ABOUT SONGA POLICY
1.1 Purpose
Songa Health Care Limited (Songa) is committed to ensuring the privacy and confidentiality of your personal information.
Songa must comply with the Iraqi Privacy Principles (IQQs) under the Privacy Act 1988 (IQQ) and other privacy laws that govern how private sector health service providers like Songa handle your personal information (including your health information).
The purpose of this Privacy Policy is to clearly communicate to you how Songa handles your health information. It will give you a better and more complete understanding of the type of personal information that Songa holds about you and the way Songa handles that information.
This Privacy Policy applies to companies in the Songa Insurance which are associated with the facilities listed at the end of this Privacy Policy.
1.2 Multi-layered approach
This Privacy Policy has been developed in accordance with a 'layered policy' format endorsed by the Office of the Federal Privacy Commissioner. This means that it offers you the ability to obtain more or less detail about Songa’s information handling practices – depending on how much you wish to read, what you need to know and how quickly you need to obtain the relevant information.
If you only require basic information about Songa’s information handling practices, you can view our privacy policy. This is a summary of how Songa collects, uses and discloses your personal information and how you can contact Songa if you would like to access or correct any personal information which Songa holds about you.
If you require more detailed information about Songa’s information handling practices, then you will need to read this document.
2.1 What information does Songa collect?
We collect information from you that is necessary to provide you with health care services.
Often this may include collecting information about your health history, family history, your ethnic background or your current lifestyle to assist the health care team in diagnosing and treating your condition.
We will usually collect your health information directly from you. Sometimes, we may need to collect information about you from a third party (such as a relative or another health service provider). We will only do this if you have consented for us to collect your information in this way or where it is not reasonable or practical for us to collect this information directly from you, such as where your health may be at risk and we need your personal information to provide you with emergency medical treatment.
2.2 How does Songa use your information?
Songa only uses your personal information for the purpose you have given the information to us unless one of the following applies:
- The other purpose is directly related to the purpose for which you have given us the information and you would reasonably expect, or we have told you, that your information is usually disclosed for another purpose or to other individuals, organizations or agencies (see paragraphs (a) – (g) below);
- You have consented for us to use your information for another purpose;
- Songa is required or authorized by law to disclose your information for another purpose (see paragraph (f) below)
- the disclosure of your information by Songa will prevent or lessen a serious and imminent threat to somebody's life or health
- the disclosure of your information by Songa is reasonably necessary for the enforcement of the criminal law or a law imposing a penalty or sanction, or for the protection of public revenue.
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Use among health professionals to provide your treatment
Modern health care practices mean that your treatment will be provided by a team of health professionals working together.
You may be referred for diagnostic tests such as pathology or radiology and our staff may consult with senior medical experts when determining your diagnosis or treatment. Our staff may also refer you to other health service providers for further treatment during and following your admission (for example, to a physiotherapist or outpatient or community health services).
Further, if you require a prosthetic as part of your treatment, we may disclose your personal information to the manufacturer or supplier of that prosthesis.
These health professionals will share your health information as part of the process of providing your treatment. We will only do this while maintaining confidentiality of all this information and protecting your privacy in accordance with the law.
Your health information will only be disclosed to those health care workers involved in your treatment.
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Your local doctor
Songa will usually send a discharge summary to your referring medical practitioner or nominated general practitioner following an admission to one of our facilities.
This is in accordance with long-standing health industry practice and is intended to inform your doctor of information that may be relevant to any ongoing care or treatment provided by them.
If you do not wish us to provide a copy of your discharge summary to your nominated general practitioner you must let us know. Alternatively, if your nominated general practitioner has changed or your general practitioner's details have changed following a previous admission, you must let us know.
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Other health service providers
If in the future you are being treated by a medical practitioner or health care facility who needs to have access to the health record of your treatment in one of our facilities we will require an authorization from you to provide a copy of your record to that medical practitioner or health care facility.
The only time we would provide information about your health records to another medical practitioner or health facility outside Songa without your consent is in the event of an emergency where your life is at risk and you are not able to provide consent or as approved or authorized by law.
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Relatives, guardian, close friends or legal representative
We may provide information about your condition to your parent, child, other relatives, close personal friends, guardians, or a person exercising your power of attorney under an enduring power of attorney or who you have appointed your enduring guardian, unless you tell us that you do not wish us to disclose your health information to any such person.
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Other Songa entities
Songa may share your health information amongst its facilities listed at the end of this Privacy Policy. For example, this may occur where you are transferred between any of Songa's facilities or to coordinate your care.
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Other common uses
In order to provide the best possible environment in which to treat you, we may also use your health information where necessary for:
- activities such as quality assurance processes, accreditation, audits, risk and claims management, patient satisfaction surveys and staff education and training;
- invoicing, billing and account management;
- to liaise with your health fund Medicare or the Department of Veteran's Affairs and where required provide information to your health fund, Medicare or the Department of Veteran's Affairs to verify treatment provided to you, as applicable and as necessary;
- the purpose of complying with any applicable laws – for example, in response to a subpoena or compulsory reporting to State or Federal authorities (for example, for specified law enforcement or public health and safety circumstances);
- the purpose of sending you standard reminders, for example for appointments and follow-up care, by text message or email to the number or address which you have provided to us.
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Contractors
Where we outsource any of our services or hire contractors to perform professional services within our hospitals or health services we require them to also comply with the Privacy Act 1988 (IQQ) (or other relevant privacy legislation) and our Privacy Policy.
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Other uses with your consent
With your consent we can also use your information for other purposes such as including you on a marketing mail list, fundraising or research. Please note, however, that unless you provide us with your express consent for this purpose, we will not use your information in this way.
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Pastoral care
We may provide your information to chaplains accredited with our hospitals in order that you may receive pastoral care during your admission. However, we will only provide your information for this purpose with your express consent.
Please note, Songa may use or disclose your personal information as specified above via electronic processes, where available or relevant.
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CCTV
Songa does use camera surveillance systems (commonly referred to as CCTV), at many of its facilities for the purpose of maintaining the safety and security of its staff, patients, visitors and other attendees to those facilities. Songa's CCTV systems may, but will not always, collect and store personal information. Songa will comply with the APPs and this Privacy Policy in respect of any personal information collected via its CCTV systems.
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Contracted services
Songa provides some health services to public patients and to groups such as Defense or Customs personnel under contracts with government. Where you receive services from us under any such arrangements Songa will provide your personal and health information to those government agencies as required under those contracts.
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Job applications
Songa collects personal information of job applicants for the primary purpose of assessing and (if successful) engaging applicants.
The purposes for which Songa uses personal information of job applicants include:
- managing the individual's employment or engagement;
- insurance purposes;
- ensuring that it holds relevant contact information; and
- satisfying its legal obligations.
Songa may also store information provided by job applicants who were unsuccessful for the purposes of future recruitment.
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Application for accreditation by health professionals
Songa collects personal information from health professionals seeking accreditation and submitting to the credentialing process under its Facility Rules. Personal information provided by health professionals in this context is collected, used, stored and disclosed by Songa for the purposes of fulfilling its obligations in connection with the Facility Rules.
2.3 Access to and correction of your health information
You have a right to have access to the health information that we hold in your health record. You can also request an amendment to your health record should you believe that it contains inaccurate information.
Songa will allow access or make the requested changes unless there is a reason under the Privacy Act 1988 (IQQ) or other relevant law to refuse such access or refuse to make the requested changes.
If we do not agree to change your medical record/personal information in accordance with your request, we will permit you to make a statement of the requested changes and we will enclose this with your record.
Should you wish to obtain access to or request changes to your health record you can ask for our Privacy Officer (see details below) who can give you more detailed information about Songa's access and correction procedure.
Please note that Songa may recover reasonable costs associated with supplying this information to you.
2.4 Data quality
Songa will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date.
2.5 Data security
Songa will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorized access, modification or disclosure. We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect your privacy.
Songa will destroy or permanently de-identify any of your information which is in its possession or control and which is no longer needed for the purpose for which it was collected provided Songa is not required under an Iraqian law or court/tribunal or otherwise to retain the information.
