INTRODUCTION

Purpose of the Policy

This Privacy Policy outlines the commitments and obligations of Sydney Pain Clinic (“the Clinic”) in managing the personal and health information of our patients, staff, and others. The Clinic recognises the importance of privacy and is dedicated to protecting the information it holds in accordance with the Privacy and Personal Information Protection Act 1998 (PPIP Act) and the Health Records and Information Privacy Act 2002 (HRIPA) of New South Wales, Australia.

Clinic’s Commitment to Privacy

Sydney Pain Clinic is committed to providing quality healthcare in a manner that fully respects the privacy of our patients, maintains confidentiality, and safeguards the personal and health information entrusted to us. We ensure that our practices comply with the highest privacy standards and legal obligations, reflecting our dedication to privacy through transparent, responsible information handling and processing practices.

This policy applies to all operations and premises of Sydney Pain Clinic, including our locations in Potts Point, Burwood, and Chatswood.

SCOPE AND APPLICATION

Who This Policy Applies To

This Privacy Policy applies to all individuals whose personal and health information is collected, held, used, or disclosed by Sydney Pain Clinic. This includes, but is not limited to, our patients, employees, contractors, and visitors. The policy governs the actions of all staff and associates of the Clinic across our locations in Potts Point, Burwood, and Chatswood, ensuring that everyone is aware of and adheres to our privacy standards.

Types of Information Covered

The Policy covers all personal and health information handled by the Clinic. Personal information refers to any information or opinion about an identified individual, or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or recorded in a material form. Health information, a subset of personal information, pertains to information about an individual’s physical or mental health, the provision of health services, or other information collected as part of providing a health service. This includes, but is not limited to, medical records, consultation notes, diagnoses, treatment information, and personal details such as name, address, date of birth, and contact information.

COLLECTION OF PERSONAL AND HEALTH INFORMATION

Types of Information Collected

Sydney Pain Clinic collects a range of personal and health information necessary to provide our patients with comprehensive pain management care. This information includes, but is not limited to:

• Personal details such as name, address, date of birth, and contact information.
• Health information including medical history, medications, allergies, and treatment plans.
• Financial information for billing purposes, including Medicare numbers and private health insurance details.
• Emergency contact details.

Methods of Collection

The Clinic collects information through various means, always with the individual’s consent, except in specific circumstances where the law allows otherwise. These methods include:

• Directly from the patient during consultations, appointments, and treatment sessions.
• From other health service providers (with patient consent) such as referrals, medical reports, and test results.
• Through our website and digital platforms when patients interact with our services online.

Collection Notice

At or before the time (or, if that is not practicable, as soon as practicable thereafter) we collect personal or health information, Sydney Pain Clinic will provide individuals with a collection notice. This notice explains:

• The purposes for which we are collecting the information.
• How the information will be used and disclosed.
• The individual’s rights to access and correct their information.
• How to make a complaint about a breach of privacy.
• Contact details for our privacy officer.

This approach ensures transparency with our patients and complies with our legal obligations under NSW privacy legislation.

USE AND DISCLOSURE

Purpose of Use

Sydney Pain Clinic uses the personal and health information collected primarily to provide, manage, and improve our healthcare services. This includes using the information for:

• Diagnosis and treatment planning.
• Administrative purposes, such as billing and appointments.
• Quality improvement activities, training, and accreditation.
• Compliance with legal and regulatory obligations.

Conditions for Disclosure

The Clinic discloses personal and health information only under specific conditions, including:

• With the patient’s consent, either explicit or implied, for the purpose of their treatment. This may involve sharing information with other health professionals involved in the patient’s care, such as specialists, general practitioners, nurses, and allied health professionals.
• For secondary purposes closely related to the primary purpose of collection, where the patient would reasonably expect such use or disclosure (e.g., billing or administrative purposes).
• Where required or authorised by law, such as in the event of a serious health risk to the individual or public health and safety, or for the purposes of legal proceedings.

Disclosure for Healthcare Purposes

In the interest of providing comprehensive healthcare, Sydney Pain Clinic may disclose information to other healthcare providers involved in the patient’s care. This collaborative approach ensures that all healthcare professionals involved in the patient’s treatment have access to the relevant information needed to deliver the best possible care.

Before any disclosure, the Clinic ensures that:

• The patient has been informed about the potential for such disclosures in our collection notice.
• The information shared is limited to what is necessary for the purpose of the patient’s healthcare.

Privacy and confidentiality are paramount, and all disclosures are conducted securely and with respect for the privacy of our patients.

DATA QUALITY AND SECURITY

Accuracy of Information

Sydney Pain Clinic is committed to ensuring that the personal and health information it collects, uses, and discloses is accurate, complete, and up-to-date. To achieve this, we:

• Regularly review our data collection processes.
• Encourage patients to update their personal information whenever changes occur.
• Verify the information we have on file during patient check-ins or appointments.

Protection of Information

The Clinic takes the security of personal and health information seriously and has implemented robust measures to protect it from misuse, loss, unauthorised access, modification, or disclosure. These measures include:

• Secure storage of physical records in locked cabinets or secure facilities.
• Use of encrypted electronic systems with access controls to ensure that only authorised personnel can access sensitive information.
• Regular training for our staff on privacy and confidentiality principles and practices.

Data Breach Response

In the unlikely event of a data breach, Sydney Pain Clinic has a response plan in place to effectively manage and mitigate the risks associated with the breach. This plan includes:

• Immediate steps to secure the information and prevent any further breaches.
• Assessment of the breach’s impact and the potential harm to affected individuals.
• Notification to affected individuals and relevant authorities, as required by law, about the breach and advice on steps to protect their information.
• Review and strengthening of our data security measures to prevent future breaches.

Our commitment to data quality and security ensures that personal and health information is handled in a manner that respects the privacy of our patients and complies with applicable privacy laws.

ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

Access by Individuals

Sydney Pain Clinic acknowledges the right of individuals to access their personal and health information held by us, in accordance with the Health Records and Information Privacy Act 2002 (HRIPA) and the Privacy and Personal Information Protection Act 1998 (PPIP Act) of New South Wales. Patients may request access to their information by:

• Contacting the Clinic’s Privacy Officer using the contact details provided in this policy.
• Submitting a written request that specifies the information they wish to access.

The Clinic will respond to access requests within a reasonable timeframe and may charge a fee to cover the cost of retrieving and copying the requested information. Access may be denied in certain circumstances specified by law, in which case the individual will be given a reason for the decision.

Correction Process

The Clinic is committed to maintaining accurate, complete, and up-to-date personal and health information. Individuals have the right to request the correction of any information they believe is inaccurate, incomplete, or out-of-date. To request a correction, individuals should:

• Contact the Clinic’s Privacy Officer with details of the requested changes.
• Provide any supporting documentation that may be required to substantiate the request.

The Clinic will take reasonable steps to correct the information in a timely manner or, if there is a disagreement about the accuracy of the information, note the individual’s request in the records.

Anonymity and Pseudonymity

Sydney Pain Clinic acknowledges the rights of individuals to interact anonymously or under a pseudonym where it is lawful and practicable to do so. For many of our activities, the collection of personal and health information is essential to provide a high standard of healthcare. However, in situations where it does not impede the provision of our services, individuals may have the option to not identify themselves, or to use a pseudonym. Examples may include:

• Seeking general information about our services over the phone or via our website.
• Participating in patient satisfaction surveys where personal identification is not required.

It is important to note that in the context of healthcare, the ability to interact anonymously or under a pseudonym is limited due to the need for accurate patient records and the potential impact on the quality of care. Sydney Pain Clinic will inform individuals if it is possible and appropriate to interact anonymously or under a pseudonym for specific services.

OVERSEAS TRANSFERS OF PERSONAL INFORMATION

Sydney Pain Clinic is committed to protecting the privacy and security of personal and health information, including when this information is transferred overseas. The Clinic will only transfer personal information outside of Australia in circumstances where:

• The individual has provided explicit consent after being informed of the potential risks to their privacy.
• The transfer is necessary for the performance of a contract between the individual and the Clinic, or for the implementation of pre-contractual measures taken at the individual’s request.
• The transfer is necessary for important reasons of public interest, for legal claims, to protect the vital interests of the individual, or other exceptions as permitted under the Health Records and Information Privacy Act 2002 (HRIPA) and the Privacy and Personal Information Protection Act 1998 (PPIP Act).

When transferring personal information overseas, Sydney Pain Clinic takes steps to ensure that the recipient of the information adheres to privacy standards that are comparable to those upheld by the Clinic, including:

• Confirming that the recipient is subject to a law or binding scheme that offers similar protection to the information as the laws in NSW and Australia.
• Implementing contractual arrangements with the recipient to safeguard the personal information.

The Clinic also reviews the privacy practices and policies of overseas recipients regularly to ensure ongoing compliance with Australian privacy laws and standards.

COMPLAINTS AND DISPUTES

Making a Complaint

Sydney Pain Clinic is committed to maintaining the highest privacy standards and takes any complaints regarding privacy and the handling of personal information seriously. If you believe that the Clinic has breached your privacy rights or failed to comply with privacy laws, you are encouraged to contact our Privacy Officer to file a complaint. Complaints can be made by:

• Contacting the Privacy Officer directly via the contact details provided in this policy.
• Submitting a written complaint detailing the nature of the breach or concern.

Complaint Handling Process

Upon receiving a complaint, Sydney Pain Clinic will:

• Acknowledge receipt of the complaint within a reasonable timeframe.
• Investigate the circumstances surrounding the complaint, which may involve seeking further information from the complainant or relevant staff members.
• Aim to resolve complaints within 30 days of receipt. If the complaint is complex and cannot be resolved within this timeframe, we will inform the complainant of the reasons for the delay and provide an updated timeframe for resolution.
• Communicate the outcome of the investigation to the complainant, including any actions taken to resolve the issue or reasons for the decision if the complaint is not upheld.

If you are not satisfied with the outcome of your complaint, you have the right to escalate the matter to the NSW Information and Privacy Commission or the Australian Information Commissioner, depending on the nature of your complaint.

CONTACT INFORMATION

Sydney Pain Clinic is committed to protecting the privacy of individuals and encourages feedback on its privacy practices. If you have any questions, concerns, or comments about this Privacy Policy, or if you wish to access, update, or correct your personal information, make a complaint about a breach of your privacy rights, or discuss any privacy issues, please contact our Privacy Officer at:

Privacy Officer Contact Details:

• Address: 18 Roslyn Street, Potts Point 2011 NSW
• Phone: 02 8866 1393
• Email: info@sydneypainclinic.com

The Privacy Officer is responsible for ensuring that Sydney Pain Clinic complies with its privacy obligations and for dealing with inquiries and complaints about privacy matters. The Privacy Officer will endeavour to respond to all inquiries and complaints in a timely and comprehensive manner.