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APP PRIVACY POLICY for HealthFit Coaching Exercise Physiology – How We Manage Your Personal Information

1. POLICY

HealthFit Coaching and all staff and contractors are committed to protecting the privacy of our clients. Information collected is kept strictly confidential and used only for client healthcare.

2. POLICY PURPOSE

To ensure all clients who receive advice from HealthFit Coaching are comfortable sharing and entrusting their health information to the practice. This policy provides information about how your personal information is collected and used within the practice and the circumstances in which we may disclose it to third parties.

3. SCOPE

This policy applies to all staff, contractors, and clients of HealthFit Coaching.

4. PRIVACY POLICY PROCEDURES

HealthFit Coaching will:

  • Provide a copy of this policy upon request
  • Ensure all staff and contractors comply with the APP and deal appropriately with inquiries or client concerns
  • Take reasonable steps to implement practices, procedures, and systems to ensure compliance with the APP and deal with inquiries or complaints
  • Collect personal information for the primary purpose of managing client healthcare and for financial claims and payments

Staff and Contractor Responsibility

Staff and contractors will take reasonable steps to ensure clients understand:

  • What information has been and is being collected
  • Why the information is being collected and whether this is due to a legal requirement
  • How the information will be used or disclosed
  • Why and when their consent is necessary
  • HealthFit Coaching’s procedures for access and correction of information, and procedures for responding to complaints of information breaches, including by providing this policy

Client Consent

HealthFit Coaching will only interpret and apply a client’s consent for the primary purpose for which it was provided. If the practice wishes to use collected information for any additional purpose, we will seek additional client consent prior to doing so.

5. COLLECTION, USE, AND DISCLOSURE

HealthFit Coaching recognises that the information we collect is often of a highly sensitive nature. As an organisation, we have adopted privacy compliance standards based on the Australian Privacy Principles to ensure your personal information is protected.

To ensure quality and continuity of care, your personal information may be shared with additional medical and allied health practitioners, and with third parties for administrative and billing purposes.

Collected personal information will include client:

  • Names, addresses, and contact details
  • Medicare number for identification and claiming purposes
  • Healthcare identifiers
  • Medical information including health and medical history, medications, lifestyle and social history, and risk factors

Personal information may be held at the practice in various forms:

  • As electronic records
  • As visuals ie x-rays, CT or MRI scans, videos, photos

The practice’s procedures for collecting personal information is set out below:

  • Staff or contractors collect client personal and demographic information via intake forms when clients book an initial consultation. Please review the associated Information Collection Statement.
  • During the course of providing health care services, staff or contractors will collect further personal information.
  • Personal information may also be collected from the client’s guardian or responsible person (where practicable and necessary), or from other involved health care specialists.

The practice holds all personal information securely, whether in electronic format, in protected information systems or in hard copy in a secured environment.

Personal information collected by HealthFit Coaching may be used or disclosed in the following instances:

  • Necessary to lessen or prevent a serious threat to a client’s life, health or safety, or public health or safety, or it is impracticable to obtain patient’s consent
  • For the purpose the client was advised of during consult with the treating allied healthcare provider
  • As required during the normal operation of services provided. i.e. for referral to a medical specialist or other health care provider
  • For the purpose of a confidential dispute resolution process
  • Some disclosure may occur to third parties engaged by or for the practice for the practice for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy.

The practice will not disclose personal information to any third party other than in the course of providing health care services or collecting payment, without full disclosure to the client or the recipient the reason for the information transfer and full consent from the client.

The practice will not disclose personal information to anyone outside Australia without need and without client consent.

The practice will not use any personal information in relation to direct marketing to a client without that client’s express consent.

The practice evaluates all unsolicited information it receives to decide if it should be kept, acted upon, or destroyed.

HealthFit Coaching will employ all reasonable endeavours to ensure that a client’s personal information is not disclosed without their prior consent.

6. DATA QUALITY

Client personal information collected and retained in our records for the purpose of providing quality health care will be complete, accurate, and up to date at the time of collection.

7. DATA SECURITY

All due care will be taken to ensure the protection of client privacy during the transfer, storage, and use of personal information.

8. ACCESS TO CLIENT INFORMATION AND CORRECTION

The following will apply with regard to accessing private personal information by an individual:

  • An individual has the right to request access their own personal information and request a copy or part of the whole record.
  • Individuals have the right to obtain their personal information in accordance with the Federal Privacy Act from 1 January 2019 onwards. Requests must be made in writing and an acknowledgement letter will be sent to the client within 14 days, confirming the request and detailing whether the request can be complied with and an indication of any costs associated with providing the information. Time spent and photocopying costs when processing a request can be passed on to the requesting client. Information can be expected to be provided within 30 days.
  • Requests for information prior to 1 January 2019 will be considered by the practice.
  • Whilst the individual is not required to give a reason for obtaining the information, a client may be asked to clarify the scope of the request.
  • In some instances the request to obtain information may be denied. In these instances the client will be advised.
  • The material over which a health care provider has copyright might be subject to conditions that prevent or restrict further copying or publication without the provider’s permission.
  • The practice will take reasonable steps to correct personal information where it is satisfied it is not accurate or up to date. From time to time the practice will ask clients to verify that the personal information held by the practice is correct and up to date.
  • Clients may also request in writing that the practice corrects or updates their information.
  • Upon client request, the information held by this practice will be made available to another health care provider.

9. COMPLAINTS

HealthFit Coaching understands the importance of confidentiality and discretion in the way we manage and maintain client personal information. The practice takes complaints and concerns about the privacy of personal information seriously. Clients should express any privacy concerns in writing. The practice will then attempt to resolve it in accordance with its complaint resolution process.

All staff and contractors of HealthFit Coaching are required to observe the obligations of confidentiality in the course of their work with the practice, and are required to sign Confidentiality Agreements.

If you are dissatisfied with the level of service provided, we encourage you to discuss any concerns relating to the privacy of your information with your health care provider or the practice principal.

If the complaint has not been resolved to your level of satisfaction all complaints should be directed to:

The Federal Privacy Commissioner
Level 8 Piccadilly Tower
133 Castlereagh Street
Sydney NSW 2000

Privacy Hotline: 1300 363 992

10. REVIEW DATE

January 2019