PwC Perth Pilot Privacy Statement

MediBio & Vital Conversations

Privacy Policy and Data Security & Management

 

Vital Conversations and Medibio are committed to upholding the privacy of all participating individuals and organisations. The two entities have individual best practice standards for the management of confidential and personal information and they are outlined in the following Privacy Policy Statement.

 

Vital Conversation Privacy Policy

Pilot Program – Medibio & Vital Conversations

Privacy Policy for Management of Personal Information

This document describes the privacy policy of Vital Conversations (VITAL) for the management of clients’ personal information. The psychological service provided is bound by the legal requirements of the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

Client information

Client files are held in a secure filing cabinet and our secure electronic document management systems, (Accelo) which is accessible only to authorised employees. The information on each file includes personal information such as name, address, contact phone numbers, medical history, and other personal information collected as part of providing the psychological service.

How clients’ personal information is collected

A client’s personal information is collected in a number of ways during psychological consultation with VITAL, including when the client provides information directly to VITAL using hardcopy forms, correspondence via email, when the client interacts directly with (“Insert name of Psychologist/Practice) employees such as the receptionist, and when other health practitioners provide personal information to VITAL, via referrals, correspondence and medical reports.

Consequence of not providing personal information

If the client does not wish for their personal information to be collected in a way anticipated by this Privacy Policy, VITAL may not be in a position to provide access to the trial and subsequent psychological service to the client. Clients may request to be anonymous or to use a pseudonym, unless it is impracticable for VITAL to deal with the client or if VITAL is required or authorised by law to deal with identified individuals. In most cases it will not be possible for the client to be anonymous or to use a pseudonym, however if the VITAL agrees to the client being anonymous or using a pseudonym, the client must pay consultation fees at the time of the appointment.

Purpose of holding personal information

A client’s personal information is gathered and used for the purpose of providing psychological services, as part of the PwC trial, which includes analysis of assessment data, follow up of scores and in the event of a client engaging VITAL for psychological services, for the purpose of diagnosing and treating a client’s presenting issue. The personal information is retained in order provide proof of client’s participation in the trial, unidentified data for analysis, and to document what happens during sessions, and enables the psychologist to provide a relevant and informed psychological service. 

Disclosure of personal information

Clients’ personal information will not be disclosed except when:

  1. It is subpoenaed by a court; or
  2. Failure to disclose the information would in the reasonable belief of VITAL place a client or another person at serious risk to life, health or safety; or
  3. The client’s prior approval has been obtained to:
    1. provide a written report to another professional or agency, e.g., a GP or a lawyer; or
    2. discuss the material with another person, e.g. a parent, employer or health provider; or
    3. disclose the information in another way; or
    4. you would reasonably expect your personal information to be disclosed to another professional or agency (e.g. your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which your personal information was collected; or
    5. Disclosure is otherwise required or authorised by law.

A client’s personal information is not disclosed to overseas recipients, unless the client consents or such disclosure is otherwise required by law. Clients’ personal information will not be used, sold, rented or disclosed for any other purpose.

Requests for access and correction to client information

At any stage clients may request to see and correct the personal information about them kept on file. The psychologist may discuss the contents with them and/or give them a copy, subject to the exceptions in the Privacy Act 1988 (Cth). If satisfied that personal information is inaccurate, out of date or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected. All requests by clients for access to or correction of personal information held about them should be lodged with Peta Slocombe – Managing Director of Vital Conversations. These requests will be responded to in writing within 14 days, and an appointment will be made if necessary for clarification purposes.

Concerns

If clients have a concern about the management of their personal information, they may inform Peta Slocombe – Managing Director of Vital Conversations. Upon request they can obtain a copy of the Australian Privacy Principles, which describe their rights and how their personal information should be handled. Ultimately, if clients wish to lodge a formal complaint about the use of, disclosure of, or access to, their personal information, they may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at http://www.oaic.gov.au/privacy/making-a-privacy-complaint or by post to:

Office of the Australian Information Commissioner.

 

In Summary

  • Vital Conversations abides by the Australian Psychological Society’s’ requirements for the storage of records by a Psychological Practice.
  • Vital Conversations Psychologists involved in data collection and analytics throughout this trial are Registered AHPRA and Psychologists Board Australia members and abide by rigorous standards of compliance accordingly.
  • Physical records: This includes the identification of files, locked storage for hard copy information and the requirement that no private or confidential information is disclosed except where subpoenaed by a court of law.
  • Exceptions occur only where non-disclosure is likely to result in the risk of harm to self or others as a result of non-disclosure.

 

Medibio Privacy Statement

  • Security and confidentiality of employee information will be maintained according to strict Medibio privacy rules self-report instruments will be identified by a participant number rather than the employee name
  • Questionnaires to obtain medical history and demographic information will be identified by participant number these will be kept secure in locked cabinets at all times, accessible only to authorised Medibio staff
  • Identifying information is never to be saved with employee personal data
  • Identifying details are to be kept in password protected files on secure servers accessible only to authorised Medibio staff
  • Only de-identified company aggregated data may be transferred to parties other than the employee and only with the expressed permission of the employee

Data management.

  • ECG data will be de-identified, cleaned, and formatted for review and analysis
  • ECG data will be stored on secure servers accessible only to authorised Medibio staff.
  • ECG information will be sent through secure de-identified means.

Data from the trials will be used to contribute to baseline data in the empirical self-measurement of stress.  A dashboard of unidentifiable information will be provided to the client organisation sponsor (Justin Carroll, PwC Perth) with trends and outcomes from pre and post intervention for the workforce participants in the trial. 

Medibio and Vital Conversations will not in any way identify participating organisations, nor the data from participating organisations, without the written consent of PwC.  Cloud based storage will have coded and de-identified information of organisations. 

Vital Conversations expects PwC employees will comprise approximately 30% of the participants in this trial.  Vital Conversations reserves the right to report outcomes of the effectiveness of the device in broad terms without reference to either the names of participating organisations, nor is the individual client themselves.

For further information: Call 08 9382 8274 or email: info@vitalconversations.com.au