PRIVACY POLICY

1 INTRODUCTION
1.1 This Privacy Policy is to provide information to you on how your personal information (which includes your sensitive information, including your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.

2 WHY AND HOW YOUR CONSENT IS NECESSARY
2.1 When you register as a patient of a practitioner who consults from our practices, you provide consent for us (including our employees, agents, contractors and other representatives) to access and use your personal information so the independent practitioners consulting from our practices 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 so.

3 WHY DO WE COLLECT, USE, HOLD AND SHARE YOUR PERSONAL INFORMATION
3.1 Our practices will need to collect your personal information to facilitate the provision of healthcare services to you by the independent practitioners consulting from our practices. 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 (e.g. staff training).

4 WHAT PERSONAL INFORMATION DO WE COLLECT
4.1 The information we will collect about you includes your:
(a) names, date of birth, addresses, contact details including emergency contact and next of kin;
(b) demographic information, including gender, and cultural background.
(c) medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors.
(d) Medicare number (where available) for identification and claiming purposes.
(e) healthcare identifiers.
(f) payment and / or financial information.
(g) concession card details; and
(h) health fund details.

5 DEALING WITH US ANONYMOUSLY
5.1 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.
5.2 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.

6 HOW DO WE COLLECT YOUR PERSONAL INFORMATION
6.1 Ourpracticesmay collectyour personal informationin several different ways:
(a) You may provide us with your personal information directly (for example, when you make an appointment with a practitioner consulting from our practices, our practice staff will collect your personal and demographic information via your registration);
(b) 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 providers.
(c) We may also collect your personal information when you contact us via our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media; and
(d) 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:
i your guardian or responsible person.
ii other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services; and / or
iii your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).
6.2 If your practitioner deems it in your best interest to discuss your clinical information with you, we will arrange for this to occur either in person, via telephone or via videoconference.

7 WHEN, WHY AND WITH WHOM DO WE USE ANDSHARE YOUR PERSONAL INFORMATION
7.1 We collect, use and disclose your personal information to facilitate the provision of medical services to patients of the independent practitioners consulting from our practices.
7.2 We may also share your personal information:
(a) with other healthcare providers.
(b) when it is required or authorised by law (e.g. court subpoenas, or where we are obliged to make a mandatory notification to a regulatory body);
(c) 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 where it is otherwise impractical to obtain your consent.
(d) to assist in locating a missing person.
(e) to establish, exercise or defend a claim.
(f) for the purposes of confidential dispute resolution processes.
(g) during the course of providing nursing support services.
(h) for the purposes of uploading that information to your My Health Record, such as through the shared health summary or event summary; and / or
(i) with third parties who work with our practices 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.
7.3 Only people who need to access your information will be able to do so. Other than in the course offacilitating the provision of medical services or as otherwise described in this policy, our practices will not share personal information with any third party without your consent.
7.4 We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent, other than with our virtual assistants who are offshore for the purpose of facilitating the management of your health by your independent practitioner. Where information is sent offshore, we and our offshore employees will continue to adhere to the APPs and other privacy requirements.
7.5 Our practices 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 practices in writing.
7.6 Your practitioner may use an artificial intelligence program to record and summarise your appointment and store the transcript of the appointment in your medical record. These notes will be reviewed by your practitioner to ensure they accurately reflect your appointment before they are relied upon to provide medical advice.
7.7 Our practices cannot make any warranties or guarantees on how third parties will collect, store, or use data. Where there has been a breach of privacy by the third-party due to their own conduct, we will not be liable for any damages of any kind recognised by law and our liability is limited to the extent of our negligence or misconduct contributing to the breach. We will participate in updating you on your practitioner’s behalf if needs be in relation to any communications from the third-party with your practitioner in connection with any breach of privacy committed by the third-party. Any complaints regarding third-party programs should be sent to the third-party. For more information, please find the following third-party privacy policies:
(a) https://www.heidihealth.com/au/legal/privacy-policy policy here; and
(b) https://www.lyrebirdhealth.com/au/patientprivacy policy here.

8 HOW DO WE STORE AND PROTECT YOUR INFORMATION
8.1 Your personal information may be stored at our practices in various forms.
8.2 Our practices store information as electronic records (including via cloud-based services), and archived paper records.
8.3 Our practices store all personal information securely in physical and cloud servers based in Australia via the use of passwords, encrypted back-ups, confidentiality agreements for Australian and offshore employees and secure cabinets.
8.4 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).
8.5 We take steps to destroy or de-identify information that we no longer require.
8.6 Our server security policy is designed to protect the servers from unauthorised access, data breaches, and other security threats. Our practices use the following security measures to ensure the personal information which it holds is secured:
(a) Antivirus software is installed on all servers and updated regularly.
(b) Firewalls are configured to block unauthorised traffic.
(c) Servers are placed on their own subnet.
(d) Access to servers is restricted to authorised users.
(e) Offshore employees only have limited online remote access, their activity is logged and monitored and they cannot store, copy or share any data from our system.
(f) Physical access to the servers are limited, with servers located in a locked room and security cameras installed around the building.
(g) Servers are patched regularly to fix security vulnerabilities.
(h) Backups are created regularly every hour onsite with daily offsite backups.
(i) Payment and / or financial information is securely stored with Tyro, an Authorised Deposit-Taking Institution, and a token is generated and used to effect transactions. You consent to the use of tokens in order to securely store your payment information. Please let us know if you do not consent to the use of tokens for the storage of your payment information.

9 HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION AT OUR PRACTICES
9.1 You have the right to request access to, and correction of, your personal information.
9.2 Our practices acknowledge patients may request access to their medical records. You can lodge this request either via email (feedback@wallsendhealthcare.com.au) or telephone. Our practices will acknowledge your request within three (3) business days. We can post the requested information to your postal address, or we can email the information to you if you request it. If we are required to process a request for your records, we may charge for our reasonable costs incurred in complying with your request.
9.3 Our practices 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 practicesare correct and current. You may also request that we correct or update your information, and you should make such requests in writing to feedback@wallsendhealthcare.com.au. There is no fee charged for making corrections to your personal information.

10 HOW CAN YOU LODGE A PRIVACY-RELATED COMPLAINT, AND HOW WILL THE COMPLAINT BE HANDLED AT OUR PRACTICES
10.1 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.
10.2 Complaints should be addressed to:
(a) Name and Position: Mr Shah. Operations Manager
(b) Email: feedback@wallsendhealthcare.com.au
10.3 We will respond with acknowledgement of your complaint within three (3) business days and provide a response within thirty (30) business days.
10.4 You may also contact 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.

11 PRIVACY AND OUR WEBSITE
11.1 If you “like” or comment on our social media pages, we will have your social media name.
11.2 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.
General Data Management Policy
1. Data Breach Response Policy
Purpose:
This policy defines a structured approach to identifying, responding to, and mitigating data breaches, ensuring compliance with the Notifiable Data Breaches (NDB) scheme, RACGP Policies and Procedures, and Australian Privacy Act 1988.
Scope:
• Applies to all employees, contractors, and third parties who access the company’s systems or engage via email or other electronic communication.
• Covers both onsite and offshore staff accessing the Australian-based servers remotely and utilising the other systems, accounts and communications.
Implementation:
• Any suspected or confirmed data breaches must be immediately reported to the Data Protection Officer.
• An incident response team investigates and mitigates the breach within two days and will advise the outcome of the investigation.
• Offshore staff accessing patient data remotely must ensure data is neither stored nor shared outside the secured practice system and that they notify the Data Protection Officer of any suspected breach.
• Regular training, audits and penetration testing are conducted.
Compliance:
• Data breaches are reported in accordance with NDB requirements.
• Disciplinary actions are enforced for non-compliance.
• Employees undergo mandatory annual data security training.

2. Email Policy
Purpose:
To regulate email communication, ensuring security and confidentiality of patient and business data, especially for remote offshore staff.
Scope:
• Applies to all employees communicating via company emails.
• Covers email use for transmitting sensitive patient data.
Implementation:
• Emails containing patient data must be encrypted using end-to-end encryption.
• All staff, contractors and third parties are prohibited from forwarding business emails to personal accounts or other third parties.
• Phishing and email scams must be reported immediately to the Data Protection Officer.
Compliance:
• Routine audits of email communication.
• Violations result in disciplinary action.
• Employees sign acknowledgment of adherence to the email security policy.

3. Internet Usage Policy
Purpose:
To define acceptable internet usage to safeguard patient data and prevent cybersecurity threats.
Scope:
• Applies to onsite and remote employees, contractors and third parties using the internet to access company systems or otherwise from the company premises.
Implementation:
• Internet access is strictly for business-related purposes.
• Offshore staff may only access patient data within the practice’s secured VPN network.
• Unauthorized websites, downloads, and software installations are prohibited.
Compliance:
• Employees, contractors and third parties must undergo internet security training.
• Unauthorized use results in access restriction or termination.
• Employees, contractors and third parties acknowledge and agree that the company may utilise monitoring systems for the purposes of ensuring compliance.

4. Remote Access Policy
Purpose:
To manage risks associated with remote access to the medical practice’s network.
Scope:
• Applies to all remote workers, including offshore staff handling appointment scheduling and data entry and any administrative task as directed by management.
Implementation:
• Remote access must be secured via VPN and Multi-Factor Authentication (MFA).
• Personal devices used for remote access must meet cybersecurity standards and be approved by the company before use.
• Offshore staff may only access patient data under direct supervision and where expressly agreed prior.
• Remote sessions must be logged and monitored.
Compliance:
• Regular audits of remote access logs.
• Any unauthorized data retrieval results in immediate termination.
• Ongoing cybersecurity training is mandatory.

5. Removable Media Policy
Purpose:
To prevent unauthorized data transfer and minimize malware risks.
Scope:
• Applies to all employees, contractors and third parties accessing the company’s systems and using removable media devices.
Implementation:
• Only encrypted devices approved by IT are permitted.
• Offshore staff are strictly prohibited from using removable media for patient data storage or otherwise in performing their work for the company unless otherwise agreed with the company prior.
Compliance:
• Violation results in immediate access revocation.
• All employees, contractors and third parties acknowledge and agree that the company utilises IT audits and monitoring for all removable media usage.

6. Server Security Policy
Purpose:
To secure server infrastructure and ensure compliance with cybersecurity best practices.
Scope:
• Covers all company-owned servers and network equipment.
• Applies to all employees, contractors and third parties accessing server resources.
Implementation:
• Servers must be maintained in a secured environment on site in Australia with restricted physical and digital access.
• Offshore staff are restricted to accessing data remotely and cannot interact directly with servers.
• All employees, contractors and third parties acknowledge and agree that the company utilises IT monitoring in order to track any unauthorized access attempts to be logged and reviewed.
Compliance:
• All employees undergo security training.
• Unauthorized access attempts lead to disciplinary action.

7. Software Installation Policy
Purpose:
To regulate the installation of software to prevent security vulnerabilities.

Scope:
• Applies to all staff using company-owned computing devices.
Implementation:
• Employees, contractors and third parties of the company may not install software without prior IT approval.
• Only licensed and approved software is allowed.
Compliance:
• Unauthorized software installation results in disciplinary action.
• All employees, contractors and third parties acknowledge and agree that the company utilises IT audits over all installed software regularly.

8. Wireless Communication Policy
Purpose:
To protect wireless network access from unauthorized connections.
Scope:
• Covers all wireless communication devices used within company networks.
Implementation:
• WPA3 encryption is mandatory for all company Wi-Fi networks.
• Employees, contractors and third parties may not connect personal devices without authorization from the company’s authorised representative.
Compliance:
• Unauthorized access attempts lead to account suspension.
• All employees, contractors and third parties acknowledge and agree that the company utilises regular wireless security assessments.

9. Privacy Policy
Purpose:
To protect patient information and ensure compliance with Australian privacy laws.
Scope:
• Applies to all staff, contractors and third parties handling patient data, including offshore employees.
Implementation:
• Offshore staff must not store, copy, or share any data beyond authorized tasks.
• Any related restricted patient information is only accessible via secured practice systems and limited to task assigned.
Compliance:
• All staff sign confidentiality agreements.
• Unauthorized access leads to termination.

10. Offshore Staff Data Handling and Security Policy
Purpose:
To regulate how offshore reception and admin staff handle patient data securely.
Scope:
• Applies to all offshore employees interacting with Australian patient data.
Implementation:
• Offshore staff must sign strict confidentiality agreements.
• All employees, contractors and third parties acknowledge and agree that the company utilises monitoring and other tools to ensure compliance for remote access activities to be logged and monitored.
Compliance:
• Any unauthorized access results in immediate contract termination.

11. Cybersecurity Compliance and Risk Management Policy
Purpose:
To ensure compliance with cybersecurity frameworks and mitigate risks.
Scope:
• Covers all employees, contractors and third parties and IT infrastructure.
Implementation:
• Regular risk assessments and cybersecurity training.
• Strict access controls for all sensitive systems.
Compliance:
• Employees undergo annual cybersecurity certification.

12. Incident Management and Reporting Policy
Purpose:
To define the structured approach for handling security incidents.
Scope:
• Applies to all employees, including offshore staff, contractors and third parties engaged with the company.
Implementation:
• Incidents must be reported within 24 hours.
• A post-incident review is conducted to prevent future breaches.
Compliance:
• Failure to report incidents leads to disciplinary action.

POLICY STATEMENT REVIEW
11.3 This privacy policy will be reviewed annually to ensure it is in accordance with any changes that may occur.
11.4 Last reviewed: 13 March 2025.