Policies

Opportunities are available for patients and other visitors to tell us, “How we are doing” and we collect systematic patient experience feedback at least every three (3) years. 

The practice information sheet and website provide patients with information on how to provide feedback, including how to make a complaint. 

We have a complaints resolution process which all members of the practice team can describe, and we also make the contact details for the Victorian health complaints agency readily available to patients if we are unable to resolve their concerns.

Patients have a ‘right to complain’ and where possible, patients and others are encouraged to raise any concerns directly with the practice team who are all trained to make sure patients of the practice feel confident that any feedback or complaints made will be handled appropriately. We believe most complaints can be responded to and resolved at the time the patients or other people such as carers, relatives, friends, or other consumers make them known to our team. 

Under national and Victorian privacy laws, our practice provides and adheres to a complaints process for privacy issues and those related to the Australian Privacy Principles (APPs).

All members of our practice team are educated to be prepared to address complaints as they arise. Depending on the nature of the complaint and any advice received from our medical indemnity insurers where required, complaints are recorded and actioned with a copy placed in the patient’s health record if related to patient care.

All clinical and medical staff, as well as administration staff, are aware of the professional and legal obligations regarding the mandatory reporting of unprofessional conduct.

Verbal complaints are handled either by senior reception staff or the practice owner, who takes the patient to a quiet area to discuss their problem. Written complaints are discussed with the practice owner and the principal doctor and a response, written or verbal will be prepared.

Our complaints handling process aims to minimise patient anxiety or hostility, which may lead to litigation. We follow these steps:

  • Inform the staff member responsible for the complaint.
  • For verbal complaints, escort the patient to a private area to discuss.
  • Listen attentively, take notes and repeat key concerns to reassure the patient you understand their complaint.
  • Assure the patient we will take their complaint seriously and thoroughly investigate it.
  • Document the complaint in a memorandum and record details in the complaints register.
  • Notify the patient’s GP.
  • Contact the patient within two working days after they lodge a complaint, and continue to update them during the investigation so they know we care.
  • For a clinically-based complaint, contact the treating GP’s medical defence organisation for advice.
  • Decide on an appropriate resolution, and notify the patient. 
  • Document all communication with the patient, including written responses. 
  • Review the complaint at our next team meeting to discuss how it could have been prevented.

Procedure

Patients and others have opportunities to register their complaints either verbally, in writing or via our suggestion box. Patients or others are able to complain anonymously if desired.

All members of our practice team are educated to be prepared to address complaints as they arise.

When receiving complaints, our practice keeps in mind the following in order to minimise further patient anxiety and hostility:

  • Handle all complaints seriously, no matter how trivial they may seem.
  • Verbal complaints made in person should be addressed in a private area of the practice where possible.
  • Use tactful language when responding to complaints.
  • Do not blame others; patients may not have all the facts or they may distort them.
  • Address the patient’s expectations regarding how they want the matter resolved.
  • Assure the patient that their complaint will be investigated and the matter not disregarded.
  • Offer the person an opportunity to complete a formal complaint form (they may accept or decline).
  • Document all complaints and other relevant information and place this in the complaint folder so the person designated to manage complaints is informed of the complaint (even if the matter appears to have been resolved).
  • Alert the general practitioner about disgruntled or hostile patients so they can diffuse the situation immediately – often patients are reluctant to make a complaint directly to a general practitioner.
  • Always inform the person designated to manage complaints if you become aware of any significant statements made by the patient or significant change in patient attitude.

The practice has appointed Masum Rashid with designated responsibility for seeking, collecting, analysing, investigating, resolving and managing all feedback and complaints. Any investigation and resolution of complaints is undertaken using an open disclosure process, incorporating the following:

  • Acknowledge the patient’s right to complain.
  • Acknowledge receipt of the complaint as soon as possible, but within two (2) working days using the Acknowledgment of Complaintletter template.
  • Respond to all complaints as soon as reasonably practicable, but within thirty (30) days in an open and constructive manner including an explanation and if appropriate an apology.
  • If a resolution of the matter is to take longer than thirty (30) days, an update of the resolution activities will be provided to the patient, with an anticipated revised timeframe for resolution.
  • Work with the patient to resolve the complaint and communicate the outcome with the patient, including any changes made as a result of the complaint.
  • As a routine, contact the practice’s insurer when there is a complaint about a member of the medical or clinical team in order to seek advice on resolving the complaint before any action is taken.
  • Where a complaint is made against a practice team member, provide the team member with an opportunity to discuss the details in a private setting.
  • Ensure the complaint does not adversely affect the patient’s care.
  • Record the complaint, investigation and actions in the dedicated complaints file and, if related to patient care, include a copy in the patient’s health record.
  • Ensure, where appropriate, complaints are reviewed at practice team meetings; analyse trends and discuss the methods of resolution.
  • Review other types of patient feedback (i.e. feedback surveys, suggestion box) during practice team meetings.
  • Keep a record of improvement(s) made in response to feedback or complaints.
  • Where appropriate, inform the patient about practice improvements made as a result of their input.

If the matter cannot be resolved, the patient is advised about how to contact the external health complaints agency for our Health Complaints Commissioner.

Victoria

Office of the Health Services Commissioner

Telephone: 1300 582 113

Our practice is mindful that even if patients have provided electronic contact details, they may not be proficient in communicating via electronic means and patient consent needs to be obtained before engaging in electronic communication. Electronic communication includes email, facsimile and Short Message Service (SMS).

Communication with patients for health management purposes via electronic means is conducted with appropriate regard to privacy

The health management purposes include:

Reminders – appointment, disease prevention, health promotion activities and health checks

Recalls – follow up, periodic medical / pathology review, and urgent reviews

Patient authorisation for SMS contact requires:

  • Patient signature in the appropriate section of our New Patient Registration form (scanned to patient file).
  • Confirmation of mobile number at each visit.
  • The message not to include sensitive health information (e.g pathology results).
  • The message to include practice name and how to contact the practice (e.g Better Health Family Clinic, Tel: 03 9702 9300).
  • Inclusion of the message in the patient’s record.

Considerations when using SMS reminder systems:

  • The SMS reminder to the patient is recorded in the patient file
  • The practice sees a record of the patient SMS reminders sent
  • There is a register accessible by the practice to view the patient responses to the SMS reminders
  • The practice is able to identify a SMS reminder sent to a patient for a flagged recall  or reminder and the response from the patient in order to ensure appropriate action to nil or no responses by the patient.
  • Understand what the SMS software does when the patient provides a nil or no response – what is the appointment automatically cancelled? is there a record in the patient file of the nil or no response? how is a flagged recall or reminder managed?

 

 

Patient Electronic Contract

Procedure

Electronic Communication Confidentiality

Communication with patients via SMS must be conducted with appropriate regard to the privacy and confidentiality of the patient’s health information.

The practice provides the team with regular updates and training on privacy and confidentiality, as well as part of the new staff induction program.

Our practice provides health services to a diverse and multicultural population, including people with disability and those from non-English-speaking backgrounds (NESB).

We recommend NESB patients use a professional interpreter service to assist them during consultations. They may wish to enlist a translator who is a family member or friend, however we discourage children from translating on their parent’s behalf. And in some cases, having a family member or friend translate is also not appropriate, for the following important reasons:

  • sometimes the patient is reluctant to disclose information to someone they know
  • a relative or friend may inadvertently or deliberately relay biased translation of information.

We advise patients to use the Translating and Interpreting Service (TIS) – Doctors Priority Line (1300 131 450). This is a free service, available 24 hours a day by phone at the time of consultation or with 48 hours’ notice, onsite at the practice.

As well as impartiality and greater accuracy, we prefer professional interpreter services over family or friends translating for a patient because they:

  • enhance our provision of quality patient care
  • offer confidentiality
  • understand the importance of risk management
  • provide efficient, effective communication of information in sometimes time-critical situations
  • adhere to professional conduct at all times, not being emotionally involved with patients.

Visit the TIS website for further information about the their services.

Hearing Impaired Patients

A free interpreting service is available for patients who are deaf and use Australian Sign Language (AUSLAN). Contact the National AUSLAN Interpreter Booking and Payment Service (NABS) on 1800 246 945 or the NABS website for further information.

Culturally Appropriate Care

Our practitioners find it valuable to have information about a patient’s cultural background. We use the following guidelines for developing our practice’s approach.

  • Not all patients wish to identify their cultural background. This needs to be respected, and the practice needs a system for noting this in the patient’s file.
  • Patients may be willing to have a discussion relating to their cultural background with some team members, but not others. For example, with the nurse, but not the receptionist. Encourage all team members to complete this information.
  • Have a range of standard phrases to assist staff to encourage patients to self-identify. For example:
    • Are you of Aboriginal or Torres Strait Islander origin?
    • Would you mind completing this section? (Point to the question on the form)
    • We are updating all patient records in relation to cultural identity.

Procedure

Our practice recommends translating and interpreting services to patients in the following ways:

  • GPs and clinical staff – providing TIS contact details during a consultation
  • Reception staff – when booking appointments

All doctors in this practice are registered with the TIS. Details of each doctor’s TIS registration number are located at [insert location].

If TIS National is the chosen option book an interpreter by ringing the Doctor Priority Line Tel: 1300 131 450 (free service) or booking on line or by fax.

This 24 hour service is available via telephone at the time of consultation, or if appropriate advance notice is given (usually 48 hours), the interpreter can be on site at the practice during a consultation (subject to availability) or at the patients home.  If an interpreter is attending the practice or home it is important to ensure the appointment starts on time.

OPTIONAL

 

The following is our practice’s protocol when assisting NESB patients:

The Translating and Interpreting Service (TIS National) provides access to phone and onsite interpreting services in over 160 languages and dialects. Further information is available at www.tisnational.gov.au 

 

 

Culturally Appropriate Care

In our practice, we encourage patients to self-identify their cultural background (e.g. Aboriginal and Torres Strait Islander self-identification) when they register with the practice.

We have identified the main cultural groups in our practice and endeavour to provide culturally appropriate written health information.

We collect information about the country of birth, languages spoken and any other additional cultural information. We have a system to regularly update our patient information using a standard Update Your Details Form.

The standard indigenous status question asked is “Are you of Aboriginal or Torres Strait Islander origin?” This question is asked of all patients, irrespective of appearance, country of birth or whether our practice team members know of the patient or their family background. Our practice collects this information from patients initially as part of our New Patient Information Form.

Our clinical software has the option to input Aboriginal and/or Torres Strait Islander status or other cultural backgrounds; therefore, we use the drop-down options rather than free-text to assist with extracting the information for preventative activities.

 

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 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?

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.

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. Further, information can also be collected through electronic transfer of prescriptions (eTP), My Health Record, eg via Shared Health Summary, Event Summary
  3. 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.
  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).

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, Event Summary).

We use document automation, where only relevant data is collected when preparing documents for third party stakeholders.

Any information being transmitted to third parties are through secure and encrypted channels.

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 e.g. as paper records, electronic records, visual records (X-rays, CT scans, videos and photos), audio recordings.

Our practice stores all personal information securely. All information is protected by passwords, firewalls, anti-malware, anti-virus software and the server is in a securely locked room. Staff access to information is limited and all staff are bound by confidentiality agreements.

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 our practice will respond within 30 days. The collation and handing over of this information will incur a cost of which you will be informed.  

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 practice/practice manager or by emailing to info@betterhealthfamilyclinic.com.au

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. You can let us know;

  • in person;
  • by calling us on 03 9702 9300;
  • in writing to Better Health Family Clinic,127- 129 Somerville Road, Hampton Park, VIC 3976; and
  • by email to info@betterhealthfamilyclinic.com.au.

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.

Privacy and our website

We may collect information about how you access and use our website, including your IP address, browser type, and the pages you visit. We also use cookies and similar technologies to enhance your experience and analyse website traffic.

Privacy and Social Media

We may collect information about your interactions with our page, including your IP address, browser type, and the posts you visit.

Policy review statement

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