Date of Last Revision: October 2019
- HPS branded pharmacies are independently owned pharmacies providing pharmacy services to health facilities throughout Australia. HPS branded pharmacies are referred to in this policy as HPS Pharmacies.
- HPS Services Pty Ltd ACN 160 438 559 (HPS Services) provides support services and systems for each HPS Pharmacy. HPS Services is part of the HBS Group of companies including HPS Corrections Pty Ltd (ACN 159 945 936), HPS Hospitals Pty Ltd (ACN 136 875 922), HPS IVF Pty Ltd (ACN 156 303 561), HPS Services Pty Ltd (ACN 160 438 559), HPS Finance Pty Ltd (ACN 169 377 986), Hospharm Pty Ltd (ACN 136 875 922), and HPS Brands Pty Ltd (ACN 167 204 962) (HPS Group).
- We know that privacy is important to you. We manage your personal information in accordance with Australian privacy laws.
A brief summary about our approach to privacy
- If you are a patient at a hospital where HPS pharmacists provides pharmacy services, we will collect your personal information (including information about your health) to provide you with your medication. Pharmacists may also provide clinical pharmacy services. An HPS Pharmacy may collect personal information from you, your hospital, your medical practitioner and other health professionals involved in your care.
- Information about medications we have dispensed or clinical pharmacy services we have provided will be shared with the hospital and health professionals involved in your care.
- We may also use or disclose your personal information for billing, administrative and accreditation purposes or where required or permitted by law.
- We keep your personal information secure and we treat it with respect and care. You can contact us if you have questions or concerns about your privacy or to access or correct your personal information using the contact details at the end of this policy.
What information do we collect about you?
If you are a patient at a hospital
- When you receive treatment at a hospital, the hospital collects personal information about you (including about your health) and creates a record on its hospital information system.
- When a health professional involved in your care prescribes or orders medication for you a record will be made in the HPS electronic dispensing system (HPS Dispensing System) which receives and collects the information from the hospital’s information system.
- The information collected by the HPS Dispensing System will include information about you such as:
- your name, date of birth and contact details;
- your Medicare number;
- details of your private health insurance;
- information about any concessions you are entitled to, such as if you are a pensioner or veteran;
- medications you are taking or treatments you are having;
- details of medication history events such as allergic reactions and drug interactions,
- details of patient carers or support networks, and
- details about your treating health professionals (including General Practitioners, Consultant Specialists, Allied Health Professions (community pharmacists, physiotherapists etc).
- HPS pharmacists may also provide clinical pharmacy services to you during your stay at a hospital. For example, a pharmacist may provide advice about medications you are taking. When they do, a record of the interaction and the advice provided is made and collected by HPS.
- We may also collect information from you if you contact us directly, for example if you call us about an invoice or payment.
- You do not have to identify yourself when you contact us. You can also use a nickname or alias to protect your privacy. However, it is generally not possible for us to provide pharmacy services, dispense medication or answer your queries if we do not know who you are.
- HPS may collect personal information about other individuals who are not patients. This includes job applicants, individuals who interact with HPS on a commercial basis and health professionals who provide services to patients at health facilities.
- The kinds of personal information we collect will depend on the capacity in which you are dealing with HPS. Generally, it would include your name, contact details, professional details and information regarding our interactions and transactions with you.
- If you are applying for employment with HPS, we collect personal information from you to assess your application and suitability for employment.
How does HPS collect and use your personal information?
You are a patient at a hospital or of a health service
- The HPS Pharmacy uses your personal information collected from the hospital or health service in order to dispense medications to you.
- Pharmacists in an HPS Pharmacy may collect personal information to provide clinical pharmacy services. This may be collected directly from you but may also be collected from the hospital’s records or other health professionals involved in your care. For example, the pharmacists may talk to your doctor about the medications that you are taking.
- We will also use your personal information to issue invoices to you for medications dispensed during your health service visit, hospital stay or at discharge.
- If you are under the age of 18, a pharmacist will generally collect personal information about you from your parent or guardian. If you have sufficient understanding and maturity to make decisions about your health care, we may also collect personal information directly from you.
We also use your personal information to administer and manage our service. This includes:
- safety and quality assurance activities;
- testing and maintenance of our systems;
- risk management and management of legal liabilities and claims;
- meeting our legal and regulatory obligations;
- meeting and managing our commercial contracts and service level agreements; and
- responding to queries, complaints or inquiries.
If you are a prospective employee/applicant
- Generally, we will collect this information directly from you. We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies, previous employers or referees you have nominated).
When does HPS share personal information?
You are a patient at a hospital or of a health service
- The HPS Pharmacy will share your personal information with other health professionals, including doctors, nurses, pharmacists, and allied health professionals involved in your care.
- The HPS Pharmacy may also disclose your personal information to other parties where necessary to provide you with pharmacy services. For example, if you require specialised medicines or specially compounded or prepared medicines we may order these from other pharmacy services or suppliers of medicines.
- The HPS Pharmacy may share your personal information with the hospital or health service as part of reporting information to them associated with the provision of pharmacy services such as patient billing reports and clinical pharmacists’ activity ward reports.
- The HPS Pharmacy will share your personal information with HPS Services and other members of the HPS Group to provide billing services and manage account inquiries on its behalf.
- We may disclose your personal information to the applicable State and Federal regulatory bodies in line with our legal, regulatory and professional conduct obligations.
- We may disclose your personal information to third parties where required to collect payment of unpaid invoices.
General disclosures of personal information
- We may disclose your personal information to third parties to administer and manage our service and systems. This includes quality assurance activities, testing and maintenance of IT systems and management of legal liabilities and claims.
- We may also disclose your personal information to third parties if you have consented or we are legally required or entitled to do so.
How does HPS store my personal information?
- We keep your information in paper and electronic records. Paper documents may be converted to electronic form for storage. Original paper documents are archived or securely destroyed.
- We use physical security and other measures to protect your personal information. Paper records are generally stored securely at our facilities. Archived paper records are stored securely off site at information and record management companies.
- Electronic records are held on our computer systems and can be accessed by pharmacists, pharmacy assistants and HPS staff. We keep our systems and network secure by using physically secure servers, firewalls, user identifiers and passwords to control access.
- Our personnel are bound by a formal code of conduct requiring confidentiality of HPS information or by their obligations of professional conduct as registered health practitioners. We train and supervise our staff to ensure your information is treated with respect and care in accordance with privacy laws which apply to us.
Will you send my personal information overseas?
- We do not typically or routinely send personal information overseas.
- We will only disclose your personal information overseas:
- if we have your consent;
- if we have taken reasonable steps to ensure that the recipient will comply with the Australian Privacy Principles; or
- an exception under the Australian Privacy Principles applies.
How can I access or correct my personal information?
- You have a right to request access to your personal information using the contact details below. In limited circumstances, your request may be declined where privacy laws permit this. In those circumstances, we may give you access through an agreed intermediary (for example, an appropriate health professional).
- We will generally provide you with access free of charge.
- We do our best to ensure that your personal information is accurate, complete and up-to-date. You can help us by letting us know if your details change or if you notice errors in information we hold about you. If you think information we hold about you is incorrect, incomplete or out-of-date, you may ask us to amend our records. It is generally not possible to make changes to clinical records or records on our dispensing system. However, you may be entitled to ask us to include a statement with your records.
How do I raise a concern or make a complaint about privacy?
- If you have any questions or concerns about how we use your personal information, please contact us using the details below.
- You can make a complaint to our Privacy Officer using the contact details below. We will usually acknowledge receiving your written complaint within 5 business days. The Privacy Officer will consider your complaint to determine whether there are simple or immediate steps we can take to resolve your complaint.
- If your complaint requires more detailed consideration, the Privacy Officer will let you know that we have received your complaint within two weeks and try to respond to your complaint promptly. If something is not clear, we may ask you to provide more information about your complaint and the outcome you would like.
- In most cases, we will respond to a complaint within 30 days. If your complaint involves complex issues and we need more time to respond, we will let you know.
- If you are not satisfied with our response, or you think that we may have breached the Australian privacy laws, you have the right to make a complaint to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details can be found online at www.oaic.gov.au.
How to contact us
HPS Director of Human Resources
29 Alexander Avenue
Ashford SA 5035
Telephone: 08 8177 8200
Email: [email protected]