Privacy Policy
Introduction
This privacy policy provides information to you, our patient, on how your personal information (including your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.
Why and when your consent is necessary
When you register as a patient of our practice, you provide consent for our GPs and practice staff to access and use your personal information so they can provide you with the best possible healthcare. Only staff who need to see your personal information will have access to it. If we need to use your information for any other purpose, we will seek your additional consent.
The Gap Doctors recognises the importance of protecting the privacy and rights of individuals and patients in relation to their personal and health information. This document is The Gap Doctors’ privacy policy. It explains how we collect and manage your personal information.
Our practice is governed by several state-specific privacy laws. We respect your right to privacy and have a legal obligation to comply with the Privacy Act 1988. The rules and regulations under this Act are known as the Australian Privacy Principles (APPs).
What is a patient health record?
Medical records, whether electronic or paper-based, are a collection of information about a patient’s healthcare that is essential for present and future care (WHO, 2001). These records are covered by s.3 of the Health Records Act 2001 (AustLII, 2012).
A medical record must contain sufficient information to identify the patient and document information relevant to treatment during current and future episodes of care. For example:
The patient’s medical history
The orders and results of physical examinations or tests
Information relating to allergies
Other factors requiring special consideration
Secure and guaranteed access to complete information in the medical record is essential to ensure that healthcare professionals have accurate information when and where they need it. This maximises the quality and efficiency of care provided.
What is personal information?
Personal information is any information that can be used to identify you. This includes, but is not limited to, your name, date of birth, address, telephone number, email address, and occupation. If you can reasonably be identified from the information we collect, it is considered personal information.
Our privacy policy covers all patients and anyone who uses our services.
What is sensitive information?
Sensitive information refers to details necessary for us to provide your healthcare. This may include family, social, or medical history, genetic information, and emergency contact details. In this policy, both personal and sensitive information are referred to as “personal information.”
What personal information do we collect and hold?
The Gap Doctors may collect and store information such as:
Your name, address, and telephone number
Your age or date of birth
Your Medicare number, Veterans’ Affairs number, Health Care Card number, health fund details, or pension number
Current and past medications or treatments
Information relevant to your medical care, including your previous and current medical history and family medical history (where clinically relevant)
Your ethnicity
Occupation or job title
The names of health service providers or specialists to whom you are referred, copies of referrals, and reports received
Any additional information you provide directly to us, either in person, through representatives, or via allied health professionals providing services through our centres or clinics
We may also collect non-identifiable information, such as anonymous responses to surveys.
How do we collect your personal information?
We usually collect your personal information directly from you, unless it is unreasonable or impracticable to do so. Collection methods may include:
Completion of our patient registration form
Information you disclose during consultations with GPs, nurses, or allied health professionals
Telephone or online appointment bookings
In some circumstances, we may collect personal information from other sources when it is not practical to collect it from you directly. These may include:
Your guardian or responsible person
Other healthcare providers such as specialists, hospitals, pathology, diagnostic imaging services, and community health services
Your health fund, Medicare, or the Department of Veterans’ Affairs
Dealing with us anonymously
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 legally required to deal with identified individuals.
What happens if we can’t collect your personal information?
If you do not provide the required personal information:
We may not be able to provide the requested services, either at the same standard or at all
Your diagnosis and treatment may be inaccurate or incomplete
There may be risks to your health outcomes
Why do we collect, use, hold and share your personal information?
Our main purpose for collecting, using, holding, and sharing your personal information is to manage your health and provide healthcare services to you. We may also use your information for related business activities, including:
Financial claims and payments
Practice audits and accreditation
Business processes such as staff training
Other purposes include:
Delivering medical services and treatments
Administrative and billing purposes
Keeping your contact details up to date
Handling complaints
Complying with laws and regulations
Conducting research, clinical trials, and proactive screenings
Sending direct marketing communications (where permitted)
Recall and reminder systems for follow-ups and health promotion
Answering enquiries and providing service-related information
Meeting requirements for medical defence organisations or insurers
We do not sell, rent, or disclose your personal information other than as described in this policy or permitted under the law.
Telehealth
The Gap Doctors does not conduct audio or visual recordings of telehealth consultations. When telehealth services are provided (onsite or remotely), only telephone consultations are used. Doctors will obtain verbal consent to record your consultation in your patient file, and the record will be notated accordingly.
How do we store and protect your personal information?
Your information is stored electronically. Our practice is considered paperless and complies with RACGP computer security guidelines. Safeguards include:
Password-protected access for authorised staff only
Automated privacy protection (e.g., screensavers, timeouts)
Frequent data backups stored securely off-site
Antivirus software and firewalls
A tested business continuity plan
Confidentiality agreements signed by all staff and contractors
It is important that your personal information is kept accurate and up to date. Please notify our reception staff of any changes promptly.
When, why and with who do we share your personal information?
We may share your personal information in the following cases:
With third parties working with our practice for business purposes (e.g., accreditation or IT providers)
With other healthcare providers
When required or authorised by law (e.g., court subpoenas)
When necessary to prevent a serious threat to health or safety
To assist in locating a missing person
For legal claims or dispute resolution
Where statutory notification is required (e.g., reportable diseases)
During medical services through eTP or My Health Record
We will not share your information with third parties without your consent unless legally required.
Direct marketing materials
We may send you information about our services that we believe may interest you. This may be via SMS, email, or post, in compliance with marketing laws such as the Spam Act 2003. You may opt out of these communications at any time.
How can you access and correct your personal information at our practice?
You may request access to, or correction of, your personal information by writing to:
The Office Manager, The Gap Doctors
We will respond to your request within 30 days. A fee may apply to cover administrative costs. Access may be refused in limited circumstances, such as when it may interfere with the privacy of others or breach confidentiality.
Complaints
If you have concerns about your privacy, please address them in writing to:
The Office Manager, The Gap Doctors
We will respond within 30 days. If unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au or by calling 1300 363 992.
Overseas disclosure
We do not disclose your personal information to overseas recipients. If such disclosure becomes necessary, we will obtain your consent first.
Security
We take all reasonable steps to ensure your personal information is secure and protected from misuse, loss, unauthorised access, modification, or disclosure. Personal information is destroyed or de-identified when no longer needed.
Reviews and Updates
This privacy policy is reviewed and updated annually. Updated versions will be available on our website and from reception.
Last updated: 24/03/2025
Review: June 2026