Group Privacy Policy


Group Privacy Policy 

1. Purpose

Icon Cancer Centre, previously known as Central Comprehensive Cancer Centre, is made up of some of Hong Kong’s most experienced medical oncologists, and is proud to be part of the Icon Group.

Integrated Clinical Oncology Network Pty Ltd and its subsidiaries (the “Icon Group”, “we” or “us”) is committed to providing exceptional cancer care and treatment and to protecting your Personal Information while doing so.

2. Scope

This Privacy Policy sets out and explains how all members of the Icon Group collect, use, store, protect and disclose your Personal Information.   The Policy is supplementary to any specific consent you provide.  For example, we will normally request your prior written consent for the collection, use or disclosure of your sensitive Health Information.

3. Definitions

Key terms used in this policy are as follows:

Term Definition
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a) whether the information or opinion is true or not; and

(b) whether the information or opinion is recorded in a material form or not.

Personal Information as used in this policy covers Health Information and Sensitive Information.

 

Health Information means: (a) information or an opinion about:

(i) the health or a disability (at any time) of an individual; or

(ii) an individual’s expressed wishes about the future provision of health services to the individual; or

(iii) a health service provided, or to be provided, to an individual;

that is also personal information;

(b) other personal information collected to provide, or in providing, a health service to an individual

(c)  other personal information collected in connection with the donation, or intended donation, by an individual of his or her body parts, organs or body substances;

(d)  genetic information about an individual in a form that is, or could be, predictive of the health of the individual or a genetic relative of the individual.

Sensitive Information Means:

(a)  information or an opinion about an individual’s: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record;

that is also personal information; or

(b)  health information about an individual; or

(c)  genetic information about an individual that is not otherwise health information; or

(d)  biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or

(e)  biometric templates.

 

4. Collection of Information 

We collect Personal Information for the principal purpose of providing you with medical care, treatment and services, as well as for billing and administrative purposes, including submitting health fund claims on your behalf. We will also, where permitted, collect Personal Information for other related or ancillary purposes.

The types of personal information that we collect may include your name, address, telephone number, private health fund membership details, and Health Information such as your past, current, and family health conditions, test results, treatments, procedures and medical advice.

Without limiting the foregoing, we may collect Personal Information from patients that we consider to be reasonably necessary to provide health care services, including:

  • medical history
  • family medical history
  • next of kin
  • ethnic background
  • current lifestyle and activities
  • clinical observations
  • test results
  • billing information
  • private health insurance membership numbers and details of level of cover.

In most circumstances we will collect your Personal Information directly from you rather than third parties.   But if necessary and permitted by law, we may need or be required to collect Personal Information from third parties.  For example, in cases of emergency where collection of your Personal Information is necessary to prevent or lessen a serious and imminent threat to your life or health, then we may collect such information from third parties without your consent if you are physically or legally incapable of doing so.

You are not obligated to disclose your Personal Information to us.  However, if you do not provide the information requested, we may not be able to provide you with the best possible health care or meet the expectations you may have of us as care providers.

In some cases, we will require you to specifically consent to any collection, use or disclosure of your Personal or Health Information as part of a Treatment Consent or Financial Consent, or other specific consent.

In most cases your consent will be requested in writing, but we may also accept your verbal consent.  Sometimes your consent may also be implied through your conduct with us, or due to anticipated activities/reasons ancillary to the primary purpose of your prior consent.

Icon will destroy unsolicited information where it is determined that the information would not normally have been collected

5. Use and Disclosure of Information

We may use and disclose your Personal Information for the purpose for which it was collected, including related secondary purposes, and for other purposes authorised by you or required by law.

Examples of uses and disclosures of your Personal Information may include:

a) Use and disclosure amongst health professionals to provide treatment

Modern health care practices require a patient’s treatment to be provided by a team of health professionals. These health professionals share patient Personal Information as part of the process of providing treatment. This is managed while maintaining confidentiality and protecting the patient’s privacy in accordance with the law. Personal Information will only be disclosed to those health care professionals directly involved in a patient’s treatment. Icon may disclose Personal Information via electronic processes or standard or express post where relevant.

b) A patient’s General Practitioner or referring Medical Specialist

Icon may send a discharge summary or letter to the referring medical practitioner, nominated practitioner and/or General Practitioner following consultation or treatment. This is intended to inform the referring practitioner of information that may be relevant to any ongoing care or treatment provided by them. Icon will confirm the most up to date details of a patient’s nominated General Practitioner at the time of consultation/treatment.

c) Other health service providers

Medical practitioners or health care facilities that require access to patient health records of treatment will require an authorisation from the patient to provide a copy of the medical record to that medical practitioner or health care facility. Disclosure will be provided without consent if it is not reasonable or practicable to obtain consent and Icon reasonably believes that the disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety.

d) Students, medical, nursing, allied health disciplines

Medical, nursing and allied health disciplines undertake placements at Icon facilities. As part of their placement, students may access patient health records of treatment. All students undertaking placement with Icon sign a Confidentiality Agreement.

e) Relatives, guardian, close friends or legal representative

Icon may provide information about a patient’s condition to their parent, child, other relatives or guardians, where the patient is incapable of giving consent or cannot communicate the consent. Icon will disclose Personal Information where it is satisfied that the disclosure is necessary to provide care or treatment to the patient or for compassionate reasons, unless the patient tells Icon that they do not wish Icon to disclose their Personal Information to any such person. Where a patient does not have capacity, Icon will disclose information about the patient’s health to a person exercising that patient’s power of attorney under an enduring power of attorney or advance care directive.

f) Off-shore facilities or entities

Icon may share Personal Information to entities at other Icon Group facilities or other third parties located outside of Singapore.  This may include transfer of Personal Information to Australia for medical or administrative review or support or related activities.

g)  Expanded Communications

We may use your Personal Information in order to provide you with educational, clinical trials, resources, events and/or activities that we consider may be relevant or of interest to you.  We do not sell your Personal Information to any marketing or other third party.

 h) Other common uses and disclosures

Icon may also use and disclose Personal Information in an identified format:

  • for invoicing, billing and account management;
  • for health funds, or other such organisations to verify treatment provided and the financial level of cover;
  • for the purposes of complying with any applicable laws, responding to a subpoena or compulsory reporting to State or Federal authorities (e.g. law enforcement or public health and safety circumstances);
  • when communicating with medical defence organisations, insurers, medical experts or lawyers for anticipated or existing legal proceedings;
  • if it is necessary information for the purposes of protecting a child from the risk of physical or psychological harm;
  • in order to prevent or lessen a serious and imminent threat to life, health or property or a person;
  • if matters are disclosed relating to serious criminal activity that have, or are likely to occur;
  • to third-party service providers who manage some of the services we offer; all of whom are obligated to comply with the PDPA and the Privacy Act 1988 (Cth);
  • to undertake quality assurance for the purpose of monitoring service delivery standards; and
  • for the purposes of sending standard reminders (e.g. appointments or treatment reminders via text message, email, voice mail, or post to addresses disclosed to Icon).

In limited circumstances, we may disclose your Personal Information overseas.  Where information is required to be disclosed overseas Icon will takes reasonable steps to ensure that the international third party uses your Personal Information in accordance with our Privacy Policy.

If you request or authorise Icon to transfer your Personal Information, including your Health Information, to another health service provider, Icon  will provide a copy or a written summary of such to that other health service provider as soon as practicable.

6. Access and Correction of Personal Information

In order to assist us in keeping your Personal Information accurate, complete and up to date, you are requested to promptly notify us of changes or updates to your Personal Information.  You may request access to Personal Information we hold about you by making a written request to our Data Protection Officer, whose details are below. We will respond to your requests within a reasonable period.

If upon receiving access to your Personal Information, or at any other time, you believe the Personal Information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We take reasonable steps to correct your Personal Information so that it is accurate, complete and up to date.

7. Security of Personal Information

Icon stores your Personal Information in both paper and electronic forms.  The security of your Personal Information is important to us. We take reasonable measures to ensure that your Personal Information is stored safely to protect it from misuse, loss, unauthorised access, modification, interference, or disclosure, and take electronic and physical security measures such as:

  • Locked storage of paper records;
  • Use of document shredding and security bins;
  • Authentication and password controls for electronic records;
  • Use of our managed devices and services (e.g. iPads, laptops, email) for transfer of Personal Information.

Icon 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, unless otherwise required by law to be retained.

Periodic audit and risk assessments are conducted to ensure the appropriate availability, integrity and confidentiality of Personal Information managed through our systems.

In the event of a data breach, Icon will take immediate action to mitigate the breach and will comply with the mandatory data breach requirements of the Privacy Act 1988 (Cth). Icon will assess whether there is a likely risk of any serious harm to affected individuals and if so, will immediately notify such individuals with a description of the the data breach, the kinds of information concerned and recommendations about the steps that you should take in response to the data breach.

8. Privacy Policy Changes

Icon may amend the Privacy Policy from time to time in accordance with changes in laws and technology and Icon’s operations and practices.

9. Enquiries and Complaints

If you have an enquiry or complaint about the way Icon handles your Personal Information then please contact our Data Protection Officer, whose contact details are in the section below.   We will respond to your enquiry or complaint as soon as reasonably practicable.  Making a complaint will not affect the care you receive from us, and someone else can make the complaint on your behalf.

11. Contact Details

If you wish to contact us in relation to your Personal Information or any matter in this Privacy Policy, please contact:

Privacy Officer
Icon Group
PO Box 3787
South Brisbane, QLD, 4101, Australia
Switchboard: 07 3737 4500
Fax: 07 3737 4501
Email: privacy@icon.team

A translated copy of this Privacy Policy is available if required and upon request.

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