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PRIVACY - WHAT CAN PRACTICES DO?
Privacy Officer, Privacy Audit - Step by Step
- PRIVACY OFFICER - appoint one (e.g. GP, Practice Manager/Nurse)
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Co-ordinate, implement & monitor privacy policy
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Promote to all interested parties including patients, GPs and staff
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Act as liaison officer for all privacy issues and patient requests for
record access
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Formulate privacy policy
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Conduct privacy reviews (analyse what data collected, how, storage,
disclosure, consent)
See new policy in generic DDDGP Practice Manual 6.7
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NPPs - Familiarise yourself with the 10 National Privacy Principles
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PRIVACY AUDIT - Review Current Privacy/Confidentiality Policies &
Processes
See new policy in generic DDDGP Manual 6.8
(Do this by referring to the NPPs and turning them into questions -
investigate to see if practice complies…simply answer each question and
document)
Your final summary document can form the basis of the practice privacy
document that can be viewed by a person requesting information on practice
privacy policies, what data collected, how, storage, security etc.
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What is
our primary purpose? e.g. To provide comprehensive, co-ordinated and continuing
whole person medical care for individuals, families and the community.
(based on RACGP definition)
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NPP1 What information do we collect? i.e. any identifying details incl.
DOB, address, Tel, NOK, Emergency contacts, Marital status, employer details,
Medicare No., Health Insurance details, Ethnicity, allergies & other
sensitivities, Past & current medical history, social history, Medical
procedures, Diagnostic tests, Results, Referrals, Reports from other health
service providers, X-rays, Progress notes, Financial details related to billing,
Medications, Immunisations, Work Cover examinations ….dates, amounts, related to
this data….. Where possible information is collected directly from the patient.
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NPP1 Purpose of collection? To gain sufficient information to provide for
optimal ongoing management of each patient's health, care and well being and to
ensure practice is viable to continue treating patients.
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NPP5 How is the data stored? Paper, computer - patient registration form,
accounts form, Medicare, Health Insurance claim form, Referral letter, medical
record forms as per Rolls Printing/RACGP medical records. Medication scripts
written manually & via computer (Medical Director software), Immunisation forms
- ACIR, Pap Smear Registry forms, S8 Drugs - internal booklet used paper form to
denote usage, sterilisation register (paper), doctor's letters/referrals on
computer or paper. Medical records stored electronically on computer; also old
records prior to Jan 1999 stored in paper records. Data accessed only via
authorised GPs and staff. Computers have password access with paper medical
records stored in locked filing cabinets/filing area. Staff who access files
have signed privacy agreements. Practice manager and reception staff require
access to accounts, demographic records and from time to time actual medical
records. GPs are also aware of privacy restrictions and access issues and use
passwords for computer access.
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NPP2 How is data used? For maintaining current information about patients,
updating demographics; accounts - payment, invoicing, follow-up; recall &
reminder system, actioning report results, adding to medical record for
comprehensive data - results, operation reports, emergency department visits,
after hours & home consultations, telephone notes,
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NPP1& 6
Who has access? For primary purpose and related secondary purpose: GPs, practice
manager, reception staff. Patients referred to another health service provider
will be aware that the information in referral letter, given to that service
provider for normal course of ongoing patient care & management and patient has
the right not to give consent to this (then they would not be referred to that
provider!) Accounts details only provided to gain payment from
insurance/Medicare office. No additional unnecessary data given.
Pathology/Radiology, other medical, dental specialists, and allied health
service providers providers included here. If research conducted, then each
patient provides informed consent for his/her personal health information to be
released. Patient has right to access of own personal health information under
privacy legislation with noted exceptions. See our policy and NPP6 Access &
Correction.
Under certain legislation we must disclose patient information e.g. Infectious
Diseases Act - Health (Infectious Diseases) Regulations, Adoption Act
Specify as much as you can. Records must be disclosed under court orders,
subpoenas, search warrants and Coroner's Court cases
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NPP5 Do we inform patients of the intended use of their information?
See Policy Manual & summarise main issues for this review.
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NPP2 Use & Disclosure When do we obtain a patient's consent?
Note: express and implied consent . See 6.5 of policy manual.
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NPP3 Quality Is the data we collect accurate, up to date, & complete?
Audit sample of records e.g. 20 records for latest path, x-ray other results
incl. referrals to specialists.
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NPP4 How do we protect data from misuse, loss & unauthorised access?
Refer to Sec 6 of policy manual esp 6.3 Retention of Records & Archiving for
security of records policies. Do random check of staff and their knowledge of
policy and observe conduct for same.
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DDDGP Dec 2001
North
East Valley Division General Practice, Victoria,
Australia, Disclaimer
Level 1, Pathology Building, Repatriation Campus, A&RMC,
Heidelberg West VIC 3081. .. map
Phone: 03 9496 4333, Fax: 03 9496 4349, Email: nevdgp@nevdgp.org.au,
Please note: NEVDGP does not provide
an on-line consultation
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