Western NSW Primary Health Network (WNSW PHN) is committed to protecting the privacy of your personal information in accordance with the Australian Privacy Principles and the Privacy Act 1988 (Cth). It is one of our primary obligations that any personal or sensitive information you provide to us is not used for any other purpose than that intended and expected unless we are required to do so by law. This Privacy Statement outlines our practices for the collection, use and management of the personal information we store.
Purposes for which information is collected, stored, used and disclosed
WNSW PHN’s focus is to understand and prioritise health care needs of its communities, identify service gaps, support frontline health services and increase the efficiency and effectiveness of primary health care. To achieve this, we need to collect baseline data, conduct needs assessments and analyse health-related information. WNSW PHN utilises this information to identify priority areas to commission (contract) organisations and health service providers to deliver integrated primary health care services that are appropriate and relevant to meet the needs of the community.
WNSW PHN also provides support to general practice, Aboriginal health services and other primary health care providers to assist them in providing high quality health care and other services. We also promote safety and quality through showcasing and disseminating research and evidence of best practice by collecting and reporting data to support continuous improvement. General Practices participating in WNSW PHN’s Practice Incentives Program Quality Improvement (PIP QI) provide us with information (usually de-identified, unless otherwise authorised) for the preparation, production and distribution of aggregated reports, the provision of program-related support and assistance, population health planning and reporting to the Department of Health or Australian Institute of Health and Welfare (AIHW).
WNSW PHN utilises this information to coordinate and integrate health services, provide information to general practice, health service providers and other members of the community and to report to government agencies and other funding bodies.
Types of personal information collected by us
The personal information WNSW PHN collects and stores depends upon our relationship with you and the nature of the function we are performing. We will only collect personal information about you when you have provided it to us or authorised a third party to provide that information to us.
To meet our obligations as a Primary Health Network, WNSW PHN collects personal information about:
- Health Service Organisations and Providers who have been commissioned (contracted) by us to deliver services to the community.
- Our Board and committee members, employees and contractors.
- Our stakeholders, members of the community and other people whom we deal with.
This information includes but is not limited to:
- Health Service Organisations’ details such as business name, addresses, contact numbers, email and website addresses, PIP information, clinical software, Medical Benefits Scheme data and details of the services offered.
- Health Service Providers contracted to provide services to communities, such as name, addresses, contact numbers, email and website addresses and details of the services offered. We also collect the individual provider’s details such as; name, address, contact numbers, email address, professional qualifications, professional registration and provider numbers, bank and tax details, identification details, drivers licence and/or passport details, and certificates of currency verifying appropriate insurances such as public liability, professional indemnity and workers compensation. We will also conduct and store information relating to police checks and working with children checks as required.
- Participants of WNSW PHN Continuing Professional Development events including phone and email contact information.
- General Practice and other primary health care service providers’ identified patient information such as demographic data, ethnicity identifiers, smoking status, medications taken, allergy status, cervical screening data, chronic disease prevention measures and data related to diabetes, coronary heart disease and chronic obstructive pulmonary disease.
- Board Members and Committee members names, addresses, contact numbers, email address, tax file number, information about work history, qualifications and other details as required.
- Prospective or current employees or contractors names, addresses, contact numbers, email address, date of birth, tax file number, Australian Business Number, identification details, passport and/or drivers licence details, information about work history and performance, qualifications, and other relevant details as required.
- Stakeholders and other community members, but only information to the extent necessary for the relevant circumstances.
Where it is practicable to do so, we will allow you to deal with us anonymously or by using a pseudonym. However, this may not be possible for health service providers, employees and contractors.
Collection of personal information
WNSW PHN collects personal information through a variety of methods, such as, in person, in writing, by telephone, via email, social media and through our website.
De-identified personal health-related information is collected with the agreement of the relevant data holder, such as general practices and other primary health care service providers. Information may also be collected from other health-related organisations.
When assessing applications from prospective employees, contractors or potential service providers, WNSW PHN will, with prior consent, collect personal information from former employers, nominated referees and professional associations.
We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we store.
Storage and security of personal information
We undertake all reasonable steps to protect the personal information held in our possession against loss, unauthorised access, use, modification, disclosure and misuse. Once information is no longer required, we will take reasonable steps to destroy or permanently de-identify any personal information we store.
Much of the information we store about you will be stored and backed up electronically in a secure data centre located within Australia. Some information we store about you will be stored in paper files and these files are kept securely in our office. We use a range of physical and electronic security measures to protect the security of the personal information we store.
Disclosure of personal information
WNSW PHN will only disclose personal information we store in accordance with the requirements in the Privacy Act for the purposes of operating the Primary Health Network and meeting our obligations under our funding agreement with the Commonwealth Department of Health.
In our role as a commissioner of services, we impose the same privacy obligations on any entities or contractors we engage to provide services. A confidentiality clause imposes obligations on the funding recipient with respect to information collected, created, or held under our funding agreements.
In relation to our staff, personal information may be collected from or about our personnel and may be used or disclosed to administer, monitor, review, promote and evaluate WNSW PHN’s programs or any other grant programs administered by the Department of Health and for directly related purposes.
Information collected under WNSW PHN’s PIP QI will be shared on behalf of general practice with third parties, AIHW, who are specified and authorised in the agreements we have entered into with participating general practices.
It is not likely that any disclosure of personal information will be made to overseas recipients.
Electronic collection of personal information
Each time you visit our website, we collect and store information about your computer’s assigned IP address and the use of our website. This information may include the date and time of visits, user location, information accessed, referring page, navigation, fields completed in any forms and device type. This information is not linked to your personal information unless required by law.
Electronic information about users is also collected when accessing our electronic newsletter including contents clicked, mail client, domain and device type.
The WNSW PHN website does not include facilities to guarantee the secure transmission of information across the internet. Whilst reasonable efforts are made to provide security, users should be aware that there are inherent risks in transmitting information across the internet.
Accessing and Correcting Your Personal Information
You have a right under the Privacy Act 1988 (Cth) to access personal information we store about you. You also have the right to request corrections of any personal information that we store about you if you think the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
To access or seek correction of personal information we store about you, please contact our Privacy Officer (see below for contact details).
We do not charge for receiving a request for access to personal information, or for complying with a correction request. We do however reserve the right to charge you for our services a reasonable fee to assist with covering our costs specifically incurred in meeting your request for information.
If you think we may have breached your privacy, you may contact us to make a complaint using the contact details below. Complaints should be made in writing to ensure we fully understand the nature of your complaint and the outcome you are seeking. Alternatively, you may submit your feedback via our online feedback form at: https://wnswphn.org.au/about-us/contact-us
Please be aware that it may be difficult to properly investigate or respond to your complaint if you provide insufficient detail. You may also submit an anonymous complaint, however, if you do, it may not be possible for us to provide a response to you.
We are committed to quick and fair resolution of complaints and will ensure your complaint is taken seriously and investigated appropriately. Your access to the services we provide is not affected in any way should you make a complaint.
If you are not satisfied with the way we have handled your complaint in the first instance, you may contact the Office of the Australian Information Commissioner to refer your complaint for further investigation. Please note that the Information Commissioner may not be able to investigate if you have not first brought your complaint to our attention.
Office of the Australian Information Commissioner
Telephone: 1300 363 992
Post: GPO Box 5218
Sydney NSW 2001
If you wish to:
- query how your personal information is collected, held, used or disclosed by us;
- ask us questions about our Privacy Procedure;
- request access to, or seek correction of personal information; and/or
- to make a privacy complaint;
please contact our Privacy Officer.
Contact: Media & Communications Coordinator, Western NSW Primary Health Network
Telephone: 1300 699 167
Post: PO Box 890
Dubbo NSW 2830
WNSW PHN CEO