Privacy Policy

Privacy Commitment

Frontier Dermatology is committed to protecting the privacy of patient information and to handling personal information in a responsible manner. This Privacy Policy represents how Frontier Dermatology manages your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act). Our Privacy Policy seeks to safeguard the privacy of your personal information in accordance with the Australian Privacy Principles (APPs) contained within the Privacy Act.

In this Privacy Policy, “we” and “us” refers to Lamrock and Thornton Pty Ltd ACN 642 841 067 ATF Frontier Dermatology and “you” refers to any person about whom we collect personal information.

1. Overview, purpose, and terms

‍When you first register as a patient, our Patient Registration or Privacy Consent form requests your consent so that we can collect, use, hold and share your personal information. This enables us to provide you with the best possible healthcare and to allow us to manage our practice. If we intend to use your personal information for any other purpose, we will seek your consent first.

This privacy policy explains:
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o  How we manage your personal information(including your health information), containing the collection, use, disclosure, quality, and security of your personal information.
o  The kinds of information we collect and how that information is held.
o  The purposes for which we collect, hold, use, and disclose personal information.
o  How you can access your personal information and how you can request to correct such information; and
o  How you can complain about a breach of your privacy and how we will handle your complaint.

If you have any queries, concerns, or feedback regarding our Privacy Policy, please do not hesitate to contact us:

Ph: (02) 4022 8739
Email: reception@frontierdermatology.com.au
Post: 294 Charlestown Road, Charlestown, NSW, 2290.

In this Privacy Policy, we use the terms:

"Personal information" as defined in the Privacy Act. This means: "information or an opinion about an identified individual, or an individual who is reasonably identifiable:

o   Whether the information or opinion is true or not; and
o   Whether the information or opinion is recorded in a material form or not.

The kinds of personal information and data that may be collected includes but is not limited to your:
o   Full name.
o   Residential address.
o   Date of birth.
o   Full name and contact details of family members and/or associates.
o   Financial information; and
o   Any other information necessary for the purposes of carrying out our services/functions.

Personal information also includes ‘Sensitive information’ which is a subset of personal information and includes information or an opinion about an individual’s race, religion, political or trade association, sexual preferences, criminal record, or health information about an individual.

Information which is “sensitive information” attracts a higher privacy standard under the Privacy Act and is subject to additional mechanisms for your protection.

“Health information" as defined in the Privacy Act. This is a subset of "personal information" and means information or an opinion about:

o   About an individual’s health or disability at any time (that is, past, present or future).
o   About an individual’s expressed wishes regarding future health services.
o   About health services provided, or to be provided, to the individual.
o   Collected while providing a health service; and
o   Collected in connection with the donation or intended donation of body parts and substances.

This means that personal details related to an individual’s attendance with a health services provider (e.g., name, address, Medicare number, billing information), medical information, notes made by healthcare personnel, identifiable biological specimens or samples, or genetic information all constitute “health information”.

We, Us, Our, shall mean:

1. Frontier Dermatology
2. Employed, contracted and independent medical and healthcare practitioners who practice from our rooms.

Frontier Dermatology is a private medical practice that specialises in dermatology. We provide facilities, management, administrative, and nursing services to independent medical/healthcare practitioners who run their own independent business from our practice. These practitioners have agreed to fall under and abide by our Privacy Policy and framework.

2. Collection of personal information

‍Frontier Dermatology collects information which is necessary to provide you with healthcare services and to appropriately manage and conduct our business. This includes collecting personal information such as your name and contact details, medical history, family history, past and current treatments, lifestyle factors and any other information which is necessary to assist us in providing you appropriate care. We will also collect your Medicare number and health fund details (where applicable). We require you to provide us with your personal details and a full medical history so that we may properly assess, diagnose, and treat illnesses and be proactive in your health care, as well as manage the practice.

Frontier Dermatology will usually collect your personal information directly from you, including patient consent forms, medical records, and consultations with you, or from another health service provider.

Sometimes we need to collect information about you from third parties where the Privacy Act or other law allows it - this may include, but is not limited to: relatives, friends, and other people responsible for you, other members of your treating team, diagnostic centres, specialists, hospitals, the My Health Record system, electronic prescription services, Medicare, your private health insurer, and the Pharmaceutical Benefits Scheme.

We will only collect information from third parties where:

o   You have consented to such collection; or
o   Such collection is necessary to enable us to provide you with appropriate healthcare services (such as emergency medical treatment or where your health is at risk);
o   Such collection is reasonably necessary to enable us to appropriately manage and conduct our business; or
o   It is legally permissible for us to do.

We collect information in various ways such as over the phone or in writing, in person when you attend the practice or over the internet. This information may be collected by medical or non-medical staff. In emergency situations we may also need to collect information about you from your relatives or friends.

Collection of information requires your consent. You are not obliged to provide the information requested but failure to do so might compromise the quality of health care and treatment. 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. It is important to be aware that if you provide incomplete or inaccurate information or withhold information, we may not be able to provide you with healthcare services.

This practice will not use or disclose personal information for the purposes of direct marketing by this practice or any other party.

Medical photography

We may need to take photographs of your skin condition for inclusion in the medical record. As clinical photographs are a part of the medical record they cannot be deleted.

As part of the medical record, clinical photographs may be sent with other written communication to other treating doctors. Your verbal permission will be sought if the photograph is to be sent electronically to other health professionals. Your written permission will be sought if photographs are to be used for any other purpose such as teaching or publication.

3. How we use your personal information

‍In general, Frontier Dermatology will collect, hold, use, and disclose your personal information for the following purposes:

o   To provide health services to you
o   To communicate with you in relation to the health service being provided to you
o   To comply with our legal obligations, including, but not limited to, mandatory notification of communicable diseases or mandatory reporting under applicable child protection legislation.
o   To help us manage our accounts and administrative services, including billing, arrangements with health funds, pursuing unpaid accounts, management of our ITC systems
o   For consultations with other doctors and allied health professional involved in your healthcare.
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•   Including treating doctors and specialists outside this medical practice. This may also include allied health professionals, and institutions such as hospitals. This may occur through referral to other doctors, or for medical tests and in the reports or results returned to us following the referrals. This may occur verbally, in writing or electronically (by email or SMS).
•   Disclosure to other doctors working at the practice, locums, and by Registrars and medical students attached to the practice for the purpose of patient care and teaching. Please inform us if you do not want your records accessed for these purposes.

o   To obtain, analyse and discuss test results from diagnostic and pathology laboratories
o   For identification and insurance claiming
o   If you have a My Health Record, to upload your personal information to, and download your personal information from, the My Health Record system.
o   To liaise with your health fund, government, and regulatory bodies such as Medicare, the Department of Veteran's Affairs, and the Office of the Australian Information Commissioner (OAIC) (if you make a privacy complaint to the OAIC), as necessary.

The practice will treat your personal information as strictly private and confidential. Information will only be used or disclosed for purposes directly related to your care and treatment, or in ways that you would reasonably expect that we may use it for your ongoing care and treatment.

Frontier Dermatology only uses your personal information to provide you with healthcareservices or to enable us to appropriately manage and conduct our business, unless:

o   There is a secondary purpose which directly relates to the primary purpose, and you would reasonably expect, or Frontier Dermatology has informed you, that your information will be used for that secondary purpose, or you have given your consent for your personal information to be used for a secondary purpose.
o   The disclosure of your information is necessary for the enforcement of criminal law or a law imposing a penalty or sanction, or for the protection of public revenue.
o   The disclosure of your information will prevent or lessen a serious and imminent threat to somebody's life or health; or,
o   Frontier Dermatology is required or authorised by law to disclose your information for another purpose.

Information collected may be stored on our computer medical records system and in some cases in hand-written medical records. Personal information that we hold is protected by securing our premises and by placing passwords and varying access levels on databases to limit access and protect electronic information from unauthorized interference, access, modification, and disclosure.

4. Disclosing your personal information

‍Frontier Dermatology may disclose your personal information to our employees, contractors, and service providers for us to provide healthcare services to you and to allow us to manage our business. We will also disclose your personal information to healthcare professionals directly involved in your treatment. Where your medical records are required in the case of a medical emergency, we will provide these to the relevant medical professional without waiting for your consent, where we believe this is in your interests.

Your personal information may also be provided to third parties if we are legally obliged to do so by a court subpoena, statutory authority, search warrant, coronial summons or to defend a legal action.

We may provide your personal information to third parties involved in your care, such as:

o   Your parents, children, relatives and close friends, guardians or a person exercising a power of attorney or enduring power of attorney. Please advise us if it is your wish no third party as stated is to have access to your personal information.
o   Government departments and agencies, such as Defence or Department of Veterans Affairs, or departments responsible for health, aged care, and disability where we are required to do so.
o   Private health insurers and Medicare Australia.
o   Anyone authorised by you to receive your personal information

Frontier Dermatology engages the following third-party service providers who assist us in delivering our services to you:
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o   Xestro electronic medical record system https://xestro.com/privacy.html
‍o   Medical Objects secure messaging system https://www.medicalobjects.com/privacy/
‍o   HealthLink secure messaging system https://au.healthlink.net/privacy-policy/

We may undertake and participate in research studies. We will always request your written permission to be involved in such research before we release any personal information to third party researchers.

5. Overseas recipients

Frontier Dermatology does not engage with any overseas entities or persons where your personal information will be transferred, stored, or disclosed. Should we wish to transfer your personal information overseas, for example to international experts, we will ask for your consent before we do so.

6. Data storage, quality, and security

‍We strive to maintain the reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security. All personal information, whether stored as a hard copy or in electronic form is protected from unauthorised access, misuse, interference, loss, modification, or disclosure. Some of the steps we take to ensure your personal information is secure include:

o   We maintain physical security over our paper and electronic data and premises
o   Access to personal information is restricted on a ‘need to know basis’
o   Our staff are trained on privacy, and we have detailed internal processes and systems to protect your privacy
o   Our staff sign confidentiality agreements
o   Holding your information on an encrypted database
o   Holding your information in secure cloud storage
o   Our practice has document retention and destruction policies (destroy and de-identify data when it is no longer required
o   We conduct regular risk management reviews
o   Implement firewalls and virus scanning tools to stop viruses and unauthorised access to our systems.

Our website and email are linked to the internet. We do use an end-to-end encrypted email provider, however, no data transfer over the internet is 100% secure. Accordingly, any information which you transmit to us online or via email is transmitted at your own risk. A record of email communication will be stored in your medical file.

7. Destroying your personal information

‍Subject to applicable laws, Frontier Dermatology may destroy records containing personal information when the record is no longer required by Frontier Dermatology.

It is likely your medical records held by us contain sensitive information. We are required to abide by relevant legislation in the retention and disposal of your medical records.

8. Accessing and amending your personal information

‍We encourage you to contact us if you have a query regarding your personal information. You may request an amendment to your personal information if you consider that it contains inaccurate, incorrect, or incomplete information.

You have a right to request access to any information we hold about you. If you make a request to access personal information that you are entitled to access, we will provide you suitable means of accessing it. We will not charge you for making the request. In circumstances where you request, we provide a copy of your personal information to you, we may charge you a fee to cover our reasonable costs for complying with the request for access.

You may be asked to submit your request in writing and for information that identifies you to satisfy Frontier Dermatology that a request for personal information. If so, include:
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a)     Name and contact details.
b)    The personal information you want to access.
c)     How you’d like access to the personal information (such as receiving a copy by email or post, or if you just want to look at the information); and
d)    If you authorise a person or organisation to access the personal information on your behalf.

There may be instances where we cannot grant you access to some of the information we hold. There are certain circumstances where Frontier Dermatology can deny access to personal information - for example where giving access would have adverse and unreasonable implications on the privacy of others, where granting access is unlawful or where denying access is required by law.

If Frontier Dermatology refuses an individual’s access or correction request, Frontier Dermatology will provide written reasons for the refusal, including information to complain about the refusal.

Frontier Dermatology reserves the right to change its guidelines for providing access.

You can contact us about any privacy issues as follows:

Ph: (02) 4022 8739.
Email: reception@frontierdermatology.com.au
Post: 294 Charlestown Road, Charlestown, NSW, 2290.

9. Participation in research and clinical trials

‍Frontier Dermatology may participate in medical research and clinical trials. Clinical trial activity undergoes approval by an Ethics Committee.

We will always request your permission to be involved in such research before we release any personal information to third party researchers. Your clinician will explain the purpose of the research or trial and ask that you sign a consent form before you can participate.
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We may use your de-identified health information for research and audit purposes, to improve diagnosis and treatment of melanoma and related conditions.

10. Telehealth Consultations

‍Some appointments may be conducted as a Telehealth consultation using videoconferencing platforms on which your cybersecurity cannot be guaranteed. Sometimes is carried out with another practitioner or nursing staff member present during the consultation. Your verbal consent will be obtained prior to arranging a Telehealth consultation.

11. Complaints

‍If you are unsatisfied with the way we have dealt with your personal information, you may make a complaint by emailing us at reception@frontierdermatology.com.au. When you make a complaint, you should:

a)     Identify yourself.
b)    Provide a contact address and a contact phone number.
c)     Provide a brief description of the matter and why you think Frontier Dermatology has mishandled your personal information.
d)    Let us know what you would like us to do to resolve the matter.

We will, within fourteen days, respond to you and attempt to resolve with you your issues as they relate to your personal information.

If you are still unsatisfied, you may wish to direct your complaint to the OAIC. The OAIC accepts written complaints via its privacy complaint form or via email. Please refer to the OAIC’s website for further information concerning how to lodge a privacy complaint: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a- privacy-complaint-with-us/.

You may also send your complaint to the OAIC by:

Emailing your complaint to enquiries@oaic.gov.au
Sending a letter to by post to: Director of Privacy Case Management GPO Box 5218 Sydney NSW 2001
Faxing your complaint to (02) 9284 9666

12. Review and change to Privacy Policy

‍We may alter this Privacy Policy following any legislative change or upon a review of our information handling processes.

The current version of our updated Privacy Policy is available from:
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o   Frontier Dermatology 294 Charlestown Road, Charlestown, NSW, 2290.
o   Our website – www.frontierdermatology.com.au
o   By contacting reception on (02) 4022 8739.

13. Relevant information when using our website:

‍Use of cookies

A 'cookie' is a small data file placed on your machine or device which lets us identify and interact more effectively with your computer. Cookies are used by many websites, including those operated by us. Cookies can facilitate a user’s ongoing access to and use of a website. Cookies allow us to customise our website to the needs of our users. If you do not want information collected using 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 website.

Links to other sites

Our website may provide links to third party websites. These linked sites are not under our control, and we are 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 website.
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Collection of non-identifiable information

We may also collect some information that is not personal information because it does not identify you. For example, we may collect anonymous answers to surveys or aggregated information about how our website is used.

Communications

We may contact you directly or send you communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, phone, and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will use that method of communication. In addition, at any time you may opt-out of receiving communications from us by contacting us (see the details below) or by using opt-out facilities provided in the communication and we will the ensure that your name is removed from our mailing list. We will not provide your personal information to other organisations for the purposes of such communications.

This Privacy Policy may be amended or revised at any time. The revised Privacy Policy will take effect when it is uploaded on our website. This Privacy Policy represents the latest version of the Privacy Policy.

More information about the privacy provisions can be obtained by calling the Office of the Information Commissioner (OIC) on (07) 3234 7373 or 1800 642 753 or by visiting www.oaic.gov.au.