The Australian Privacy Principles generally apply to private sector organisations of a certain size (revenue more than $3,000,000).
Health information is regarded as one of the most sensitive types of personal information. As a result, all organisations that provide a health service are covered by the Privacy Act regardless of whether they are above or below the threshold that would ordinarily apply. A “health service” includes any activity that involves:
- assessing, recording, maintaining or improving a person’s health; or
- diagnosing or treating a person’s illness.
Even so, the Privacy Act only applies to smaller organisations in respect of health information. “Health information” includes any information collected about a person’s health or disability and any information collected in relation to a health service a person has received. It includes such things as:
- the symptoms described by a patient or the provider’s observations of the patient’s health
- billing details
- pathology reports, such as those relating to blood samples and X-rays
- dental records
- Medicare number
- private hospital and day surgery admission and discharge records
- genetic information – perhaps following a genetic or paternity test
- other sensitive information about things such as race, sexuality or religion when it’s collected by a health service.
So the definition is pretty broad. Information required for processing accounts would be caught by the third bullet point. A healthcare identifier is a unique 16 digit number used to identify individuals under the personally controlled electronic health (eHealth) record system. It is different to a Medicare card number.
So what are the risks?
What’s not so obvious is where to source one. Sourcing a template online might seem like a fast and easy solution, but there may be loopholes that can go unnoticed if not looked over by someone with expertise in this area. Conversely, approaching a legal professional to create one is a costly option and can take some time.
I look forward to hearing your thoughts on the matter.