Privacy Policy
Introduction
This privacy policy is to provide information to you, our patient, on how your personal information (which includes your health information) is collected and used within our practice, and the circumstances in which we may share it with third parties.
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 that need to see your personal information will have access to it. If Cranebrook need to use your information for anything else, we will seek additional consent from you to do this.
Cranebrook Doctors recognises the importance of protecting the privacy and the rights of individuals and patients in relation to their personal information and health. This document is Cranebrook Doctors’ privacy policy and it tells you how we collect and manage your personal information.
Our Practice is governed by a number of state specific privacy laws. Cranebrook Doctors respect your right to privacy and have a legal obligation to abide by the Privacy Act 1988. The rules and regulations under the Privacy Act are known as the Australian Privacy Principles or the APP.
What is a patient health record?
Medical records, whether electronic or not, are a collection of information about a patient’s healthcare that are essential for his or her present and future care (WHO 2001) and are covered by s.3 of the Health Records Act 2001 (AustLII 2012).
As such, the medical record must contain sufficient information to identify the patient to whom it relates, as we ensure information relevant to the patient’s treatment during current and future episodes of care, for example:
the patient’s medical history
the orders and results of any physical examination or tests
information relating to allergies
other factors that may need special consideration.
Secure and guaranteed access to complete information collected in the medical record is essential to ensure that healthcare professionals have the right information available when and where they need it. This maximises the quality and efficiency of the treatments they can provide to their patients at the point of care.
What is personal information?
Your personal information is any information that Cranebrook Doctors can be used to personally identify you. This includes but is not limited to your name, date of birth, address, telephone number, email address and profession or occupation. If you are reasonably identified form the information collected by us, the information is considered personal information. Our privacy policy covers all patients and anyone who uses our services.
What is sensitive information?
Sensitive information is any information that is necessary for us to collect in regards to your healthcare. This information may include family, social or medical history, genetic information and emergency contact. In this policy both personal and sensitive information are referred to as “personal information”
What personal information do Cranebrook collect and hold?
Cranebrook Doctors collects and stores personal information such as:
your name, address and telephone number;
your age or date of birth;
your Medicare number, Veterans’ Affairs number, Health Care Card number, health fund details or pension number;
current and past medications and or treatments;
information relevant to your medical care, including but not limited to your previous and current medical history and your family medical history (where clinically relevant);
your ethnicity;
occupation or job title;
the name of any health service provider or medical specialist to whom you are referred, copies of any letters of referrals and copies of any reports back; and
any additional information relating to you that you provide to us directly through our representatives, medical or allied health professionals providing services at or from our Centres, Clinics or Call Centres, or otherwise.
Cranebrook may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys.
How do Cranebrook collect your personal information?
Cranebrook Doctors collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:
by you completing one of our patient registration forms;
or disclosed by you during a consultation with your GP, one of our Registered Nurses or Allied Health Professionals 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).we may also collect your personal information when you telephone us or make an online appointment.
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.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information required:
We may not be able to provide the requested services to you, either to the same standard or at all; or
your diagnosis and treatment may be inaccurate or incomplete.
there may be risks to your health outcome
Why do we collect, use, hold and share your personal information?
Our practice will need to collect your personal information to provide healthcare services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your health.
We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training).
to deliver medical services and treatment to you, and to enable you to be attended by medical practitioners, registered nurses and other allied health professionals at Cranebrook Doctors
for organizational, administrative and billing purposes;
to keep your contact details up to date;
to process and respond in the event that a complaint is made by you;
to comply with any law, rule, regulation, decision or direction of a regulator, or in cooperation with any governmental authority;
for the purposes of data research and analysis including conducting clinical trials and proactive screenings and for the purpose of sending you direct marketing communications in relation to these;
for inclusion in a recall and reminder system to be advised of follow up visits and health promotion;
to answer enquiries and provide information or advice about existing services and all matters relevant to the services we provide to you;
to meet requirements of notification to our medical defence organisations or insurers.
Your personal information is not shared, sold, rented or disclosed other than as described in this Privacy Policy or as permitted under the Act.
Telehealth
Cranebrook Doctors does not conduct audio/visual recorded telehealth. When/if the practice conducts telehealth consults onsite or remotely they will only use telephone consultations. Doctors will acquire verbal patient consent for entering a record of your consultation in your patient chart. The patient record will be notated accordingly.
AI
Notes
At Cranebrook Doctors, we leverage advanced AI technology to assist our doctors in recording medical notes more efficiently. Our goal is to enhance the quality and accuracy of documentation while maintaining the highest standards of patient care.
Doctor Review.
While AI tools assist in the note-taking process, every medical note is carefully review and finalized by your doctor. AI serves as a support tool — your doctor remains fully responsible and in control of your medical records and care decisions.
Patient Information Stays Private
We are committed to protecting your privacy. All medical information handled through AI-assisted processes is kept secure and confidential, in compliance with all relevant privacy laws and regulations. Your trust and confidentiality are paramount.
Review and Updates
This policy will be reviewed annually or as required to accommodate technological advancements or regulatory changes.
How do Cranebrook Doctors store and protect your personal information?
Your personal information is stored electronically.
Our practice is considered paperless and has systems in place to protect the privacy, security, quality and integrity of the personal health information held electronically. Appropriate staff members are trained in computer security policies and procedures.
All personal information including patient health records, visual records (X-rays, CT scans, videos and photos), and audio recordings are stored electronically.
Our practice ensures that our practice computers and servers comply with the RACGP computer security checklist and that:
computers are only accessible via individual password access to those in the practice team who have appropriate levels of authorisation.
computers have screensavers or other automated privacy protection devices are enabled to prevent unauthorised access to computers.
servers are backed up and checked at frequent intervals, consistent with a documented business continuity plan.
back up information is stored in a secure off-site environment.
computers are protected by antivirus software that is installed and updated regularly
computers connected to the internet are protected by appropriate hardware/software firewalls.
Cranebrook have a business continuity plan that has been developed, tested and documented.
The quality of the personal information Cranebrook hold.
All staff and contractors must sign confidentiality agreements prior to commencing work with our practice.
It is most important that we have up to date personal information on your file. Please ensure that any changes to your personal information are updated promptly with our reception staff. Out of date or incorrect information could lead to adverse health outcomes.
When, why and with who do we share your personal information?
Sometimes Cranebrook are required to 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 only sharing relevant health information.
Document automation ensures only relevant information is included.
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, Event Summary).
Only people who need to access your information will be able to do so. All referral templates including those that utilise document automation technology are regularly reviewed to ensure only relevant medical information is included and released to a third party.
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.
Direct marketing materials
We may send you information our about services that we consider may be of interest to you. This information may be sent via SMS, email or post in accordance with all marketing laws such as the Spam Act 2003. You can opt out of receiving such material from us at any time. Please inform our reception staff if you do not wish to receive this information from us.
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 to:
Office Manager, Cranebrook Doctors
Our practice will respond to your request for access within 30 days. There may be a fee for access to information. This fee covers any administrative costs associated with access.
There may be instances where Cranebrook cannot grant you access to the personal information Cranebrook hold; however, we will only do so in accordance with our rights and obligations under the Act. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, 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 to:
The Office Manager, Cranebrook Doctors
Our practice will respond to your request within 30 days.
How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?
Cranebrook take complaints and concerns regarding privacy seriously.
You should express any privacy concerns you may have in writing. Cranebrook will then attempt to resolve it in accordance with our resolution procedure. Such requests should be made in writing and addressed to: Office Manager, Cranebrook Doctors
Our practice will respond to your request within 30 days.
You may also contact the OAIC. Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992.
If you believe that your privacy has been breached, please contact us in accordance with the arrangements set out below and provide details of the incident so that Cranebrook can investigate it.
Do we disclose your personal information to anyone outside Australia?
Cranebrook Doctors does not disclose your personal information to overseas recipients. In the event that we are required to do so, we will obtain your consent.
Security
We take all reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. we hold your information electronically. Personal information is destroyed or de-identified when no longer needed.
Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact Cranebrook Doctors, in writing at the details below.
we will treat your requests or complaints confidentially. Cranebrook doctors will aim to ensure that your concern is resolved in a timely and appropriate manner.
The Office Manager
Cranebrook Doctors,
Reviews and Updates of our privacy policy
This policy is reviewed and updated annually. Updated versions of this privacy policy will be available on our website and from reception. This privacy policy was last updated on 13/06/2026
Review:
June 2027
Meeting your privacy obligations
Use of this template does not guarantee compliance with the Privacy Act. It is intended as a guide of a general nature only. The content of this template incudes general statements, which practices may need to amend to ensure the policy accurately reflects the way an individual practice operates and meets its privacy obligations. Practices using this template should seek appropriate legal or other professional advice if they have specific concerns or privacy needs not covered in this template.
The objective of this document is to provide you, our patient, with clear information on how your personal information is collected and used within the practice. Occasionally we also need to share your personal information to involve others in your healthcare and this policy outlines when, how, and why we share your information.
1. Who can I contact about this policy?
For enquiries concerning this policy, you can contact 9249 9111.
Ensure that contact details are up to date and readily accessible for patients seeking information regarding the privacy policy. You may choose to provide a generic email address that is regularly monitored as a point of contact rather than a specific member of the practice team.
2. When and why is your consent necessary?
When you register as a patient of this practice, you provide consent for the GPs and practice staff to access and use your personal information to facilitate the delivery of healthcare. Access to your personal information is restricted to practice team members who require it for your care. If we ever use your personal information for purposes other than outlined in this document, we will obtain additional consent from you. It is important to us that as our patient, you understand why we collect and use your personal information.
By acknowledging this Privacy Policy you consent to us collecting, holding, using, retaining and disclosing your personal information in the manners described below.
Ensure the practice patient registration form, or other processes, include a section for obtaining and documenting consent for the use of personal information. It is also important to create a culture with the practice team in relation to obtaining express consent for any non-healthcare-related use of patient information, such as seeking specific consent for direct marketing of the practice services.
Why do we collect, use, store, and share your personal information?
The practice collects, uses, stores, and shares your personal information primarily to manage your health safely and effectively. This includes providing healthcare services, managing medical records, and ensuring accurate billing and payments. Additionally, we may utilise your information for internal quality and safety improvement processes such as practice audits, accreditation purposes, and staff training to maintain high-quality service standards.
Ensure the practice team are aware of the various purposes for which patient information may be collected, used, held, and shared. Maintain transparency with patients regarding the reasons for collecting and utilising their personal information to build trust and confidence in the practice.
4. What personal information is collected?
The information we will collect about you includes your:
- names, date of birth, addresses, contact details
- medical information including medical history, medicines, allergies, and adverse reactions immunisations, social history, family history and risk factors
- Medicare number (where available) for identification and claiming purposes
- healthcare identifier numbers
- health fund details.
5. Can you deal with us anonymously?
You can 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.
Ensure that patients are informed of their right to deal with the practice anonymously or under a pseudonym. Make provisions to accommodate anonymous or pseudonymous interactions unless impracticable.
Dealing with general practices anonymously
The Privacy Act requires patients to be provided with the option of not identifying themselves, or of using a pseudonym, when dealing with a practice unless it is impracticable to do so. Information about this should appear in the practice privacy policy.
The Privacy Act 1988 requires practices to consider whether it is practical to give patients the option of not identifying themselves, or using a pseudonym. However, practices do not have to deal with patients anonymously or pseudonymously. The OAIC website provides further information in this topic here.
6. How is personal information collected?
The practice may collect your personal information in several different ways:
When you make your first appointment, the practice team will collect your personal and demographic information via your registration.
Ensure that a collection statement is attached to/within the patient registration form to inform patients about the information being collected and its purpose.
We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment, or communicate with us using social media.
Assess whether these methods of collecting personal information apply and amend the statement accordingly. Specify the participation status of your practice in digital health services such as the use of online appointment technology of the My Health Record for transparency.
In some circumstances, personal information may also be collected from other sources, including:
- 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 (if relevant).
- While providing medical services, further personal information may be collected via:
• electronic prescribing
• My Health Record
• online appointments.
Assess whether these methods of collecting personal information apply and amend the list accordingly. Specify the participation status of your practice in digital health services such as the use of online appointment technology or the My
Health Record for transparencу.
Various types of images may be collected and used, including:
- CCTV footage: Collected from our premises for security and safety purpose
If there is CCTV in the practice you may want to place signs in the waiting rooms and other areas where footage is captured.
Using personal devices for medical images
The guidelines on using personal devices for medical images should align with Australian privacy obligations, particularly the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). The RACGP resource Using personal mobile devices for clinical photos provides further information on the considerations required when taking clinical photos on a personal mobile device that belongs to a clinician and is used outside of the workplace.
Compliance with privacy obligations
To comply with Australian privacy obligations when collecting personal information from third-party sources, you must understand and adhere to the Privacy Act 1988 and the Australian Privacy Principles (APPS) this includes:
- verifying third-party compliance
- ensuring informed consent
- collecting only necessary data
- maintaining data accuracy
- updating your privacy policy and notifying patients of these updates as required
- protecting data with strong security measures
- facilitating individuals’ rights to their data
- providing regular education and training for the practice team on privacy practices.
To ensure compliance, you can include the following line in the privacy policy:
“We will always comply with privacy obligations when collecting personal information from third-party sources. This includes ensuring transparency with patients, obtaining necessary consents, maintaining data accuracy, securing the information, and using it only for specified purposes.”
7. When, why and with whom do we share your personal information?
We sometimes share your personal information:
- with third parties 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 (e.g. In referral letters)
- when it is required or authorised by law (e.g. 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 it is a statutory requirement to share certain personal information (e.g. some diseases require mandatory notification)
- When it is provision of medical services, through electronic prescribing, My Health Record (e.g. via Shared Health Summary, Event Summary).
You will need to specify if the practice uses any of the above digital health tools. Are there any other usual disclosures specific to the practice which you should include here?
Only people who need to access your personal information will be able to do so. Other than providing medical services or as otherwise described in this policy, the practice will not share personal information with any third party without your consent.
We do not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
Alternatively, if the practice is likely to share personal information outside of Australia, clearly set out where it is likely to make those disclosures if it is practicable to do so, e.g., if an overseas transcription service is used you will need to make your patients aware of this. If information is not being sent overseas, state this clearly.
8. Will your information be used for marketing purposes?
The practice will not use your personal information for marketing any 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 the practice in writing.
Medical Board of Australia has requirements for advertising a regulated health service. If your practice is intending to direct marketing for patients please review the guidelines here.
9. How is your information used to improve services?
The practice may use your personal information to improve the quality of the services offered to patients through research, analysis of patient data for quality improvement and for training activities with the practice team.
We may provide de-identified data to other organisations to improve population health outcomes. If we provide this information to other organisations patients cannot be identified from the information we share, the information is secure and is stored within Australia. You can let reception staff know if you do not want your de-identified information included.
At times, general practices are approached by research teams to recruit eligible patients into specific studies which require access to identifiable information. You may be approached by a member of our practice team to participate in research. Researchers will not approach you directly without your express consent having been provided to the practice. If you provide consent, you would then receive specific information on the research project and how your personal health information will be used, at which point you can decide to participate or not participate in the research project.
Definitions of de-identified and personal information
The RACGP Three key principles for the secondary use of general practice data by third parties defines de-identification as: the removing or altering information that identifies an individual or is likely to do so. Where information has been appropriately de-identified, it is no longer considered ‘personal information’ and can therefore be used or shared in ways that de-identified might not otherwise be permitted under the Privacy Act 1988 (Cwlth). A general practice can therefore lawfully share patient data without specific or express patient consent.
When personal information (i.e., data has not been de-identified) is requested by a third party, specific patient consent is usually needed, and the requesting entity will need to meet the requirements of a human research ethics committee.
Use of de-identified patient data
If the practice routinely provides patient health information to other organisations for secondary use the practice should make patients aware that this is occurring by including this information as part of the privacy policy. Practices should give patients assurances and advice on their rights and how their data is protected and must state the practice’s approach to collection of healthcare information for primary and secondary purposes. Whilst patient consent for sharing de-identified practice data is not a legal requirement, it is good practice to have a procedure for ensuring patients who do not consent to secondary use of data are removed from any data extraction process. Most data extraction tools have this functionality.
10. 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 quidance.
11. How are Artificial Intelligence (Al) Scribes used?
The practice uses an Al scribe tool to support GPs take notes during their consultations with you. The Al scribe uses an audio recording of your consultation to generate a clinical note for your health record. The practice Al scribe service is
Heidi.
- does not share information outside of Australia
- stores the audio file once the transcription is complete.
- retains sensitive, personal identifying information as part of the transcription
The practice will only use data from our digital scribe service to provide healthcare to you.
If you do not use an Al scribe service this section can be removed
If you do use an Al scribe service, you will need to delete the relevant information in the list above to accurately reflect how your Al scribe service manages patient data.
Use of artificial intelligence (Al) scribes
It is important practices understand the new and relatively high potential risks when considering the use of commercially available artificial intelligence (Al) scribes. Practices and GPs choosing to deploy Al scribes need to consider the implications both when selecting and using these tools.
The RACGP guidance on Artificial Intelligence (Al) Scribes provides more information on Al scribes.
GP’s should also give individual patients the option to opt out of the use of Al scribes when required.
12. How is your personal information stored and protected?
Your personal information may be stored in various forms.
- Specify the ways in which the practice stores information, such as paper records, electronic records, visual records (e.g.. X-rays, CT scans, videos, and photos), and audio recordings.
- The practice stores all personal information securely.
- Explain how personal information is securely stored and protected, such as electronic format, in protected information systems or in hard copy format in a secure environment.
- Provide examples like passwords, secure cabinets, and confidentiality agreements for staff and contractors. However, avoid providing details that would jeopardize the effectiveness of your security measures.
- Add CCTV information e.g., our practice has this, and provide details of recordings and storage and access store these recording and the areas that have this in the practice e.g., excluding consulting and treatments rooms and including car park entry etc.
13. How can you access and correct your personal information at the practice?
You have the right to request access to, and correction of, your personal information.
The practice acknowledges patients may request access to their medical records.
Provide details of any fees that may be associated with providing this information if applicable – these must not be excessive. Patients cannot be charged for making the request – only for the costs of complying with the request.
The practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. Sometimes, we will ask you to verify your personal information held by the practice is correct and current. You may request we correct or update your information. To do this please contact via phone on (02) 9249 9117.
14. How can you lodge a privacy-related complaint, and how will the complaint be handled at the practice?
We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have.
We will then attempt to resolve it in accordance with the resolution procedure.
Provide practice contact details such as an email address. You must include mailing address and contact number. Insert tumaround timeframe specific to the practice processes.
If you do not feel we have resolved your issue You may also contact the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner will require you to give them time to respond before they investigate. For further information visit www.oaic.gov.au or call the OAIC (Office of the Australian Information Commissioner) on 1300 363 992.
You could also provide details to contact relevant state or territory health authorities/ombudsman if they also have jurisdiction.
15. How is privacy on the website maintained?
Note: This (e.g., section through is optional.
If you are collecting personal information via the practice website or interact digitally with information that occurs or by email) you need to include a statement about the collection of personal through the website or social media and the use of website analytics, cookies, etc
At Cranebrook and confidentially. Doctors, any This personal practice information you share with us through website, email, and social media, is handled uses analytics and cookies.
16. Policy review statement
Our privacy policy is regularly reviewed to ensure compliance with current obligations.
If any changes are made:
- They will be reflected on the website.
- Significant changes may be communicated directly to patients via email or other means.
Please check the policy periodically for updates. If you have any questions, feel free to contact us.
