PRIVACY POLICY
Tonya Gabriel-Brennagh is the director of two businesses: Psyche’s Journey and Mental Gymnastics.
Psyche’s Journey is the counselling division and Mental Gymnastics supplies clinical training to professionals and workshops for the general public.
Both Psyche’s Journey and Mental Gymnastics work under strict privacy with their clients. This includes the collection, use and disclosure of personal information They are organisations that work with the principals of governance and accountability.
They work within a framework of integrity and correction of personal information. We respect and support individual to access their personal information.
This privacy policy covered the following areas:
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Practice Procedures
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Staff/Provider Responsibilities
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Client Consent
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Collection of information
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Use and Disclosure of Information
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Access, Corrections and Privacy Concerns
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Complaint Resolution
To ensure clients who receive consultation from the Practice are comfortable in entrusting their health information to the Practice. This policy provides information to patients as to how their personal information (which includes their health information) is collected and used within the Practice, and the circumstances in which we may disclose it to third parties.
Practice Procedure
The Practice will:
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Provide a copy of this policy upon request
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Ensure staff comply with the APP and deal appropriately with enquiries and concerns
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Take such steps as are reasonable in the circumstances to implement practices, procedures and systems to ensure compliance with the APP and deal with inquiries or complaints
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Collect personal information for the primary purpose of managing a patient’s healthcare and for financial claims and payments.
Staff Responsibility
The Practice’s staff will take reasonable steps to ensure client understand:
Client Consent
The Practice will only interpret and apply a patient’s consent for the primary purpose for which it was provided.
The Practice staff must seek additional consent for the client if the personal information collected may be used for any other purpose.
Collection of Information
The Practice will need to collect personal information as a provision of clinical services to a client at the practice. Collected personal information will include clients:
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Names, addresses and contact details
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Medicare number (where available)(for identification and claiming purposes)
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Healthcare identifiers (when appropriate)
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Medical information including medical history, medications, allergies, adverse events, social history, family history and risk factors.
A client’s personal information may be held at the Practice in various forms:
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As paper records
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As electronic records
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Videos, and photos
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As audio recordings
The Practice’s procedure for collecting personal information is set out below.
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Practice staff collect client’s personal and demographic information via registration when clients present to the Practice for the first time. Clients are encouraged to pay attention to the collection statement attached to/within the form and information about the management of collected information and client privacy.
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During the course of providing Psychological services, the Practice’s psychologist will consequently collect further personal information.
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Personal information may also be collected from the patient’s guardian or responsible person (where practicable and necessary), or from any other involved healthcare specialists.
The Practice holds all personal information securely, whether in electronic format, in protected information systems or in hard copy format in a secured environment.
Use and Disclosure of Information
Personal information will only be used for the purpose of providing medical services and for claims and payments, unless otherwise consented to. Some disclosure may occur to third parties engaged by or for the Practice for business purposes, such as accreditation or for the provision of information technology. These third parties are required to comply with this policy. The Practice will inform the patient where there is a statutory requirement to disclose certain personal information (for example, concerns around self-harm, or harm to others).
The Practice will NOT disclose personal information to any third party other than in the course of providing psychological services, without full disclosure to the client or the recipient, the reason for the information transfer and full consent from the client.
Exceptions to disclose without client consent are where the information is:
The Practice will not use any personal information in relation to direct marketing to a client without that client’s express consent. Clients may opt-out of direct marketing at any time by notifying the Practice in a letter, phone call or email.
The Practice evaluates all unsolicited information it receives to decide if it should be kept, acted on or destroyed.
Access, Corrections and Privacy Concerns
The Practice acknowledges patients may request access to their psychological records. Clients are encouraged to make this request in writing, and the Practice will respond within a reasonable time.
The Practice will take reasonable steps to correct personal information where it is satisfied they are not accurate or up to date. From time to time, the Practice will ask clients to verify the personal information held by the Practice is correct and up to date. Clients may also request the Practice corrects or updates their information, and clients should make such requests in writing.
The Practice takes complaints and concerns about the privacy of client’s personal information very seriously. Clients should express any privacy concerns in writing. The Practice will then attempt to resolve it in accordance with its complaint resolution procedure.
Complaints Resolution
All complaints should be referred to the Psychologist involved and should the matter not be resolved to the complainant’s satisfaction an external review shall be conducted by an independent consultant psychologist as nominated by the practice.
Related Resources
Compliance indicators for the Australian Privacy Principles: An addendum to the computer and information security standards (Second edition)
www.racgp.org.au/ehealth/privacy
RACGP Computer and information security standards (CISS) and templates (2013)
www.racgp.org.au/your-practice/e-health/protecting-information/ciss/
The RACGP Privacy handbook & patient pamphlet