The Australian Dental Association Inc (ADA) has developed a privacy policy template for dental practices to adapt, for compliance with the requirements of the Australian Privacy Principles (APPs). Practices should use this template as a guide and adapt it to support their individual procedures. It is not legal advice.
This template covers:
- practice procedures
- staff responsibilities
- patient consent
- collection, use and disclosure of information
- access to information.
The template is designed to communicate to patients how a practice manages personal and health information and to complement other practice policies such as complaint resolution and breach notification procedures. The sections in red text are for you to revise and adapt to the specific procedures of your dental practice.
For more information on privacy, visit the Office of the Australian Information Commissioner at www.oaic.gov.au. Your ADA Branch may also provide guidance on meeting privacy requirements in your jurisdiction.
Make your policy freely available for your patients so they know that it exists and they can access it. For example, display it at your practice reception and on your website (if you have one), and make reference to it in your registration forms and other forms or notices.
This policy should be reviewed regularly to ensure it remains applicable to current practice procedure and legal requirements.
Acknowledgement
The Australian Dental Association Inc (ADA) acknowledges and thanks the Royal Australian College of General Practitioners (RACGP) for allowing the Association to revise this template to meet the needs of dental practices.
Any variations from the original – which was developed by the RACGP for use by general practices – are the ADA’s alone.
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Holistic Dental Donvale Privacy Policy
Current as of: 1st July 2020
Introduction
This privacy policy provides information to you, our patient, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.
Why And When Your Consent Is Necessary
When you register as a patient of our practice, you provide consent for our dental practitioners and practice staff to access and use your personal information so they can provide you with the best possible dental care. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will generally seek additional consent from you to do this, unless obtaining your consent is not practical or reasonable, and an exception under the Privacy Act 1988 (Cth) applies.
Why Do We Collect, Use, Hold And Share Your Personal Information?
Our practice will need to collect your personal information to provide dental services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your dental health. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (e.g. staff training).
What Personal Information Do We Collect?
The information we will collect about you includes your:
- name/s, date of birth, address/es, contact details (e.g. telephone, email), family contact information
- details of your oral health condition and the treatment/s and service/s you have received
- details of your general health (e.g. medications, allergies, medical conditions) and medical history that may impact the dental treatment you receive
- private health insurance information
- Medicare number (where available) for identification and claiming purposes
- information regarding other funding sources, where relevant (e.g. Child Dental Benefits Schedule, Department of Veterans’ Affairs)
- information on workers’ compensation, motor vehicle and other accident claims, where relevant
- healthcare identifiers, where relevant.
Dealing With Us Anonymously
You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.
How Do We Collect Your Personal Information?
Our practice may collect your personal information in several different ways.
- When you make your first appointment our practice staff will collect your personal information via your registration.
- During the course of providing dental services, we may collect further personal information.
- We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media.
- In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:
- your guardian or responsible person
- other involved healthcare providers, such as specialists and diagnostic imaging services
- your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).
When, Why And With Whom Do We Share Your Personal Information?
We sometimes share your personal information:
- with third parties who work with our practice for business purposes, such as information technology providers – these third parties are required to comply with APPs
- with other healthcare providers
- when it is required or authorised by law (e.g. court subpoenas)
- when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent
- to assist in locating a missing person
- to establish, exercise or defend an equitable claim
- for the purpose of confidential dispute resolution process
- when there is a statutory requirement to share certain personal information (e.g. some diseases require mandatory notification)
Only people who need to access your information will be able to do so. Other than in the course of providing dental services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.
We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
Our practice will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.
How Do We Store And Protect Your Personal Information?
Your personal information may be stored at our practice in various forms. The majority of the information is stored electronically on our computer servers and computers in a closed network. Our practice stores all personal information securely. Our computer systems are secured by passwords and are encrypted and backed up daily to a remote server within Australia, managed by a local IT company.
Paper and hard records such X-rays, CT Scans, photos and signed documents and forms are also kept where it is impractical to convert them to digital format. Paper records and hard copies of X-rays and CT scans are stored in locked cabinets and kept on site.
All staff and contractors engaged in this practice are required to undergo training to understand their responsibilities in maintaining your privacy and to sign a confidentiality agreement in order to protect your personal information.
Sending Information Overseas
As part of maintaining your records, the practice may use off-site electronic data storage providers, transcription service providers, professional indemnity insurers, marketing agencies or other third-party service entities. These providers may be located offshore.
We will try to inform you about where your information is sent. Please be assured that we take reasonable steps to ensure compliance with the Australian Privacy Principles in relation to any offshore transfer of your information
How Can You Access And Correct Your Personal Information At Our Practice?
You have the right to request access to, and correction of, your personal information.
Our practice acknowledges patients may request access to their dental records. We ask that you put this request in writing to the practice manager via email (info@holisticdentaldonvale.com.au) or fill a request form in person and our practice will respond within a reasonable time (30 days). Fees may be charged to reimburse us for printing, preparation and postage costs.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we will ask you to verify that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and to assist us with attending to your request we would prefer you to make such requests in writing to the practice manager at info@holisticdentaldonvale.com.au.
How Can You Lodge A Privacy-Related Complaint, And How Will The Complaint Be Handled At Our Practice?
We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve your issue/s in accordance with our resolution procedure. You can email us at info@holisticdentaldonvale.com.au, write to us at 3/90 Mitcham Road Donvale VIC 3111 or call 0398426572. We will respond to your concerns within 30 days.
You may also contact the Office of the Australian Information Commissioner (OAIC). The OAIC may decide not to investigate your complaint if you have not raised it with the practice first. If you have lodged a complaint with us, and we have not responded within 30 days or you are dissatisfied with our response, you may then take your complaint to the OAIC. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992.
Privacy And Our Website
Our Internet Service Provider makes a record of your visit to our practice website and logs the following information for our reference:
- Your server addresses
- Your domain or top-level domain name (for example practice.com, .gov, .au, etc.)
- The date, time and duration of your visit to the site
- The pages you accessed, and documents downloaded
- The previous site you visited
- The type of browser you are using
- Your ISP may collect more or less information for you
This non-identified information is used to monitor usage patterns on our site in order to improve navigation and design features – helping you to get information more easily.
Our website does not provide facilities that guarantee secure transmission of information over the internet. You should be aware that there are risks in transmitting information across the internet, including online forms and email. If you are concerned about conveying sensitive or personal material to Us over the internet, contact us by telephone to discuss the matter.
Our website contains links to other websites. We are not responsible for other websites’ privacy practices, and care should be taken when providing personal information on any website.
We use cookies and industry standard analytics to collect data to help us determine which pages are most popular, peak usage times and other information that helps us make our websites easier and more efficient for you to use. This website only uses session cookies during a search query of the web site.
Upon closing your browser, the session cookie set by this website is destroyed and no personal information is maintained
