PRIVACY POLICY

1. Introduction

   1. This Privacy Policy is to provide information to you on how your personal information (which includes your sensitive information, including your/your patient's health information) is collected and used within Dr Keegan's practice, and the circumstances in which we may share it with third parties.

2. Why and how your consent is necessary

   1. When you register as a patient of an independent practitioner who consults from our practice, you provide consent for us (including our employees, agents, contractors and other representatives) to access and use your personal information so the independent practitioners consulting from our practice can provide you with the best possible healthcare. Only persons who need to see your personal information will have access to it. If we need to use your information for any other purposes, we will seek additional consent from you to do so.

3. Why do we collect, use, hold and share your personal information

   1. Our practice will need to collect your personal information to facilitate the provision of healthcare services to you by the independent practitioners consulting from our practice. Our main purpose for collecting, using, holding and sharing your personal information is to facilitate the management of your health by those independent practitioners. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (e.g. staff training).

4. What personal information do we collect

   1. The information we will collect about you includes your:

      1. names, date of birth, addresses, contact details including emergency contact and next of kin;

      2. demographic information, including gender, cultural background, and religious beliefs;

      3. medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors;

      4. Medicare number (where available) for identification and claiming purposes;

      5. healthcare identifiers;

      6. payment and / or financial information;

      7. concession card details; and

      8. health fund details.

5. Dealing with us anonymously

   1. 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.

   2. Please be aware that Medicare rebates are only available where a Medicare card (and / or associated information) is available. As such your practitioner may require you to pay for your consults in full without this rebate if you choose to deal with us anonymously or under a pseudonym.

6. How do we collect your personal information

   1. Ourpractice may collectyour personal informationin several different ways:

      1. You may provide us with your personal information directly (for example, when you make an appointment with an independent practitioner consulting from our practice, our practice staff will collect your personal and demographic information via your registration);

      2. The independent practitioners providing medical services may also collect further personal information from you which may be disclosed to us. Information can also be collected through My Health Record, e.g. via Shared Health Summary, Event Summary or through a Discharge Summary provided by a hospital or other healthcare service providers;

      3. We may also collect your personal information when you contact us via our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media; and

      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:

         1. your guardian or responsible person;

         2. other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services; and / or

         3. your health fund, Medicare, or the Department of Veterans’ Affairs (as necessary).

   2. If your practitioner deems it in your best interest to discuss your clinical information with you, we will arrange for this to occur either in person, via telephone or via videoconference.

7. When, why and with whom do we use and share your personal information

   1. We collect, use and disclose your personal information to facilitate the provision of medical services to patients of the independent practitioners consulting from our practice.

   2. We may also share your personal information:

      1. with other healthcare providers;

      2. when it is required or authorised by law (e.g. court subpoenas, or where we are obliged to make a mandatory notification to a regulatory body);

      3. 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 where it is otherwise impractical to obtain your consent;

      4. to assist in locating a missing person;

      5. to establish, exercise or defend a claim;

      6. for the purposes of confidential dispute resolution processes;

      7. during the course of providing nursing support services;

      8. for the purposes of uploading that information to your My Health Record, such as through the shared health summary or event summary; and / or

      9. 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 the Australian Privacy Principles (APPs) and this policy.

   3. Only people who need to access your information will be able to do so. Other than in the course of facilitating the provision of medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent. 

   4. De-identified patient data may be used for teaching, education, and research purposes. Our practice will take reasonable steps to ensure any such data will not be re-identified and that the data which is used is handled in accordance with applicable laws and ethical standards. 

   5. We may share your personal information with our third party service providers (including third party artificial intelligence software providers) outside Australia (including the Philippines) where it is necessary to support the delivery of healthcare services to you by your independent practitioner. We will take reasonable steps to ensure that any such overseas recipients will comply with the APPs (or a substantially similar law or binding scheme applicable in their jurisdiction) in relation to the collection, use, disclosure, storage and destruction or de-identification of any personal information which may be provided to them prior to making such a disclosure.

   6. 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.

8. Use of artificial intelligence (AI) and technology in healthcare services 

   1. Our practice may facilitate the use of certified, cloud-based third-party applications, including AI-powered tools or software with natural language processing, enhanced search engines or diagnostic support capabilities, to support the provision of healthcare services to you by the independent practitioners consulting from our practice. These applications may be used by our practice or your practitioner for referrals, clinical note-taking, consent processes, bookings and appointments, telephony services, and other similar administrative processes necessary to assist your practitioner to provide you with efficient and high-quality care. 

   2. You will be asked to provide informed consent prior to the use of any such AI applications and the use of any personal information by such applications will be in accordance with the APPs, this policy, and any other regulations or standards which may be applicable to the use of AI in healthcare.

9. How do we store and protect your information

   1. Your personal information may be stored at our practice in various forms.

   2. Our practice stores information as electronic records (including via cloud-based services), visual records (including photos) and archived paper records.

   3. Our practice stores all personal information securely via the use of passwords, encrypted back-ups, confidentiality agreements for staff and secure cabinets.

   4. All records will be retained until the later of seven (7) years from your last contact with the practice, or until you reach the age of twenty-five (25).

   5. We take steps to destroy or de-identify information that we no longer require.

   6. Our server security policy is designed to protect the servers from unauthorised access, data breaches, and other security threats. Our practice uses the following security measures to ensure the personal information which it holds is secured:

      1. Antivirus software is installed on all servers and updated regularly.

      2. Firewalls are configured to block unauthorised traffic.

      3. Servers are placed on their own subnet.

      4. Access to servers is restricted to authorised users.

      5. Physical access to the servers are limited, with servers located in a locked room and security cameras installed around the building.

      6. Servers are patched regularly to fix security vulnerabilities.

      7. Backups are created regularly every hour onsite with daily offsite backups.

10. How can you access and correct your personal information at our practice

    1. You have the right to request access to, and correction of, your personal information.

    2. Our practice acknowledges patients may request access to their medical records. You can lodge this request either via email reception@drmathewkeegan.com or telephone 02 5603 8111. Our practice will acknowledge your request within three (3) business days. We can post the requested information to your postal address, or we can email the information to you if you request it. If we are required to process a request for your records, we may charge for our reasonable costs incurred in complying with your request. 

    3. 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 reception@drmathewkeegan.com. There is no fee charged for making corrections to your personal information.

11. How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice

    1. We take complaints and concerns regarding privacy seriously. You should express any privacy concerns (including any breach of the APPs or any registered binding APP code) you may have in writing. 

    2. Complaints should be addressed to:

       1. Name: Privacy Officer

       2. Address: PO Box 1230, Mona Vale NSW 1660

       3. Email: admin@drmathewkeegan.com

    3. We will respond with acknowledgement of your complaint within three (3) business days and provide a response within thirty (30) business days.

    4. You may also contact the Office of the Australian Information Commissioner (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.

12. Privacy and our website

    1. If you “like” or comment on our social media pages, we will have your social media name. 

    2. Our website uses cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address and pages you have accessed on our website and on third-party websites. You are not identifiable from such information. You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

    3. Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked from our website.

13. Privacy statement review

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

    2. Last reviewed: 2 October 2025.