Privacy is very important to Healthy Travel Pty Ltd (Healthy Travel).
Healthy Travel is committed to protecting personal information collected in accordance with the Australian Privacy Principles and other applicable privacy laws and industry standards.
This policy applies to the personal information we collect and use including patients, visitors to the website. What type of personal information we collect and the ways in which we use and disclose that personal information, how we manage personal information aaand how you can access and seek correction of it.
INFORMATION COLLECTED
Patients and prospective patients
Healthy Travel may collect the following personal information from its patients and prospective patients.
- Identifying and contact information including but not limited to: full name, date of birth, sex/ gender, residential address, postal address, contact phone numbers, email address, nationality, country of birth, emergency contact/ next of kin
- Health information including but not limited to: current and past medical history, any new health information, investigation and test results and names of other treating medical practitioners
- Other information including racial/ ethnic origin, sexual practices, philosophical belief and lifestyle factors
- Financial information such as account history and billing information, Medicare details, Department of Veterans Affairs card details, commonwealth concession card details
Healthy Travel will only collect personal information by lawful and fair means and will not collect personal health information in an unreasonably intrusive manner.
Wherever possible, Healthy Travel will collect personal health information directly from the patient/ prospective patient or a person authorised by the patient.
Healthy Travel will only collect information from third-party healthcare providers for purposes pertaining to continuity of care.
Healthy Travel will retain all personal health information collected for a minimum of 7 years following the patient’s last interaction with Healthy Travel.
The destruction of any personal health information will be conducted by an accredited third-party provider, and a certificate of destruction retained by Healthy Travel.
How do we collect personal health information
Healthy Travel may collect your personal information in several different ways:
- When you make your first appointment Healthy Travel will collect your personal and demographic information via the Health Engine appointment booking form
- Completion of your Travel Medicine Patient Registration Form
- During the course of providing you with travel medicine advice and services
- In some circumstances personal information may be collected from other sources such as:
- Australian Immunisation Register
- Your guardian or responsible person
- Other healthcare providers, such as General Practitioner, specialists, hospitals, pathology and diagnostic imaging providers etc.
- An active My Health Record
DISCLOSURE OF PERSONAL HEALTH INFORMATION
Healthy Travel will not disclose personal health information to a third-party unless:
- The individual has consented to the disclosure or the disclosure is provided for under the “Consent to Collect Use and Disclose Personal Health Information”
- In accordance with the Privacy Act 1988 (Cth) the disclosure is to a responsible carer of that person, as in the case of a child, or if the person in question is physically or legally incapable of giving consent to the disclosure, or for compassionate reasons, unless there is good evidence of the persons wish to the contrary
- Healthy Travel is legally obliged to disclose information (e.g. notification of certain infectious diseases, suspected child abuse etc.)
- Disclosure is necessary to prevent a serious or imminent threat to an individual’s life, health or safety, or to prevent a criminal offence or seriously improper conduct;
- it is required for judicial, administrative or coronial proceedings or is requested under a court order or subpoena;
- it is the subject of a search warrant, or is required to help identify or locate an Employee;
- it is required to facilitate organ donation.
Healthy Travel may be required to disclose personal health information to third-parties overseas where a patient is in need of urgent medical assistance, or where medical evacuation is required. Healthy Travel will take all reasonable steps to ensure that information disclosed to an international third-party is protected and treated as confidential.
STORAGE AND PROTECTION OF PERSONAL INFORMATION
Healthy Travel stores all personal health information in electronic format in its clinical management software, Xestro. Xestro is a web-based application that complies with the Australian standard for healthcare data storage and transmission.
ACCESSING PERSONAL HEALTH INFORMATION
Patients of Healthy Travel can request access to their personal health information stored with Health Travel. Request to access personal health information should be made in writing to [email protected]
It is at the discretion of the patient’s consulting practitioner(s) to provide the patient with either an up-to-date summary of their medical history, or a copy of all their personal health information.
Healthy Travel will not be required to provide patient access to their personal health information where:
- Healthy Travel reasonably believes that giving access would pose a serious threat to the life, health or safety of an individual, or to public health or safety; or
- The request for access of frivolous or vexatious; or
- The information relates to existing or anticipated legal proceedings, and would not be accessible by the process of discover in those proceedings; or
- Giving access would reveal the intentions of Healthy Travel in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
- Giving access would be unlawful; or
- Denying access is require or authorized by or under an Australian law or a court/ tribunal order; or
- Both the following apply:
- Healthy Travel has reason to suspect that unlawful activity or misconduct of a serious nature, that related to the entity’s function or activities has been, is being or may be engaged in:
- Giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
- Giving access would likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- Giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.
On receiving a written request to access personal health information, Healthy Travel will respond within a reasonable period. Healthy Travel will provide the patient with access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.
If Healthy Travel refuses to grant access to the patient’s personal health information requested, or give access in the form requested, Healthy Travel will provide written notices that sets out:
- The reasons for the refusal (except where disclosure of the reasons would be inappropriate); and
- The mechanisms available to complain about the refusal
As per the Privacy Amendment (Private Sector) Act 2000 (Cth), Healthy Travel reserves the right to charge a reasonable administration fee to complete a request for access to personal health information.
CORRECTION OF PERSONAL INFORMATION
Healthy Travel endeavours to keep all patient information collected up-to-date, accurate and complete for the duration of its active use.
It is a patient’s obligation to notify Healthy Travel of any changes to their contact details. If a patient becomes aware that their personal information held by Healthy Travel is incorrect, the patient has the ability to request a correction of the information.
Requests to change personal information should be directed to [email protected].
Requests to change personal health information will be directed to the patient’s medical practitioner.
If Healthy Travel refuses to correct the information corrected by the patient Healthy Travel will provide written notice that sets out:
- The reasons for the refusal, except to the extent that it would be unreasonable to do so; and
- The mechanisms available to complain about the refusal.
Healthy Travel will make every reasonable effort to notify a third-party if information provided to them by Healthy Travel is found to be incorrect.
There is no charge to the patient for requesting the correction of personal information.
Healthy Travel will make every reasonable effort to notify all relevant third-parties if information provided to them by Healthy Travel is found to be incorrect.
COMPLAINTS PROCESS
Complaints about any action of the Healthy Travel team, including partner medical practitioners, arising out of this policy, or any other issue arising under the Australian Privacy Principles, must be submitted to in writing to the Operations Manager at [email protected] within 6 months of the issue arising. The Operations Manager will respond to the complaint within 14 business days after receiving the complaint.
The response will detail Healthy Travel’s decision, reason for decision and any follow up action to be undertaken. If the patient is dissatisfied with the decision, they are entitled to lodge a complaint with the National Health Practitioner Privacy Commissioner.
POLICY REVIEW
We may update this Privacy Policy to reflect changes in our practices and in accordance with any changes to the Privacy legislation, regulations and Australian Privacy Principles.
