with all privacy legislation in respect of any such information.

 2. Disclosing your personal information 

a) Third parties involved in your care, such as: 

i. Pathologists and Radiologists who have been asked to undertake diagnostic testing; 

ii. Senior medical experts and specialists who have been asked to assist in diagnosis or treatment; 

iii. Other health professionals involved in an individual’s further treatment (such as physiotherapists and occupational therapists) 

b) General practitioners (for example, by providing discharge summaries); 

c) Government agencies, such as Defence or Department of Veterans Affairs, where an individual is receiving services with SVPHT under arrangements with those agencies; 

d) Government departments responsible for health, aged care and disability where SVPHT has a legal or contractual obligation to do so; 

e) Relatives, close friends, guardians (unless SVPHT have been told otherwise); 

f) Third parties contracted to provide services to SVPHT, such as entities contracted to assist in accreditation or survey processes; 

g) Chaplains associated with SVPHT so that an individual may receive pastoral care during admission; 

h) Any of the related entities listed in the annexure; 

i) Research institutions with which SVPHT’s collaborates; 

j) Private health insurance providers and Medicare Australia; 

k) Anyone authorised by you to receive your personal information (your consent may be express or implied); 

l) Anyone SVPHT is required by law to disclose your personal information to.

3. Data storage, quality and security 

3.1 Data Quality 

SVPHT will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date. 

3.2 Storage 

All your personal information is stored by SVPHT securely in either hard copy or electronic form and may be stored offsite using a secure storage provider with obligations under the privacy act. If personal information is required to be disclosed to an overseas third party e.g. travel insurance, SVPHT will take reasonable steps to ensure that the third party does not breach the APPs (other than APP 1), unless: 

a) that third party is subject to appropriate overseas privacy legislation and there is a mechanism for individuals to enforce the protection of their personal information; 

b) the individual consents to their personal information being held by the overseas entity; 

c) there is a permitted general situation allowing the disclosure (ie, there is a serious threat to life, health or safety, there is a threat of unlawful activity, the disclosure is needed to locate a missing person, etc).

3.3 Data Security 

SVPHT strives to ensure the security, integrity and privacy of your personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. SVPHT reviews and updates (where necessary) its security measures in light of current technologies. 

3.4 Online Transfer of Information 

While SVPHT does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with SVPHT via an online process, it is at your own risk. 

There are ways you can help maintain the privacy of your personal information, including: 

a) Always closing your browser when you have finished your user session; 

b) Always ensuring others cannot access your personal information and emails if you use a public computer; and 

c) Never disclosing your user name and password to third parties.

4. Use of cookies 

A ‘cookie’ is a small data file placed on your machine or device which lets SVPHT identify and interact more effectively with your computer. Cookies do not identify individual users, but they do identify your ISP and browser type. 

Cookies which are industry standard and are used by most web sites, including those operated by SVPHT, can facilitate a user’s ongoing access to and use of a site. They allow SVPHT to customise our website to the needs of our users. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with some features of our on-line services via the SVPHT website. 

5. Links to other sites 

SVPHT may provide links to third party websites. These linked sites may not be under our control and SVPHT is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.  

6. Accessing and amending your personal information 

You have a right to access your personal information which SVPHT holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require. 

You can also request an amendment to any of your personal information if you consider that it contains inaccurate information. 

You can contact SVPHT about any privacy issues as follows: 

Privacy Officer Ph 4690 4000 

While SVPHT aims to meet all requests to access and amendments to personal information, there may be some instances where SVPHT is unable to do this where it may adversely affect your health and safety or the safety of others. 

7. Complaints 

If you have a complaint about SVPHT’s information handling practices or consider we have breached your privacy, you can lodge a complaint with: 

a) SVPHT Privacy Officer, on the contact details listed in clause 6 above; or 

b) the Executive Office 

c) the Office of Australian Information Commissioner. SVPHT deals with all complaints in a fair and efficient manner.

Annexure - related entities 

1. St Vincent’s Health Australia Limited 

2. St Vincent’s Healthcare Limited 

3. St Vincent’s Health and Aged Care Limited 

4. St Vincent’s Hospital Toowoomba Limited 

5. The Holy Spirit Northside Private Hospital Limited 

6. St Vincent’s Hospital (Melbourne) Limited 

7. St Vincent’s Private Hospital Melbourne Limited 

8. St Vincent’s Private Hospital Sydney Limited 

9. St Vincent’s & Mater Health Sydney Limited 

10. St Vincent’s Hospital Sydney Limited 

11. St Vincent’s Clinic 

12. St Joseph’s Village Limited 

13. Trustees of Mary Aikenhead Ministries