Introduction

This privacy policy is here to provide 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.

We are committed to protecting your personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.

This policy applies to personal information we handle about patients to our clinics, visitors to our website www.saltwatermedical.com.au, and the users of services we provide. It provides information about the personal information we collect and the ways in which we use that personal information, as well as the controls you have over the use of it. This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, “we” and “us” refers to Saltwater Medical and “you” refers to any individual about whom we collect personal information or anyone acting on their behalf or with their implied authority.

Please read this Privacy Policy carefully.

Your use of any part of our website or our services will constitute your consent to the collection, transfer, processing, storage, disclosure, and other uses of your personal information in accordance with this Privacy Policy.

If you do not provide us with all the personal information we request, medical practitioners operating from our clinic will not be able to provide medical services to you.

If you do not agree with the terms and conditions of this Privacy Policy, please do not use our websites or our medical services.

About Saltwater Medical

Our mission at Saltwater Medical is to be known by our patients, our people and our community as a general practice that truly cares. In every moment of every day, we want to be known for our compassion, expertise, and our extraordinary patient care.

Our values are positivity, kindness, teamwork, integrity, professional excellence, and sustainability.

These values guide our actions and our decisions in every facet of our business. Alignment with them plays a leading role when selecting our staff and when entering into the service contracts we have with the independent medical practitioners who consult with patients from our practice. We want our Independent Medical Practitioners and our support team to be people you know and trust, and we want to provide patients with exceptional healthcare without compromise.

The Independent Medical Practitioners consulting from our clinic and our employees are committed to providing you with personalised healthcare and offer comprehensive, expert, and highly regulated, evidence-based health services.

Our practice is genuinely committed to delivering high quality, personal and trusted care to our valued patients and we are nationally accredited by AGPAL as being compliant with the standards set down by the Royal Australian College of General Practitioners.

Why do we collect, use, hold and share your personal information?

Saltwater Medical will need to collect your personal information to provide quality healthcare services to you and it will be treated as sensitive information. Our main purpose for collecting, using, holding, and sharing your personal information is to manage your health.

When you register as a patient of Saltwater Medical, you provide consent for our independent GPs and practice staff to access and use your personal information so they can provide you with the best possible healthcare. Only doctors and 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 seek additional consent from you to do this.

What personal information do we collect?

When you become a patient of a GP consulting from Saltwater Medical, a patient record is made which includes personal information such as your name, address, date of birth, contact details and emergency contact details.

Generally, health information we collect about you includes:

  • your previous and current medical history (including, where clinically relevant, a family medical history) and details of treatment and health services you have received.
  • medical practitioner consultation notes
  • medications you take
  • information about other healthcare professionals and health service providers who are involved in your care
  • information about your healthcare preferences and wishes
  • family contact information, custody arrangements, your attorney, guardians, or other persons responsible for your healthcare decisions

Saltwater Medical may also collect information relevant to administering your payment arrangements such as your banking and credit card details, your pension and concession entitlements and any other relevant information.

Where it is relevant to administering your payment arrangements, we will collect information such as your Medicare number, private health care provider, DVA, pension, student or health care card number and your entitlement to benefits. Where we have collected a government related identifier (such as your Medicare number), we will not adopt that identifier as our own identifier and we will only use or disclose that identifier as required or permitted by law.

Saltwater Medical may also collect other personal information about you which is considered sensitive information, such as information about racial / ethnic origin, sexuality, gender, health conditions where this is relevant to the services we provide.

We also use your information for directly related business activities, such as financial claims and payments, practice audits and accreditation, communication and business processes (e.g. staff training).

When you make appointments, enquire about personal medical information we hold, or check in at your appointments, we will ask you to identify yourself using your name, email, address and/or date of birth. This is required to ensure we have your correct file as some patients share the same names and birthdays.

Dealing with us anonymously

You have the option of not identifying yourself, or using a pseudonym, when dealing with Saltwater Medical (for example, when making a general enquiry). However, it is not practicable for Saltwater Medical to deal with you anonymously or pseudonymously as a patient of Saltwater Medical.

How do we collect your personal information?

Saltwater Medical will, where practicable, collect information from you when:

  • you register as a new patient of a GP consulting at our practice and complete and submit documentation;
  • you communicate with us via email, telephone, SMS, our websites or social media or make an online appointment;
  • you interact with our website;
  • you communicate with medical practitioners consulting at our clinic, or staff or representatives during the course of our providing services (including information collected through electronic transfer of prescriptions (eTP), MyHealth Record / PCEHR system, for example via Shared Health Summary or Event Summary);
  • you otherwise deal with us during the course of our business.

We may also need to collect or share information from/with other sources such as treating specialists, radiologists, pathologists, hospitals, other health care providers, and the MyHealth record system and other third parties including:

  • other healthcare professionals and health service providers involved in your care
  • government agencies responsible for administering relevant entitlements and benefits (such as Centrelink, Medicare, Department of Social Services, National Disability Insurance Agency, Department of Veterans Affairs, and other government agencies responsible for home care services);

We may also collect information about you from your family members, a carer, an attorney, a guardian, or a person responsible for your healthcare decisions. If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you with the services you are seeking.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is outlined in this policy.

When, why and with whom do we share your personal information?

There are circumstances where we may be permitted or required by law to disclose your personal information to third parties. For example, to Medicare, Police, insurers, solicitors, government regulatory bodies, tribunals, courts of law, hospitals, debt collection agents, the electronic transfer of prescriptions service or to the MyHealth record system.

It may also be shared with other healthcare professionals involved in your care and other persons involved in your care.

Generally, this will only happen with your express consent and in ways you would reasonably expect. For example, Saltwater Medical may disclose your personal information to your GP or to a medical specialist involved in your care; to a hospital or aged care facility if you are referred for respite or higher levels of care; or to other healthcare professionals who are involved in your care such as nurses, occupational therapists, pharmacists, physiotherapists, podiatrists, dentists and the ambulance service.

We sometimes share your personal information:

  • In an emergency, we may provide personal information to other healthcare professionals and health services without your consent
  • We may do so to lessen or prevent a serious threat to public health and safety or it is impractical to obtain your consent
  • To assist in locating a missing person
  • To establish, exercise or defend an equitable claim
  • For a confidential dispute resolution process
  • When there is a statutory requirement to share certain personal information (e.g. some diseases require mandatory notification)
  • during the course of providing medical services, through eTP, My Health Record (e.g. via Shared Health Summary, Event Summary).
  • With third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers

Only people who need to access your information will be able to do so. Other than while providing medical 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 consent which we capture when you register as a patient. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.

Administration and management

Saltwater Medical will also use and disclose your personal information for a range of administrative, management and operational purposes.

This includes:

  • administering billing and payments and debt recovery;
  • liaising with, and reporting to, government agencies in the administration of particular funding programs;
  • administering subsidies and benefits to which you may be entitled from government agencies and other third-party payers (such as Centrelink, Medicare, Department of Social Services, Department of Veterans Affairs, and other government agencies responsible for primary care services);
  • planning, managing, measuring and monitoring and evaluating our services;
  • safety and quality assurance and improvement activities;
  • statistical analysis and reporting;
  • training staff, contractors and other workers;
  • risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
  • responding to enquiries and complaints regarding services provided to patients;
  • obtaining advice from consultants and other professional advisers; and
  • responding to subpoenas and other legal orders and obligations.

How do we store and protect your personal information?

  • Your personal information may be stored at our practice in various forms including: paper records, electronic records, visual records (X-rays, CT scans, videos and photos), audio recordings.
  • Our practice stores all personal information securely in protected information systems or in hard copy format in a secured environment.
  • We use passwords, secure cabinets, and ensure all staff and contractors with access to your records sign confidentiality and privacy agreements.

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 medical records. We require you to put this request in writing addressed to The Privacy Officer, Saltwater Medical, 7 Fourth Avenue, Caloundra, QLD 4551 and we will take steps to verify your identity. Our practice will respond within 30 days to all requests for access to medical records and may charge a fee to cover the doctors’ time and administrative cost of providing these records to you for your private use.

Costs may vary for legal or insurance purposes.

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. We ask that you also keep your information up to date should any details change, including address, phone and concession card entitlements.

You may also request that we correct or update your information, and you should make such requests to our administration team or in writing to The Practice Manager, Saltwater Medical, 7 Fourth Avenue, Caloundra, QLD, 4551.

How long will Saltwater Medical hold your personal information?

Saltwater Medical will hold your personal information until it is no longer needed. Generally, if you are a patient, your personal information will be held for a minimum of 7 years from the date of last entry in your record (in the case of children, the record is kept until the patient attains or would have attained 25 years of age). This complies with Saltwater Medical’s legal requirements to maintain such records. Full Medical records can be transferred to an alternate practitioner outside Saltwater Medical. A fee may apply. Please contact us directly for details. Information that is no longer needed will be securely destroyed or de-identified.

How is your personal information handled on our websites?

You may visit our websites (such as www.saltwatermedical.com.au) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Saltwater Medical will be managed in accordance with this Privacy Policy.

Saltwater Medical websites use cookies. A ‘cookie’ is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you accessed on our website and on third-party websites. You are not identifiable from such information. Saltwater Medical uses third-party services (such as Google Analytics) to undertake demographic analysis of visitors to our website. From time to time we may contact you for feedback and also for the purpose of reminding you of required appointments e.g. annual check-ups.

You may refuse to accept cookies by selecting the appropriate setting on your internet browser but if you do this you may not be able to use the full functionality of our website. Users of our website and social media pages are encouraged against sending personal information via the internet.

For your convenience and to improve the usage of the website and services we may insert links to third-party websites, applications or resources, for which this Privacy Policy does not apply.

Saltwater Medical is not responsible for those third-party websites, applications or resources. If you access such websites, applications or resources, you do so at your own risk and we make no representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy statements/policies of every website, application or resource you use. When we do link to a third-party website, application or resource, this does not automatically imply that Saltwater Medical endorses that website, application, resource and their contents. Our Privacy Policy does not cover the use of cookies by any third parties.

How can you lodge a privacy-related complaint, and how will the complaint be handled?

At Saltwater Medical, we take complaints and concerns regarding privacy seriously.

You may contact Saltwater Medical at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled including the collection, use, disposal, or destruction of your personal information. If you have a complaint about the privacy of your personal information (including complaints about our use of the MyHealth record system), we request that you contact us in writing.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

Attention: Privacy Officer, Saltwater Medical
7 Fourth Ave
Caloundra QLD 4551

The Privacy Officer will first consider your complaint to see if there are simple or immediate steps which can be taken to resolve the issue. We will generally respond within 14 days. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, you are entitled to make a complaint to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

Policy review statement

This privacy policy was last reviewed February 2024 and will be reviewed as needed to ensure it is in accordance with any changes that may occur either in law or changes to our operations. Any information we hold about you will be governed by our current policy which will be published on our website. We recommend you review this page periodically.