Complete Children’s Health Privacy Policy

This privacy policy is to provide information to you and to primary caregivers for patients who are minors, on how your personal information (which includes your health information) is collected and used within our practice, Moonee Valley Paediatrics Pty Ltd ACN 131 425 280 As Trustee For Moonee Valley Paediatrics Unit Trust (Complete Children’s Health) and the circumstances in which we may share it with third parties.

Why and when your consent is necessary

When you register as a patient of a practitioner who consults from our practice, you provide consent for us (including our employees, agents, contractors and other representatives) to access and use your personal information so that the independent practitioners consulting from our practice can provide you with the best possible healthcare. Only persons who need to see your personal information will have access to it. If we need to use your information for any other purposes, we will seek additional consent from you to do this.

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

Our practice will need to collect your personal information to facilitate the provision of healthcare services to you by the independent practitioners consulting from our practice. Our main purpose for collecting, using, holding and sharing your personal information is to facilitate the management of your health by those independent practitioners. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training).

What personal information do we collect?

The information we will collect about you includes your:

names, date of birth, addresses, contact details including next of kin
demographic information, including gender, cultural background and religious beliefs
medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors
Medicare number (where available) for identification and claiming purposes
healthcare identifiers
payment and/or financial information
NDIS number (for allied health) and
Pension card details,

Dealing with us anonymously

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.

Please be aware that Medicare rebates are only available where a Medicare card (and/or associated information) is available. As such your practitioner may require you to pay for your consults in full without this rebate if you choose to deal with us anonymously or under a pseudonym.

How do we collect your personal information?

Our practice may collect your personal information in several different ways.

You may provide us with your personal information directly (for example, when you make an appointment with a practitioner consulting from our practice, our practice staff will collect your personal and demographic information via your registration).
The independent practitioners providing medical services may also collect further personal information from you which may be disclosed to us. Information can also be collected through My Health Record, e.g. via Shared Health Summary, Event Summary or through a Discharge Summary provided by a hospital or other healthcare service provider.
We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media.
In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:

your guardian or responsible person
other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services
your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).

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

We collect, use and disclose your personal information to facilitate the provision of medical services to patients of the independent practitioner consulting from our practice.

We may also share your personal information:

with third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with the Australian Privacy Principles (APPs) and this policy
with other healthcare providers
when it is required or authorised by law (eg court subpoenas, or where we are obliged to make a mandatory notification to a regulatory body)
when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain your consent
to assist in locating a missing person
to establish, exercise or defend a claim
for the purpose of confidential dispute resolution processes
when there is a statutory requirement to share certain personal information (eg some diseases require mandatory notification)
during the course of providing nursing support services
for the purpose of uploading that information to your My Health Record, such as through the shared health summary or event summary

Only people who need to access your information will be able to do so. Other than in the course of 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 express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing.

How do we store and protect your personal information?

Your personal information may be stored at our practice in various forms.

Our practice stores information in our practice management system as electronic records (including via cloud-based services) and visual records (including photos).

Our practice stores all personal information securely via the use of passwords, encrypted back-ups, confidentiality agreements for staff and secure cabinets.

All records will be retained until the later of seven (7) years from your last contact with the practice, or until you reach the age of twenty-five (25).

We take steps to destroy or de-identify information that we no longer require.

Our server security policy is designed to protect the servers from unauthorized access, data breaches, and other security threats. Our practice uses the following security measures to ensure the personal information which it holds as secured:

Antivirus software is installed on all servers and updated regularly
Firewalls are configured to block unauthorized traffic
Access to servers is restricted to authorised users
Servers are patched regularly to fix security vulnerabilities
Backups are created regularly every hour onsite with daily offsite backups.

Some of the independent practitioners consulting from our practice use the dictating AI software Lyrebird. Lyrebird Health is fully compliant with the APPs and the Australian Privacy Act 1988, particularly APP 3 with respect to personal private information. All sensitive health information remains within Australian soil and is not processed overseas – ensuring complete data sovereignty. Furthermore, by default Lyrebird Health never stores any information from your consults with your independent practitioner once it has concluded. Consult notes and documents can be saved at your clinician’s discretion. All information is stored on Lyrebird Health’s Australian Amazon Web Services (AWS) infrastructure, fully-encrypted using bank level 256-bit encryption during transit and at rest. Lyrebird Health’s Data Processing Agreements with AWS ensures any information stored is only accessible to Lyrebird Health. No party, including AWS, can access or alter information. By default, this information is stored for no longer than seven (7) days. During a consult with your independent practitioner, all audio is transcribed in real-time on Lyrebird Health’s Australian servers. At no point in time are audio files saved or permanently stored. The audio stream from the consultation is completely encrypted and securely transferred to Lyrebird Health servers. All Artificial Intelligence (AI) & Language Learning Model (LLM) processing occurs on-premise via Australian AWS servers. No third-party has access to this information. By default, Lyrebird Health immediately deletes this information unless requested to be saved by your independent practitioner. As Lyrebird Health is an independent business, we are not responsible and do not have any control over the content or privacy practices of Lyrebird. For more information about Lyrebird and how they deal with private information please see their privacy policy here: Privacy & Security – Lyrebird Health or www.lyrebirdhealth.com/en-au/privacy.

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. You can lodge this request either via email (info@completechildrenshealth.com.au). We require you to put this request in writing and our practice will respond within a reasonable time which may be up to thirty (30) days. We can post the requested information to your postal address, or we can email the information to your if you request. If we are required to process a request for your records, please note that we may charge fees for our reasonable costs incurred in complying with your request.

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. You may also request that we correct or update your information, and you should make such requests in writing to info@completechildrenshealth.com.au or call the practice directly on 03 9375 7833. There is no fee charged for making corrections to your personal information.

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

We take complaints and concerns regarding privacy seriously. You should express any privacy concerns (including any breach of the APPs or any registered binding APP code) you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure.

Complaints should be addressed to:

Liana Fonti, Practice Manager

82 Holmes Road, Moonee Ponds VIC 3039

Email: info@completechildrenshealth.com.au

We will endeavour to provide a response within thirty (30) calendar days.

You may also contact:

The Office of the Victorian Information Commissioner (OVIC). For further information, visit https://ovic.vic.gov.au or call the OVIC on 1300 006 842

The Office of the Australian Information Commissioner (OAIC). Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992.

Privacy and our website

If you “like” or comment on our social media pages, we will have your social media name.

Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked from our website.

Policy review statement

This privacy policy will be reviewed annually to ensure it is in accordance with any changes that may occur.

Our most up to date privacy policy will always be available to you via our website or at reception.

This information was updated on the 4th September 2024