Privacy Policy

Melb Gastroenterology Pty Ltd ACN 693 530 415 as trustee for the Gastroenterology Trust, trading as Gastro Practice Melbourne (Gastro Practice Melbourne, we, us or our) takes privacy seriously and is committed to protecting your privacy.

This Privacy Policy explains how Gastro Practice Melbourne collects, holds, uses and discloses your personal information and health information.

Gastro Practice Melbourne is bound by the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and, where applicable, the Health Records Act 2001 (Vic).

By contacting Gastro Practice Melbourne, making an enquiry, completing a referral, registration or appointment form, scheduling an appointment with a doctor who practises from or uses Gastro Practice Melbourne, attending a consultation or procedure at one of our locations, or using our website or telehealth systems, you acknowledge this Privacy Policy and consent to the collection, holding, use and disclosure of your personal information in accordance with this Privacy Policy, to the extent consent is required by law.

This Privacy Policy may be amended from time to time. Important changes will be notified on our website or by other appropriate means. Please check our website periodically for the current version.

If you have any questions about this Privacy Policy, would like to request access to or correction of your personal information, or wish to make a privacy complaint, please contact:

Personal Information Collection and Use

This Privacy Policy relates to personal information and health information supplied by you, or by another person on your behalf, to Gastro Practice Melbourne, including:

• contact information, such as your name, date of birth, address, telephone number, email address and emergency contact details;
• communications, including information provided when you contact us, make an enquiry, request an appointment or correspond with us by phone, email, SMS, online form or otherwise;
• financial and billing information, including payment details, bank account details, billing details and third party payer details, for example where payments, deposits, cancellation fees, Medicare claims or private health insurance claims are processed;
• medical and health information, including referral details, medical history, symptoms, medications, allergies, investigation results, procedure information and other information relevant to your care or the administration of your care;
• referral and uploaded information, including information submitted through patient registration forms, GP referral forms, request appointment forms and other online forms, including referral letters, pathology results, imaging, reports and other supporting documents;
• technical information, including IP address, browser type, operating system, device information, time zone setting, plug-in types and versions, MAC address, unique device identifiers and mobile network information;
• website and usage information, including information about your visit to our website, clickstream data, pages viewed, searches, page response times, download errors, interaction information such as scrolling and clicks, and whether you click on links or open communications from us; and
• Medicare numbers and other government identifiers, where reasonably necessary for billing, claiming or liaising with Services Australia.

We may receive personal information directly from you or from third parties, including:

• your GP or referring practitioner;
• treating specialists, hospitals, pathology providers, imaging providers or allied health professionals involved in your care;
• Medicare, private health insurers, HICAPS or payment processors;
• persons authorised by you to act on your behalf; and
• other persons or organisations where permitted or required by law.

Information may be collected by phone, email, SMS, in person, through our website, through online forms including Snapforms or similar platforms, through telehealth systems, or through other written or electronic communications.

If you send us an email containing personal information, reasonable endeavours will be used to preserve the confidentiality of that information. Our internet host or IT service providers may monitor emails for maintenance, service provision, fault detection, security and legal compliance purposes. Email is not a secure method of communication. If you are concerned about sending personal information by email, you should contact us by another method.

If you choose not to provide requested personal information, this may affect our ability, or the ability of the relevant doctor, to assess your referral, arrange an appointment, provide medical services, process payments or otherwise manage your care.

How Your Personal Information Is Used

We may collect, hold, use and disclose your personal information for the following purposes:

• to assist doctors who practise from or use Gastro Practice Melbourne to provide health services to you;
• to receive, assess and process referrals, enquiries and appointment requests;
• to assist in determining which doctor may be appropriate for your care;
• to arrange appointments, procedures, hospital admissions, telehealth consultations and related administration;
• to communicate with you, including sending appointment reminders, confirmations, invoices, receipts, follow-up communications and other information relating to your care;
• to process payments, deposits, cancellation fees, Medicare claims, private health insurance claims and related accounts;
• to maintain administrative, billing, practice management and record keeping systems;
• to support quality assurance, accreditation, professional compliance and practice improvement activities;
• to obtain IT, cloud hosting, form processing, payment processing, document management and other business support services;
• to respond to feedback, requests, enquiries, concerns or complaints;
• to maintain and secure our website, systems, technology platforms and business operations;
• to detect, investigate and address security incidents, unauthorised access, malware, fraud or other risks; and
• to comply with legal, regulatory, insurance, professional and reporting obligations, including circumstances where disclosure is required or authorised by law.

Why Your Personal Information Is Used

Your personal information may be collected, held, used or disclosed for reasons including:

• where you have provided consent;
• where it is reasonably necessary to provide health services or support the provision of health services;
• where it is reasonably necessary for practice administration, bookings, billing, records management or patient communications;
• where it is necessary to comply with legal, regulatory, accreditation, insurance or professional requirements; and
• where it is otherwise permitted or required by law.

Why Sensitive Information May Be Used

Sensitive information, including health information, is only collected, used or disclosed where:

• you have provided express and informed consent, where required;
• it is reasonably necessary to provide a health service to you;
• it is necessary to protect your life, health or safety, or that of another person;
• it is necessary to establish, exercise or defend a legal claim;
• it is necessary for a permitted health management, quality assurance, accreditation or related purpose;
• it is required or authorised by law; or
• it is otherwise permitted under applicable privacy legislation.

Who Your Personal Information Is Shared With

We may disclose your personal information where permitted or required by law, including to the following persons or organisations:

• doctors who practise from or use Gastro Practice Melbourne, to enable them to provide medical services, manage records, bookings and billing, and otherwise conduct their practice;
• our staff, contractors and service providers involved in administration, reception, record management, billing, IT, cloud hosting, form processing, website support, payment processing, risk management and office support services;
• financial institutions and payment processors for payment processing;
• hospitals, day procedure centres, pathology providers, imaging providers, pharmacies and other healthcare providers involved in your care;
• your GP, referrer, treating specialists and allied health practitioners involved in your care;
• governing bodies, regulators and professional bodies, including AHPRA, the RACP and accreditation or recertification bodies, where required or reasonably necessary;
• law enforcement bodies, courts, tribunals, government agencies and regulators where required or authorised by law;
• insurers, indemnity providers, auditors, accountants, lawyers and other professional advisers;
• family members, carers, guardians, representatives or other persons authorised by you, or where disclosure is permitted or required by law;
• appropriate persons in an emergency or where necessary to lessen or prevent a serious threat to life, health or safety; and
• any other person or organisation where you have directed or authorised us to do so, or where disclosure is otherwise permitted or required by law.

We do not sell personal information.

Clinical Audit, Quality Assurance and Practice Improvement

Gastro Practice Melbourne may use information from consultations, procedures and related services for clinical audit, quality assurance, peer review, accreditation, reporting, recertification support and practice improvement purposes.

Where reasonably practicable, information used for these purposes will be de-identified before it is reviewed, discussed or disclosed. If identifiable information is required for a particular purpose, this will only occur with your consent or where otherwise permitted or required by law.

How Your Personal Information Is Stored

We may keep your personal information in physical and electronic form, or a combination of both.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Those steps may include:

• secure practice management and document storage systems;
• password protection and user access controls;
• secure cloud-based systems and email systems;
• staff confidentiality obligations;
• physical security measures for paper records and devices; and
• secure disposal and destruction processes.

Although reasonable steps are taken to protect your information, no method of electronic transmission or storage is completely secure. Information transmitted over the internet is provided at your own risk.

Where a doctor also holds your personal information separately, the way that doctor handles your information will also be governed by that doctor's own privacy policy. You should read the relevant doctor's privacy policy where applicable.

Where Your Information Will Be Held

Gastro Practice Melbourne uses third party technology and service providers to operate the practice, including email, document storage, cloud hosting, website, analytics, online form and practice administration systems. This may include providers such as Microsoft 365, Snapforms and similar providers.

Where information submitted through online forms, email or other systems is received, stored, transmitted or otherwise handled through those platforms, your personal information may be stored on servers located outside Australia or may be accessed by service providers or support personnel located outside Australia.

Where practicable, overseas locations may include the United States, Singapore and other countries in which relevant service providers maintain infrastructure or support operations. As provider arrangements and hosting locations may change from time to time, it is not always practicable to identify every country in advance.

Reasonable steps will be taken to ensure that any overseas recipient handles personal information in a manner consistent with Australian privacy law, unless an exception under the Privacy Act applies.

How Long Your Personal Information Is Stored For

We retain personal information for different periods depending on the type of information, the purpose for which it is used, and our legal obligations.

Generally, personal information is kept for as long as needed to:

• support the provision of services by Gastro Practice Melbourne and the relevant doctor;
• comply with legal, accounting, regulatory, accreditation and professional obligations; and
• deal with complaints, claims or legal proceedings.

We are generally required to retain health records for at least:

• 7 years from the date of the last entry in the record for an adult; or
• if the patient was a child, until the patient turns 25 years of age.

Once personal information is no longer required, reasonable steps will be taken to destroy it or permanently de-identify it, subject to any legal obligation to retain it.

How You Can Correct Your Personal Information

If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us in writing.

It is your responsibility to notify us if your details change, for example your address, email address, telephone number, Medicare details or emergency contact details.

We will respond to a correction request within a reasonable time, and generally within 30 days. If we agree that the information should be corrected, we will take reasonable steps to correct it. If we refuse a correction request, written reasons will be provided, except where it would be unreasonable to do so.

Access to Your Personal Information

You may request access to personal information we hold about you by contacting us in writing.

We will generally respond to an access request within a reasonable time, and generally within 30 days. Access may be provided by inspection, copy, summary or another appropriate method.

A reasonable administrative fee may be charged for providing access, for example where extensive retrieval, copying or collation is required.

Access may be refused or limited in circumstances permitted by law, including where:

• giving access would pose a serious threat to life, health or safety;
• giving access would unreasonably impact the privacy of another person;
• the request is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings; or
• there is another lawful basis for refusing access.

If access is refused or limited, written reasons will be provided, except where it would be unreasonable to do so.

Privacy Complaints

If you have concerns about how your personal information has been collected, stored, used, disclosed or otherwise managed, or believe that your privacy has been breached, you may make a complaint in writing to the Practice Manager using the contact details set out above.

We will investigate the complaint and respond as soon as reasonably practicable, and generally within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the:

If applicable, you may also complain to the:

Use of Commonwealth Government Identifiers

Gastro Practice Melbourne will not adopt Commonwealth government identifiers, such as Medicare numbers, as its own identifiers for individuals.

Those identifiers will only be used or disclosed as permitted by law, including for billing, Medicare claiming, health service administration and related lawful purposes.

AI, Cookies and Analytics

We may use AI-enabled tools from time to time, including ambient AI medical scribe or documentation tools, to assist with clinical documentation, administration and delivery of services. Where these tools are used, reasonable steps will be taken to ensure they are used consistently with privacy and confidentiality obligations.

Cookies are small files that a website transfers to your computer or device for record keeping and functionality purposes. We may use cookies, analytics tools such as Google Analytics, and similar technologies on our website and online services to help us understand website traffic, improve functionality and support user experience.

Most browsers are initially set to accept cookies. You may change your browser settings to refuse cookies, although this may affect website functionality.

Links to Third Party Websites

Our website, email updates and other communications may contain links to third party websites.

If you follow a link to another website, that website will have its own privacy policy or privacy notice. Gastro Practice Melbourne is not responsible for the privacy practices of third party websites, and this Privacy Policy does not apply to those websites.

Definitions

In this Privacy Policy, unless the context otherwise requires:

• (a) APPs means the Australian Privacy Principles;
• (b) Gastro Practice Melbourne, we, us or our means Melb Gastroenterology Pty Ltd ACN 693 530 415 as trustee for the Gastroenterology Trust, trading as Gastro Practice Melbourne;
• (c) Personal Information has the meaning given in the Privacy Act 1988 (Cth), and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not;
• (d) Privacy Act means the Privacy Act 1988 (Cth), as amended from time to time;
• (e) Privacy Policy means this privacy policy as amended from time to time and made available on our website and in hard copy on request;
• (f) Sensitive Information has the meaning given in the Privacy Act and includes health information and other sensitive information regulated under that Act; and
• (g) You or Your means the individual from whom, or about whom, personal information is collected.