The Skin & Cancer Foundation Australia trading as The Skin Hospital (the Hospital) upholds the confidentiality of information and the privacy of individuals, including The Skin Hospital’s patients. The Hospital is committed to ensuring the privacy of personal information that is provided to us.
- To set out the scope of the Hospital’s commitment in relation to privacy;
- To provide a clear expression of how personal information will be managed by the Hospital.
- the kinds of information that The Skin Hospital may collect about you and how that information is held;
- how the Hospital collects and holds personal information;
- the purposes for which The Skin Hospital collects, holds, uses and discloses personal information;
- how you can access the personal information the Hospital 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 the Hospital will handle that complaint.
Health information is:
- personal information or an opinion about:
- an individual’s physical or mental health or disability (at any time);
- an individual’s express wishes about the future provision of health services for themselves; or
- a health service provided, or to be provided, to an individual;
Other personal information collected to provide, or in providing, a health service;
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not;
Sensitive information means:
- personal information or opinion about an individual’s:
- racial or ethnic origins;
- political opinions or political associations;
- philosophical beliefs or religious beliefs or affiliations;
- sexual preferences or practices; or
- criminal record; or
- health information about an individual.
All staff at The Skin Hospital are responsible for ensuring that this policy and the Australian Privacy Principles (APPs) are complied with.
7.1 Collection and use of personal information – Types of personal information collected by the Hospital.
The Skin Hospital will only collect information which is necessary to facilitate the provision to you of health care services by a member of the Hospital or to appropriately manage, conduct and oversee The Skin Hospital’s businesses. This may include (as applicable):
- Patients/clients/research participants: The Hospital collects information from you to facilitate the provision of health care services to you by members of the Hospital 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.
- VMOs, students, contractors and volunteers: The Skin Hospital collects information from you which is necessary to properly conduct, manage and oversee the Hospital’s businesses. 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, manage and oversee The Skin Hospital’s businesses.
- Job applicants: The Hospital collects information from you, which is necessary to assess and engage job 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.
- Donors: Where you have consented, The Skin Hospital collects information from you for the purposes of fundraising for The Skin Hospital including agreeing the terms of and managing any donations you agree to make. This includes collecting personal information such as your name and address.
7.2 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:
- Another health service provider;
- Past employers and referees; or
- Related entities (being those listed in the annexure).
We will only collect information from third parties where:
- You have consented to such collection;
- Such collection is necessary to enable us to facilitate the provision of appropriate health care services by a member of The Skin Hospital;
- Such collection is reasonably necessary to enable us to appropriately manage, conduct and oversee the Hospital’s businesses; or
- It is legally permissible for us to do.
7.3 How The Skin Hospital uses your personal information
The Hospital only uses your personal information for the purpose for which it was collected by the Hospital (primary purpose), unless:
- There is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or The Skin Hospital has informed you, that your information will be used for that secondary purpose;
- You have given your consent for your personal information to be used for a secondary purpose; or
- The Skin Hospital is required or authorised by law to use your personal information for a secondary purpose (including for research and quality improvements within the Hospital).
For example, the Hospital may use your personal information to:
- Facilitate the provision of health care services to you by a member of The Skin Hospital;
- Facilitate the provision of any ongoing health related services to you;
- Appropriately manage, conduct and oversee The Skin Hospital’s businesses, such as assessing insurance requirements, conducting audits, and undertaking accreditation processes;
- Assist the Hospital to manage, conduct and oversee the Hospital’s businesses, including quality assurance programs, billing, improving its services, implementing appropriate security measures, conducting research and training personnel;
- Where required, effectively communicate with third parties, including Medicare Australia, private health insurers and Department of Veterans’ Affairs; and Carry out fundraising activities (where you have consented).
7.4 Complete and accurate details (Anonymity & Pseudonimity)
Where possible and practicable, you will have the option to deal with The Skin Hospital 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 assistance or support you are seeking, or deal with you effectively.
7.5 Disclosing your personal information
The Skin Hospital will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to facilitate the provision of health care services to you by a member of the Hospital, to help us manage, conduct and oversee the Hospital’s businesses, or for security reasons. We may provide your personal information to:
- Medical and other healthcare professionals involved in your care;
- Government agencies, such as defence or department of veterans affairs, where an individual is receiving services with a member of The Skin Hospital under arrangements with those agencies;
- Government departments responsible for health, aged care and disability where the Hospital is required to do so;
- Third parties contracted to provide services to The Skin Hospital, such as entities contracted to assist in accreditation or survey processes;
- Research institutions with which the Hospital collaborates;
- Private health insurance providers including Department of Veteran Affairs and Medicare Australia;
- Anyone authorised by you to receive your personal information (your consent may be express or implied);
- Fundraising institutions associated with The Skin Hospital (where you have consented);
- Anyone the Hospital is required by law to disclose your personal information to.
7.6 Third party service providers
Where we engage third party service providers, we may disclose personal information to those service providers who may use, process and/or store that information locally. The Skin Hospital’s IT is very particular about ensuring that all third party service providers have servers located in Australia.
7.7 Data storage, quality and security
- Data quality – the Hospital will take reasonable steps to ensure that your personal information which is collected, used, or disclosed is accurate, complete and up to date.
- Storage – all your personal information held by The Skin Hospital is stored securely in either hard copy or electronic form.
- Data security – the Hospital strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. The Skin Hospital reviews and updates (where necessary) its security measures in light of current technologies.
- Online transfer of information – while the Hospital 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 The Skin Hospital via an online process, it is at your own risk. There are ways you can help maintain the privacy of your personal information, including:
- always closing your browser when you have finished your user session;
- always ensuring others cannot access your personal information and emails if you use a public computer; and
- never disclosing your user name and password to third parties.
7.9 Links to other sites
The Skin Hospital may provide links to third party websites. These linked sites may not be under our control and the Hospital 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.
7.10 Accessing and amending your personal information
You have a right to access your personal information which The Skin Hospital 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 the Hospital about any privacy issues as follows: Chief Executive Officer or the Privacy Officer. While The Skin Hospital aims to meet all requests for access to personal information, in a small number of cases and where permitted to do so by law, The Skin Hospital may not give access or may do so only under conditions. Subject to applicable laws, the Hospital may destroy records containing personal information when the record is no longer required by the Hospital.
If you have a complaint about The Skin Hospital’s information handling practices or consider we have breached your privacy, you can lodge a complaint with:
- The Skin Hospital’s Chief Executive Officer or Privacy Officer by telephoning on 02 8651 2000; or
- The Office of the Australian Information Commissioner.
The Skin Hospital deals with all complaints in a fair and efficient manner.
The Skin Hospital deals with all complaints in a fair and efficient manner.