St Vincent’s Hospital Sydney Limited, with respect to its facilities St Vincent’s Hospital Sydney, Sacred Heart Health Service (St Vincent’s Health Network), is committed to protecting the privacy of personal information (including health and sensitive information) that we collect and hold.
This policy applies to all employees of St Vincent’s Health Network, any medical or dental practitioners appointed or credentialed with St Vincent’s Health Network; volunteers; students; contractors and any other persons who in the course of their work have access to personal information and health information, whether by electronic means or otherwise.
This policy does not apply to any information which is not personal information or health information, or is de-identified information.
Objective
This privacy policy explains how St Vincent’s Health Network handles personal information in accordance with the requirements of the Privacy Act 1988 (Cth).
Definitions
In this Privacy Policy the following terms have the following meanings:
De-identified Information |
Information or an opinion about a person whose identity cannot be ascertained from the information or opinion. |
Health Information |
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NSW Health Organisations |
Agencies or organisations which fall under the portfolio of the NSW Ministry of Health, which includes, as at April 2021:
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Personal Information |
Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
Personal Information includes both health information and sensitive information. |
Related Entities |
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Sensitive Information |
genetic information about an individual that is not otherwise health information. |
Policy Statement
St Vincent’s Health Network is committed to protecting the privacy of personal information which it collects and holds.
St Vincent’s Health Network must comply with the Australian Privacy Principles under the Privacy Act 1988 (Cth), and other privacy laws (including the Health Records and Information Privacy Act 2002 (NSW)) which govern the way in which organisations (such as St Vincent’s Health Network) collect, hold, use and disclose personal information. As an affiliated health organisation under the Health Services Act 1997 (NSW), St Vincent’s Health Network is also subject to the NSW Health Privacy Manual for Health Information (Third Edition) as amended or replaced from time to time.
The purpose of this Privacy Policy is to explain:
Mission and Strategic Fit
In line with St Vincent’s Health Network’s Mission and Values, this policy ensures that individuals are treated with compassion and empathy; and that their personal and health information is protected in accordance with the relevant privacy legislation.
Collection and use of personal information
St Vincent’s Health Network will only collect information which is necessary to provide you with health care services or appropriately manage and conduct our business. This may include (as applicable):
St Vincent’s Health Network collects information from you which is necessary to provide you with health care services or to enable you to participate in research studies. This includes collecting personal information such as your name, address and contact details, your health history, family history, past and current treatments, lifestyle factors, and any other information which is necessary to assist the health care team in providing appropriate care, or our research team in conducting its research.
St Vincent’s Health Network collects information from you which is necessary to properly manage and operate its business. This includes collecting personal information such as your name, address and contact details, professional experience, qualifications and past employers, and any other information which may be necessary to appropriately conduct its business.
St Vincent’s Health Network collects information from you which is necessary to assess and engage job applicants. This includes collecting personal information such as your name, address and contact details, professional experience, qualifications, references and past employers, and any other information which is necessary to process your job application.
Where you have consented, St Vincent’s Health Network collects information from you for the purposes of fundraising and managing donations. This includes collecting personal information such as your name and address and any other information required to process your donation.
We will usually collect your personal information directly from you, however, sometimes we may need to collect information about you from third parties, such as:
St Vincent’s Health Network only uses your personal information for the purpose for which it was collected by St Vincent’s Health Network (primary purpose), unless:
For example, St Vincent’s Health Network may use your personal information to:
Where possible and practicable, you will have the option to deal with St Vincent’s Health Network on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the services or support you are seeking, or deal with you effectively.
St Vincent’s Health Network uses camera surveillance systems (commonly referred to as CCTV) in some areas for the purposes of maintaining safety and security of its patients, personnel, visitors and other attendees. Those CCTV systems may also collect and store personal information and St Vincent’s Health Network will comply with all privacy legislation in respect of any such information.
Disclosing your personal information
St Vincent’s Health Network will confine its disclosure of your personal information to the primary purpose for which that information has been collected (eg, the provision of health care), or for a related secondary purpose. This includes when disclosure is necessary to provide services to you, to assist us in running our organisation, to facilitate the provision of quality and efficient public health care services in NSW (noting St Vincent’s Health Network is an Affiliated Health Organisation with facilities which provide public health services pursuant to a Service Agreement with NSW Health), or for security reasons.
We may provide your personal information to:
Where permissible under the privacy laws we may disclose personal information to external service providers who may use, process and store that information overseas. For example:
Data storage, quality and security
St Vincent’s Health Network will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date.
All personal information held by St Vincent’s Health Network is stored securely in either hard copy or electronic form.
St Vincent’s Health Network strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. St Vincent’s Health Network reviews and updates (where necessary) its security measures in light of current technologies.
While St Vincent’s Health Network does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with St Vincent’s Health Network via an online process, it is at your own risk.
There are ways you can help maintain the privacy of your personal information, including:
Notifiable Data Breaches
The passage of the Commonwealth Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) established a Notifiable Data Breaches (NDB) scheme in Australia. The NDB scheme requires organisations covered by the Privacy Act 1988 (Cth) (which may include the related entities) to notify any individuals likely to be at risk of serious harm by a data breach. In some cases, the Office of the Australian Information Commissioner (OAIC) must also be notified of the data breach. Please note the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) prescribes timelines for the notification process to the OAIC.
SVHA has established a Data Breach Response Plan that details how SVHA Group Entities, including St Vincent’s Health Network, must deal with any instance where there has been a potential or actual breach of personal information held by SVHA in either electronic or hard copy form. The Data Breach Response Plan includes information on the assessment and reporting of a data breach, the convening of a Data Breach Response Team and details on the communication processes to be undertaken following a breach.
All staff must familiarise themselves with the Data Breach Response Plan and its processes and ensure the plan is followed whenever a data breach is suspected or discovered.
Use of cookies
A ‘cookie’ is a small data file placed on your machine or device which lets St Vincent’s Health Network identify and interact more effectively with your computer. While cookies allow a computer to be identified, they do not contain personal information about a specific individual.
Cookies are industry standard and are used by most websites, including those operated by St Vincent’s Health Network. Cookies can facilitate a user’s ongoing access to and use of a website. Cookies allow St Vincent’s Health Network to customise our website to the needs of our users. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with some features of our on-line services via the St Vincent’s Health Network website.
Links to other sites
St Vincent’s Health Network may provide links to third party websites. These linked sites may not be under our control and St Vincent’s Health Network is not responsible for the content or privacy practices employed by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.
Accessing and amending your personal information
You have a right to access the personal information which St Vincent’s Health Network holds about you. If you make a request for access to your personal information, we will ask you to verify your identity and specify the information you require.
You may also request St Vincent’s Health Network make an amendment to any of your personal information if you consider that it contains information which is incomplete, incorrect, out of date, or misleading. St Vincent’s Health Network will consider your application and will respond in accordance with the privacy law.
You can contact St Vincent’s Health Network about any privacy issues as follows:
• By telephone via the Hospital Switchboard (02 8382 1111) and ask to speak with the Privacy Officer
• By mail addressed To the Attention of the Privacy Officer, St Vincent’s Health Network, 390 Victoria Street Darlinghurst NSW 2010
• By email addressed To the Attention of the Privacy Officer at SVHS.Feedback@svha.org.au
While St Vincent’s Health Network aims to meet all requests for access to personal information, in a small number of cases and where permitted to do so by law, St Vincent’s Health Network may not give access or may do so only under conditions.
Subject to applicable laws, St Vincent’s Health Network may destroy records containing personal information when the record is no longer required by St Vincent’s Health Network.
Complaints
If you have a complaint about St Vincent’s Health Network’s information handling practices or consider we have breached your privacy, you can lodge a complaint with:
St Vincent’s Health Network deals with all complaints in a fair and efficient manner.
Compliance:
The Chief Executive Officer must ensure that all people falling within the scope of this policy:
The Privacy Officer:
Managers and supervisors should:
All staff should:
For SVHS Annual Privacy Report, CLICK HERE