Introduction

This email policy is to provide information on how we manage our privacy and security via email communications. This email policy is adapted from and in accordance with RACGP 5th Edition standards and AHPRA guidelines.

General practices are increasingly receiving requests from patients, other clinicians and third parties for health information to be sent to them electronically because it is an easily accessible method of communicating. The Australian Privacy Principles published by the Office of the Australian Information Commissioner state that: “Health information is regarded as one of the most sensitive types of personal information.

For this reason, the Privacy Act 1988 (Privacy Act) provides extra protections around its handling.

 The Privacy Act defines health information as:

Information or an opinion about:

  • the health or a disability (at any time) of an individual; or 
  • an individual’s expressed wishes about the future provision of health services to him or her; or 
  • a health service provided, or to be provided, to an individual; that is also personal information; or
  • other personal information collected to provide, or in providing, a health service; or
  • other personal information about an individual collected in connection with the donation, or intended donation, by the individual of his or her body parts, organs or body substances; or
  • 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.

Rationale

As all health information is sensitive by nature, all communication of health information, including via electronic means, must adequately protect the patient’s privacy. Our practice takes reasonable steps to make our communication of health information adequately safe and secure. GPs, health providers. support staff and patients should be aware of the risks associated with using email in the healthcare environment.

Policy

Our practice considers our obligations under the Privacy Act before we use or disclose any health information. The Privacy Act does not prescribe how a healthcare organisation should communicate health information. Any method of communication may be used as long as the organisation takes reasonable steps to protect the information transmitted and the privacy of the patient. A failure to take reasonable steps to protect health information may constitute a breach of the Australian Privacy Principles and may result in action taken against the organisation by the Australian Privacy Commissioner. What amounts to reasonable steps will depend on the nature of the information and the potential harm that could be caused by unauthorized access to it. The RACGP has developed a matrix is to assist practices in determining the level of security required in order to use email in general practice for communication.

Our practice reserves the right to check an individual’s email account as a precaution to fraud, viruses, workplace harassment or breaches of confidence by members of the practice team. Inappropriate use of the email facility will be fully investigated and may be grounds for dismissal.

Email configuration

Communication of clinical information to and from healthcare providers are completed from within the practice’s clinical software, wherever possible, using a secure clinical messaging system such as Health link. The use of a practice’s clinical software means that a record of communication is automatically retained in the patient’s medical record.This is not possible when communicating with patients. Particularly during the current Pandemic there has been an increase in email communication with patients and pharmacies. Increasingly, referrals and prescriptions have been sent by email

We have the current protective measures in place:

1.       Computer security measures

2.       Using 3 identifiers to identify patients

3.       Notifying patients that the information is not encrypted and that there is a security risk in sending emails to them containing their personal medical information. They can choose to collect a hard copy from our office if they prefer

4.       A notice on our emails if the email is sent to the wrong address

5.       Wherever possible send patient information via secure programs such as “My Practice App”

6.       Notification to OAIC of any significant data breach

Protection against spam: Use a spam filtering program.

Encryption of patient information: Use server to server encryption such as SSL or TLS.

Email use education

General protection

  • If any information held in our email accounts that is specific to a patient’s health information  will be downloaded as per practice policy. It will be imported into relevant patient file to ensure contents are backed up with the rest of our data.
  • We do not provide confidential information to an email address (especially by return email) no matter how credible the sender’s email seems (e.g. apparent emails from your bank).
  • Use a spam filtering program.
  • Encryption of patient information
  • All email communications should be treated as confidential.
  • When sending patient information or other confidential data by email, it is best practice to use encryption.
  • Be aware that encrypted files are not automatically checked for viruses. They have to be saved, decrypted and then scanned for viruses before being opened.

Protection against the theft of information

There are significant risks if providing confidential information by email: only do so via the internet when the site displays a security lock on the task bar and with an https in the web address.

Do not inform people of your email password.

Be aware of phishing scams requesting logon or personal information (these may be via email or telephone).

Email disclaimer

The practice uses an email disclaimer notice on outgoing emails that are affiliated with the practice stating:

PRIVACY & CONFIDENTIALITY NOTICE

This e-mail and any files transmitted with it are confidential and are only for the use of the person to whom they are addressed. If you are not the intended recipient, you have received this e-mail in error, and any use, dissemination, forwarding, printing, copying or dealing with this e-mail, in any way whatsoever, is strictly prohibited. If you have received this e-mail in error, please reply immediately by way of advice to us. It is the duty of the addressee/recipient to virus-scan and otherwise test the information provided, before loading it onto any computer system. Reading this email does not warrant that the information is free from viruses or from any other defect or error. Any views expressed in this message are those of the individual sender, except where the sender specifically states them to be the views of the company.

Email correspondence

Email correspondence sent to our email address is retained as required by the Public Records Act 2002 and other relevant legislation. Email messages may also be monitored by our information technology staff for system trouble-shooting and maintenance purpose. Patient  email address details will not be added to a mailing list or disclosed to a third party unless required by law.

Policy review statement

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