Patient Privacy Policy

PRIVACY POLICY 5.2

The Definition of a patient health record

A personal health record is a collection of your personal health information. Complete patient health records improve patient safety and wellbeing as they support clinical decision making. For example, a complete patient health record assists your clinical team to easily access information on a patient’s allergies or the patient’s medical history. Consultation notes and patient health records are also a way of managing risks. 

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 anything else, we will seek additional consent from you to do this.

Why do we collect, use, hold and share your personal information?

What personal information do we collect?

The information we will collect about you includes your:

• names, date of birth, addresses, contact details
• medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors
• Medicare number (where available) for identification and claiming purposes
• healthcare identifiers
• health fund details

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 required or authorised by law to only deal with identified individuals. 

How do we collect your personal information?

Our practice may collect your personal information in several different ways.

1. When you make your first appointment our practice staff will collect your personal and demographic information via your registration.
2. During the course of providing medical services, we may collect further personal information. Information can also be collected through electronic transfer of prescriptions (eTP), My Health Record, eg via Shared Health Summary
3. We may also collect your personal information when you visit our website, send us an email, telephone us, make an online appointment or communicate with us using social media. 
4. 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:

• your guardian or responsible person
• other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services
• your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).
• While providing medical services, further personal information may be collected via:
• Electronic prescribing
• My Health record
• Online appointments 

Various types of images may be collected and used, including:
  - CCTV footage: Collected from our premises for security and safety purposes

When, why and with whom do we share your personal information?

We sometimes share your personal information:

• with third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with APPs and this policy 
• with other healthcare providers
• when it is required or authorised by law (eg: court subpoenas) 
• 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 it is impractical to obtain the patient’s consent
• to assist in locating a missing person
• to establish, exercise or defend an equitable claim
• for the purpose of confidential dispute resolution process
• when there is a statutory requirement to share certain personal information (eg: some diseases require mandatory notification)
• during the course of providing medical services, through eTP, My Health Record (eg: via Shared Health Summary).

Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.

We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.

Our practice 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 practice in writing. 

Our practice may use your personal information to improve the quality of the services we offer to our patients through research and analysis of our patient data. 

We may provide de-identified data to other organisations to improve population health outcomes. The information is secure, patients cannot be identified, and the information is stored within Australia. You can let our reception staff know if you do not want your information included. 

How do we store and protect your personal information?

Your personal information may be stored at our practice in various forms.
This may be in the form of paper records, electronic records, visual records.

Our practice stores all personal information securely.

Information is stored by electronic format, in protected information systems or in hard copy format in a secured environment. We use passwords to protect all electronically stored information. We have secure cupboards for hard copy documents and all staff sign a privacy statement upon their commencement of employment. 

How are document automation technologies used?

Document automation is where systems use existing data to generate electronic documents relating to medical conditions and healthcare. 

The practice uses document automation technologies to create documents such as referrals, which are sent to other healthcare providers. These documents contain only your relevant medical information.

These document automation technologies are used through secure medical software Best Practice.

All users of the medical software have their own unique user credentials and password and can only access information that is relevant to their role in the practice team.

The practice complies with the Australian privacy legislation and APPs to protect your information. 

All data, both electronic and paper are stored and managed in accordance with the Royal Australian College of General Practitioners Privacy and managing health information guidance. 

How can you access and correct your personal information at our practice?

You have the right to request access to, and correction of, your personal information. 

Our practice acknowledges patients may request access to their medical records. We require you to put this request in writing and send to the clinics mailing address. Alternatively, you can email your request to reception@lotusfamilyclinics.com.au and our practice will respond within 30 business days. Should L.F.C comply with the request please note that a fee may be associated with providing this information. 

Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. Each time you visit, we will ask you to verify that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing addressed to our reception team at reception@lotusfamilyclinics.com.au

How are Artificial Intelligence (AI) Scribes used? 

The practice uses an AI scribe tool to support GPs take notes during their consultations with you. The AI scribe uses an audio recording of your consultation to generate a clinical note for your health record. The practice AI scribe service is Lyrebird.

Lyrebird: What this means for your privacy 

Lyrebird Health recognises the value of privacy in healthcare and is committed to safeguarding patient data.

With strict compliance to Australian regulation, Lyrebird Health is designed to prevent unauthorised access, uphold patient anonymity, and securely dispose of sensitive data.



• Transcription is performed exclusively within Australia.
• Audio file is immediately destroyed post-transcription.
• Transcription is redacted of sensitive, personal identifying information received. 
• Post-redaction, the transcript is encrypted. It is not stored in its original form.
• Only the concerned clinician can access your health data.
• By default, data is stored on our Australian servers for 24 hours before being deleted.

The practice will only use data from our digital scribe service to provide healthcare to you. 

We also use Better Consult. This is a pre-questionnaire tool that records presenting symptoms, medications and other relevant clinical information. It then translates the data into concise medical notes, ready for them to review. While this tool is useful for our doctors it is not mandatory that you provide any pre-consultation information should you not wish to do so.

Better Consult: What this means for your privacy

The Personal Information we collect about you may include the following: 

• information such as your name, date of birth, email address, gender, telephone number/s, family details, patient identifier (if provided to us by you or your treating Practitioner), and information necessary for us to provide the Services to you;
• sensitive information such as health information, which may include your medical history, details of Practitioners and healthcare providers from whom you are receiving or have received treatment, information about your health (including current and historical symptoms, diagnoses, medical tests, medication history and your reasons for visiting a Practitioner) and other information which falls within the meaning of “health information” as defined in the Act; 
• details of your use of the Platform and communications with us; and
• any other information that you choose to provide to us when interacting with the Platform,

but only if you provide it to us directly or if we receive it from your Practitioner’s practice management software (which is software that Practitioners use for managing the operations of their medical practice and storing the medical records of their Patients).

How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?

We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure.

Complaints can be addressed to L.F.C practice manager at admin@lotusfamilyclinics.com.au or via post to 10 Smythes Road Delacombe, Vic, 3356. Should you choose to send your complaint via post please note ‘Private & Confidential – Attention Practice Manager’ on the envelope. The practice manager can also be contacted by telephone on 03 5309 3159. Our practice manager has 30 business days to respond to your complaint. 

You may also contact the Office of the Australian Information Commissioner. Generally, the OAIC will require you to give them time to respond before they investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992. 

Policy review statement

This privacy policy will be reviewed regularly to ensure it is in accordance with any changes that may occur. Amended policies will be available to patients as changes occur. 

Current as of: 18/11/2024

Review Date: 18/11/2025