Privacy Policy

Introduction

The Privacy Act (1988) was introduced to regulate the handling of personal information and protect the privacy of individuals.

In the ordinary course of business, Outcome Health collects, processes and stores health data extracted from electronic medical records from participating general practices. The stored dataset consists of de-identified medical records of patients interacting with general practices.

Outcome Health takes privacy seriously. This Policy outlines the privacy handling practices of Melbourne East General Practice Network, trading as Outcome Health (ABN 86 129 637 412), in dealing with personal information.

This Policy sets out the principles that Melbourne East General Practice Network, trading as Outcome Health (“the Organisation”), has adopted to comply with privacy obligations and protect personal information. The principles outlined here address the entire lifecycle of such information, including collection, use, disclosure, access, correction, security, and disposal.

The Organisation adheres to high standards of compliance practices in its current operations, as well as processes to continually monitor and strengthen information handling in ways that are ethical, consistent with Commonwealth and State legislation, and importantly, in line with social license and community expectations.

Outcome Health manages POLAR in accordance with applicable privacy legislation, contractual obligations and established governance processes. Where data is used for research, appropriate ethics approvals and governance arrangements are obtained. POLAR supports research activities conducted under appropriate Human Research Ethics Committee (HREC) approvals where required. Outcome Health maintains an ISO/IEC 27001-certified Information Security Management System incorporating technical, physical, and administrative controls. ISO 27001 is a comprehensive set of requirements for defining, implementing, operating, and improving our Information Security Management Systems.

 

About this Privacy Policy

This Policy was prepared in March 2015 and reviewed yearly in accordance with Australian Privacy Principles (APPs). The APPs are found in The Privacy Act 1988. We collect personal information necessary to undertake our programs, activities, or functions, including facilitating the exchange of information between Outcome Health and other agencies.

Any enquiry or complaint about privacy or confidentiality should, in the first instance, be directed to the Organisation:

Role CEO
Phone:(03) 8822 8444    Email: polar@outcomehealth.org.au

The Organisation will respond to all privacy enquiries within 30 days. If a response is not received (after 30 days), a complaint may be lodged with the Office of the Australian Information Commissioner (OAIC) via the enquiries line at 1300 363 992 or, if calling from outside Australia, at +61 2 9284 9749

What is personal information?

Personal information is information or an opinion that could identify an individual: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

When do we interact with data?

Outcome Health offers a system called POLAR to collaborating General Practices in Australia. POLAR securely extracts data from the practice or third-party integration agent, which is processed and de-identified prior to be stored. The data processing includes data cleaning, data mapping to medical terminology standards, curation, and analytics. The results are presented in an identifiable format back to the source practice via the POLAR platform. POLAR enables the practice to interrogate patient information for a range of clinical improvement and population health-based activities. Identifiable data is only available and visible within the practice setting.

We de-identify and map some of the information and supply it to our partner Primary Health Networks (PHNs) so they can use it to commission services and to provide quality improvement activities across their catchments. This is conducted with appropriate approvals, where general practices agree to share de-identified data. PHNs do not access identified data about you. You can read more about the PHNs roles here.

What types of personal information do we collect and store?

We collect clinical and administrative information generated and stored in your electronic medical record from the General Practice’s clinical information system. POLAR separates identifying information from clinical information. Identifying information is securely encrypted and protected so that only authorised users from the originating practice can re-identify their own patients when required. Re-identification is available only to appropriately authenticated and authorised users from the originating practice. Where appropriate, one-way hashing is also used to generate secure linkage keys.

Information collected from the practice is de-identified and mapped. Some of this information is made available to our partner Primary Health Networks (PHNs).

We collect information related to the care you receive at the practice from 11 broad categories:

• • • Demographic;
    • Activity (number of visits and interactions);
    • Medicare billing information;
    • Diagnosis:
    • Medications;
    • Observations (height, weight etc)
    • Pathology tests;
    • Radiology tests;
    • Immunisations;
    • Cervical screening;
    • Referral categories

A comprehensive list of common data items can be accessed by contacting Outcome Health.

We create secure linkage keys that can be used with appropriate approvals and ethics to link patient data across the health system while ensuring patient privacy.

The key is made up of fragments of each patient’s personal information. The key is then encrypted and comes with the data to us. What we see is a meaningless combination of characters. We are unable to reverse engineer the key to reveal any personal information about you. Here is an example of a key:

‘0x1F7F84C948CA85E443B2F9FGFLKJA897ADS899E30C7FAC236585C679456FB782E9A3734B7679B’

The linkage keys are designed so that Outcome Health cannot derive an individual’s identity from the key alone.

Can patients opt out of sharing de-identified data?

Your practice collects only the information required to ensure you receive the best possible care. If, however, you prefer your data to be excluded from quality improvement activities, your practice has measures in place to ensure your wishes are respected and promptly adhered to.

When you visit your practice, you can inform the practice staff (receptionist, nurse or doctor) that you do not consent for your data to be collected. Your practice will then ensure your de-identified data is not shared with us.

Patients who do not consent to have data collected about them are entitled to receive the same level of high-quality care, so you can remain confident that your choice not to participate in data programs will not affect the care you receive.

How do we collect data?

When you see your doctor, information is added to your medical record in the practice’s clinical IT system during the consultation. The POLAR software captures some of that information (either directly from the practice or from a third-party integration agent approved by your practice) de-identifies it, and sends it securely to us. We clean and map data to medical terminology standards and then send it back to the practice. (Further detail in ‘Why do we collect, hold and disclose data?’) Outcome Health may use approved analytical and machine learning techniques to improve data quality, coding or analysis. These processes operate on de-identified information and are subject to appropriate governance.

Before data arrives in our warehouse, all identifiable information is encrypted so that only a de-identified subset of patient data is visible to us. The data in this warehouse is a tool that enables your PHN to develop population health initiatives to improve your community’s health. For more information about health programs available in your area, contact your PHN.

The practice can view your details in their own version of our system, much like the clinical system used in the consultation room.

How do we collect data?

When you see your doctor, information is added to your medical record in the practice’s clinical IT system during the consultation. The POLAR software captures some of that information (either directly from the practice or from a third-party integration agent approved by your practice) de-identifies it, and sends it securely to us. We clean and map data to medical terminology standards and then send it back to the practice. (Further detail in ‘Why do we collect, hold and disclose data?’) Outcome Health may use approved analytical and machine learning techniques to improve data quality, coding or analysis. These processes operate on de-identified information and are subject to appropriate governance.

Before data arrives in our warehouse, all identifiable information is encrypted so that only a de-identified subset of patient data is visible to us. The data in this warehouse is a tool that enables your PHN to develop population health initiatives to improve your community’s health. For more information about health programs available in your area, contact your PHN.

The practice can view your details in their own version of our system, much like the clinical system used in the consultation room.

How do we store data?

We store de-identified practice data in a secure data warehouse. Your identified data is only visible in the practice. POLAR does not have access to view identifiable data. Practices can view your data only when they log in to the secure POLAR system.

Some parts of your de-identified data are viewable to the PHN in your region. PHNs use this data to know what services are most needed in your area and then work to address those needs.

Access to de-identified data stored in the POLAR warehouse is strictly monitored, audited and restricted. We take all steps necessary to ensure your de-identified data is not accessed by an unauthorised person, including multiple layers of security to ensure we maintain the highest standards in handling your data.

Why do we collect, hold and disclose data?

POLAR data is collected to:

 1. Help general practices get meaning from their patient data

First and foremost, we collect data to support your practice to provide you with the highest possible level of care.

The information recorded during your care is often complex and needs to be organised before it can provide useful insights. When we extract de-identified information from practices, we clean it up, map it to standardised medical terms, and then send it back to the practice of origin. The practice’s POLAR software then uses the cleaned-up version of the data to provide practice teams with insights into their patient cohort. This information helps practice teams to improve patient care.

For example, the POLAR software makes it easy for the practice to identify patients who are due for certain tests, such as a patient with a heart condition with no cholesterol test recorded in the last two years, or an older patient who is due for a health assessment.

POLAR transforms complex clinical data into easy-to-understand interactive graphs and colour-coded charts, enabling practices to make informed decisions and take practical action to provide you with the best care.

2. Help PHNs conduct evidence-based population health planning

The PHN in your region assists the practice with their data management needs by providing advice and education. Practices are supported in using the data in ways that translate into tangible improvements in their patients’ health.

PHNs access a subset of de-identified practice datasets, which allows them to help manage the community health needs.

For example, your PHN may identify an area or particular health issue, such as a higher than average prevalence of mental health conditions for young people living in a certain region. It can then fund support services for people in that region. Without access to this de-identified data contributed by your practice, many of these needs would remain undetected and therefore unaddressed.

3. Support ethically-approved health research projects

If your practice has agreed to allow ethical research on de-identified datasets, a limited number of data items may be made available to researchers for PHN-approved projects. There are strict guidelines around which data items are available and for what studies. PHNs will approve research only where appropriate approvals, governance arrangements, and ethical requirements have been satisfied and where it directly benefits the general practice community. In some instances, your practice may choose to be directly involved in selected research and in other cases, you may be invited to participate in a research project. This ensures that medical knowledge is continually improved, so you continue to have access to the best medical practice.

In line with all other layers of security, research access is strictly enforced and monitored. Data shared for research is strictly monitored and controlled by Outcome Health.

More details on research activity can be accessed by contacting Outcome Health on (03) 8822 8444 or by visiting: https://www.outcomehealth.org.au/services/polar/research-analytics .

Research findings are shared with your practice via various communication channels to ensure timely access to insights.

How can you access your information?

You have the right to request access to your personal information and to request that it be corrected.

1. Access to your information
We access only de-identified information, so we are unable to provide you with access to your individual information, as we don’t know which records are yours in the dataset.

The best way to see what data POLAR collects is by contacting your practice directly. You can access the information we collect at the practice by simply requesting to view it. For a complete picture of the information your doctor collected during your visit, we recommend you speak with your doctor and request to view your medical record.

2. Correction of incorrect information
Once de-identified, the data is transferred to our secure warehouse, and we are unable to identify individual patients within the de-identified data during normal operations.

For reasons described above, we can’t correct your information. However, if you think your patient information may be incorrect (that is, the information that your doctor records during your visit), you can ask your doctor to correct it. That correction will then flow through to our database in de-identified form.

What are the risks?

Although the data we hold is de-identified and, where required, encrypted, two broad risk categories remain:

1. An unauthorised person or agency accesses your data;

or

2. A person or agency attempts to re-identify patients from the de-identified dataset we hold.

We have robust systems and measures in place to address and mitigate these risks. We adhere to the strictest security standards and comply with all relevant government legislation to ensure your data is always protected. We are accredited against the highest industry standards.

In the rare event that a data breach occurs, we take immediate steps to contain and address the breach. Our detailed Data Security Breach Policy outlines the necessary steps and protocols that would be triggered immediately in the event of a breach. Additionally, we have a communication strategy in place to ensure that potentially affected individuals are notified. For more information on our comprehensive Data Breach Response Plan, contact Outcome Health at (03) 8822 8444.

Your privacy is our highest priority, and we take important steps to minimise the risk of these events.

What is the complaints process?

If you believe a breach of the Australian Privacy Principles has occurred, you may raise your concerns or lodge a complaint with:

• • • Your general practice
    • Your PHN
    • Outcome Health – contact us on 03 88228444 and ask to speak to the Privacy Manager.  Alternatively, you can email us polar@outcomehealth.org.au

Complaints are treated with the highest priority, and all reasonable steps are taken to ensure a prompt and satisfactory resolution. If you are dissatisfied with the proposed solution, you may lodge a complaint with an external body such as the Office of the Australian Information Commissioner.

Privacy Act Legislation Changes

In recent years, Australia has strengthened its privacy laws by increasing protections for personal information, improving transparency, strengthening data breach notification rules, and introducing new requirements for the use of automated systems. POLAR provides information and analytical insights to healthcare providers. Clinical decisions remain the responsibility of the treating clinician. Outcome Health has maintained a ‘privacy by design’ approach, which ensures we are well-placed to respond to legislation changes in a way that ensures continued full compliance.

Risk Assessment

This policy is assessed for risk of content variation and as such has the below rating:

References

POLAR – https://polargp.org.au/

Primary Health Networks – https://www.health.gov.au/our-work/phn

Ethical conduct of research – https://www.nhmrc.gov.au/research-policy/ethics-and-integrity

Office of the Australian Information Commissioner –  https://www.oaic.gov.au

Review of the Privacy Act – https://www.ag.gov.au/integrity/consultations/review-privacy-act-1988