Privacy Policy | SkinSafe Cancer Clinic

Privacy Policy:

Our Commitment

At SkinSafe Cancer Clinic, we value your privacy and are committed to protecting your personal and health information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Health Care Act 2008 (SA), and the Health Practitioner Regulation National Law (South Australia) Act 2010. This policy outlines how we collect, use, store, and share your information as a facilities and services provider to independent tenant doctors operating at our clinic.

Our Role

SkinSafe does not provide medical services. We operate as a services entity, providing facilities, administrative support, and secure IT infrastructure, including electronic medical record (EMR) systems, to independent medical practitioners (tenant doctors) who run their own practices from our clinic. Key points:

SkinSafe’s Responsibilities: We own and maintain secure IT systems, EMR software, and data storage infrastructure used by tenant doctors to deliver healthcare. We act as a data custodian for medical records created by doctors, ensuring compliance with privacy laws.
Tenant Doctors’ Responsibilities: Independent doctors are responsible for your clinical care and the medical records they create. They comply with their own professional and legal privacy obligations, and SkinSafe ensures their compliance through service agreements.
Shared Commitment: Both SkinSafe and tenant doctors prioritise safeguarding your personal and health information.

Information We Collect

We may collect personal and health information when you register as a patient, interact with our services, or apply for a role at SkinSafe. This includes:

Basic Details: Name, date of birth, address, phone, email.
Billing Information: Medicare number, concession card details, payment information.
Health Information: Medical history, medications, allergies, family history, risk factors (collected by tenant doctors via our EMR with your consent for their clinical service).
Healthcare Identifiers: Unique identifiers for you and your healthcare providers.
Employment Data: For job applicants or employees (e.g., resumes, qualifications, references).

Information may also be collected from other sources when direct collection is impractical or unreasonable, such as:

Your guardian or responsible person.
Other healthcare providers (e.g., specialists, hospitals, pathology, imaging services).
Your MyHealth Record, health fund, Medicare, or Department of Veterans’ Affairs. We notify you or seek consent when collecting from third parties, unless required by law.

Why We Collect Information

We collect information to:

Enable tenant doctors to provide healthcare via our facilities and EMR systems.
Manage appointments, billing, and Medicare claims.
Support clinic operations (e.g., accreditation, audits, training, quality improvement).
Communicate about clinic services or events (with your consent).
Assess job applicants or manage employees/contractors.

We will seek additional consent if your information is used for a purpose not listed here.

Anonymity and Pseudonymity

You may interact with us anonymously or using a pseudonym where practical. However, this may prevent Medicare rebates, requiring you to pay full fees without reimbursement. Legal or clinical requirements may also mandate identification.

Sharing Your Information

Your information may be shared:

With your tenant doctor and other healthcare providers involved in your care (e.g., specialists, pathology services).
With third-party service providers (e.g., IT providers, billing software, accreditation bodies) who comply with privacy laws via contractual agreements.
As required by law (e.g., mandatory reporting for infectious diseases, court orders).
To prevent or lessen a serious threat to life, health, or public safety.

Overseas Disclosure: Some third-party providers (e.g., cloud services for our Webflow-hosted website or EMR) may store data in countries like the United States or European Union. We ensure these providers comply with privacy standards equivalent to the APPs (e.g., GDPR for EU servers) through contracts or certifications. We will not share your information overseas without your consent unless legally required.

Marketing and Communications

With your consent, SkinSafe may send updates about clinic services, health programs, or events. You can opt out at any time by contacting us or using unsubscribe links.

Data Security

We protect your information through:

Secure physical facilities (locked storage, restricted access).
Password-protected IT and EMR systems with encryption.
Access limited to authorised personnel (SkinSafe staff, tenant doctors).
Regular security audits and compliance with APP 11.

In case of a data breach, we comply with the Notifiable Data Breaches (NDB) scheme, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

Data Retention and Deletion

We retain patient and billing information for at least 7 years, as required by South Australian health regulations, or until a minor reaches 25 years for health records. Employee/contractor data is kept for 7 years post-employment. Website analytics data is retained for up to 2 years. Data is securely deleted thereafter unless legally required.

Access and Correction

You may request access to or correction of your personal information by contacting our Privacy Officer. Requests for medical records will be referred to your tenant doctor. We aim to respond within 30 days, as per APP 12 and 13. There is no fee unless access requires significant effort.

Website Use

Our website (skinsafe.au), hosted on Webflow, uses cookies and analytics tools (e.g., Google Analytics) to improve user experience. These collect non-identifiable data (e.g., page views, IP addresses). You can disable cookies in your browser, but this may affect site functionality. Links to third-party websites are not covered by this policy; review their privacy practices.

Complaints

If you have concerns about your privacy, contact: Privacy Officer – SkinSafe Cancer Clinic
Email: admin@skinsafe.au
Phone: 08 8522 6660

We will respond within 30 days. If unsatisfied, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or1300 363 992.

Policy Updates

This policy is reviewed annually or as required to reflect changes in law, practice, or clinic operations. Updates are posted on our website.

Last Updated: August 2025