Privacy at VCS Foundation Ltd.
The management and staff of VCS Foundation Ltd. understand the importance of protecting the privacy and confidentiality of all personal and health information that is held by the organisation. VCS Foundation Ltd. collects a range of personal and health information about individuals. VCS Foundation Ltd. may collect this information from the individual or from another person dealing with that individual, such as their healthcare practitioner. The type of information that VCS Foundation Ltd. collects and the way in which it may use and disclose that information varies according to the services, activities and programs VCS Foundation Ltd. provides or undertakes in relation to an individual.
VCS Foundation Ltd. has strict privacy and confidentiality practices in place and all staff are required to abide by these. A Disciplinary Policy and Procedure is in place to ensure staff comply with these practices. All persons who may observe personal and health information held by VCS Foundation Ltd. are required to sign a confidentiality statement.
The statement below details how VCS Foundation Ltd. manages and uses the personal and health information it holds in relation to the services, activities and programs of its three pillars:
- VCS Pathology – a laboratory committed to excellence in cervical cytology, Human Papillomavirus (HPV) testing, histopathology and other related nucleic acid testing.
- VCS Population Health – delivering and managing population health registry systems and services, backed by specialist expertise in epidemiology, research and evaluation, health policy, health information management, reporting and statistics.
- VCS Digital Health – advancing population health management through innovative and connected technology solutions and services.
All personal and health information is stored on the premises of VCS Foundation Ltd. or in cloud based storage. Backup tapes of the information system and some slides are stored in a secure facility off-site. Where services are contracted out, contractors must comply with VCS Foundation Ltd. privacy and confidentiality requirements if any personal information is provided to them.
How is personal and health information collected?
VCS Pathology collects personal and health information directly from individuals and also from other persons involved in the care or treatment of an individual, such as their health care practitioner that orders their pathology test. Where an individual offers information directly to VCS Foundation Ltd., this may also be entered on the individual’s health record.
VCS Population Health supports a range of population health programs and initiatives, such as cancer screening and immunisation follow-up services, clinical trials and targeted projects, that improve the health and well-being of communities by providing systems and services for the collection, storage, analysis and reporting of data. VCS Population Health collects personal and health information directly from individuals, their nominated representatives and from other persons involved in the care or treatment of individuals, such as health care practitioners, laboratories or health care facilities. This information assists in maintaining accurate and up to date health records for program and project participants. VCS Population Health also receives personal and health information from other public health organisations such as the National Cancer Screening Register and the Victorian Cancer Registry, for the purposes of providing data and reports to support cancer screening activities and programs. For some projects, data is collected by our stakeholders and other parties and held within VCS Foundation Ltd. systems.
In the event that VCS Foundation Ltd. receives unsolicited personal or health information, we will deal appropriately with such information including considering whether we could have otherwise lawfully collected the information. If not, VCS Foundation Ltd. will destroy the information or ensure the information is de-identified if it is lawful and reasonable to do so.
If you do not provide, or we are unable to collect, the personal and health information we require, we may be unable to provide our services to you or you may be unable to participate in our activities or programs.
What personal and health information is held?
VCS Foundation Ltd. collects and holds personal information and health information which is necessary for and related to the performance of its work and activities.
The type of personal and health information that VCS Foundation Ltd. collects and holds about an individual will vary according to the service we provide to the individual, the activity or program the individual might participate in or our relationship with that individual. The type of information VCS Foundation Ltd. collects and holds includes the following:
- Name (current and previous), date of birth, current and previous addresses, telephone numbers, e-mail addresses.
- Cultural and linguistic diversity status, Aboriginal and Torres Strait Islander (ATSI) status.
- Medicare Number.
- The results of all pathology and screening tests performed by VCS Pathology for individuals undergoing those tests.
- In the case of cervical screening tests reported by VCS Pathology, VCS Pathology may obtain associated colposcopy, histopathology and other relevant pathology results from health practitioners and other laboratories from the National Cancer Screening Register or the Compass Register.
- Other medical and health related information, including clinical information provided by the health care practitioner ordering a pathology or screening test and clinical information provided by an individual. This may include a description of current or previous symptoms, health status, family history, health conditions, treatments and other test results
- Information relating to our VCS Population Health projects in screening and immunisation which is specific to our projects and services.
VCS Pathology also collects and holds personal information regarding the healthcare practitioner ordering a pathology test for an individual. This includes the practitioner’s name, address and Medicare Provider Number.
VCS Foundation Ltd. may also collect personal information about individuals in other circumstances, such as if a person applies for a job with VCS Foundation Ltd. or otherwise deals or transacts with VCS Foundation Ltd. The type of information VCS Foundation Ltd. may collect in those circumstances includes: name, address, date of birth, financial details, employment details and telephone numbers. All staff employed with VCS Foundation and having access to personal information are required to have a police check prior to employment.
At times and depending on projects, VCS Foundation Ltd. may collect and use other types of personal and health information which is relevant for that project or to the performance of its work and activities – for example, information provided through consent-based research or other research approved by a Human Research Ethics Committee (HREC). If any additional type of personal information (other than as specified above) will be collected and used for those projects or activities, the individual’s consent for that use and collection will be sought, unless the law permits otherwise.
Given the nature of the services and activities we perform, it is not possible for you to deal with us anonymously or by using a pseudonym.
Storage of historical records
VCS Foundation Ltd. holds historical back-up copies of records that were stored in population health registries that have ceased operating. Details of our historical records are provided below.
National HPV Vaccination Program Register (NHVPR)
VCS Foundation ceased operating the NHVPR on 31 December 2018. All records held by the Register have been transferred to the Australian Immunisation Register (AIR). The AIR can be contacted on 1800 653 809.
VCS Foundation only holds an historical back-up copy of the records transferred to the AIR – that copy contains only records created before the date of transfer. These records are securely stored and cannot be accessed without prior permission from the Department of Health, Canberra.
SA Cervix Screening Registry (SACSR)
VCS Foundation ceased operating the SACSR on 30 June 2019. All records held by the Register have been transferred to the National Cancer Screening Register (NCSR) and a copy provided to SA Health. To obtain a copy of your records relating to the SACSR please contact the NCSR on 1800 627 701.
VCS Foundation holds an historical back-up copy of the records transferred to the NCSR and SA Health – that copy contains only records created before the date of transfer. These records are securely stored and cannot be accessed without prior permission from SA Health.
Victorian Cervical Screening Registry (VCSR)
VCS Foundation ceased operating the VCSR on 30 June 2019. All records held by the Register have been transferred to the National Cancer Screening Register (NCSR). To obtain a copy of your records please contact the NCSR on 1800 627 701.
VCS Foundation holds an historical copy of the records transferred to the NCSR – that copy contains only records created before the date of transfer. These records are securely stored and protected.
How is personal and health information used?
VCS Foundation Ltd. uses the personal and health information it holds about an individual for the following purposes:
- To provide recommendations for the management of test results (follow up) to health practitioners.
- To perform and to assist in reporting a pathology test that has been ordered.
- To perform the other services we provide and to perform our other activities and programs.
- To charge for those services (where appropriate) or to liaise with a third-party payer.
- For research, to improve our knowledge, particularly of how to better prevent cancer of the cervix in women. However, no research publication will ever identify an individual without prior written consent from that person. Where small numbers of patient data are used for research purposes, data suppression is routinely applied to prevent inadvertent identification of an individual.
- To provide statistical data to the Victorian Government’s Department of Health and Human Services to support the Victorian Cancer Plan, as required by legislation, in increasing screening participation rates in specific populations or to provide statistical data to other government bodies and agencies for cancer related purposes. No statistical data identifies a person.
- To meet our other statutory and regulatory obligations.
- To manage our relationship with clients, employees, employment applicants and service providers.
- To support projects and initiatives and fulfil contractual obligations.
- To conduct activities related to quality assurance and improvement processes, accreditation and audits and managing legal and other claims.
- To respond to a complaint.
In addition to the above, VCS Foundation Ltd. may also use your information if you have given your express or implied consent for the use for another purpose, or if we are permitted or required to do so by law.
This section provides further details regarding how VCS Foundation Ltd. uses your personal information and health information if you participate in the Compass Trial. More detailed information can be found in the Compass Privacy Statement.
The personal and health information held on the Compass Register is used by VCS for the following purposes:
- to provide recommendations for follow up;
- to assist a pathology laboratory in reporting a current cervical screening test or in their decision about whether or not to issue an amended report on a previously reported cervical screening test;
- to send reminder letters to women who are overdue for screening;
- to assist women to receive follow-up care after an abnormal cervical screening test; this may involve communication with the health care practitioner or the woman;
- to assist pathology laboratories in measuring the quality of their cervical screening test reporting;
- for research to improve our knowledge, particularly about how to achieve and maintain high participation rates in cervical screening and how to prevent cancer of the cervix in women. However, no research publication will identify an individual person;
- to inform funding, management, planning, monitoring and evaluation of our registries and health services.
When is personal and health information disclosed?
VCS Foundation Ltd. may disclose your personal and health information for the purposes set out in the previous section. It may also disclose your personal and health information in the following circumstances:
- To your health care practitioner who ordered the pathology test.
- At your health care practitioner’s request, to another health care practitioner.
- At your practitioner’s request, to another laboratory when a further opinion is being sought on a pathology specimen or for a pathology test that has been ordered but which is not performed at VCS Pathology.
- In accordance with the Health Insurance Act 1973, to Medicare Australia for the purpose of payment for services for bulk-billed tests such as histology, HPV tests and other nucleic tests.
- In accordance with the Health Insurance Act 1973, to Medicare Australia to facilitate payments for the Cervical Screening Practice Incentive Program. (See next section).
- Reporting to the National Cancer Screening Register in accordance with section 13 of the National Cancer Screening Act 2016. Where VCS Pathology is aware that an objection has been lodged to such notification, then no personal or health information is disclosed.
- In accordance with Section 9 of the Improving Cancer Outcomes Act 2014, to the Victorian Cancer Registry for individuals who reside in Victoria and who are diagnosed with cancer.
- To your representative (e.g. an authorised representative or lawyer), with your written consent.
- To our legal advisers and insurers.
- To the Victorian Department of Health and Human Services or to another State or Commonwealth government department or agency in connection with the performance of one or more of its functions.
- To the extent required by law or pursuant to any court order. This may include information provided to a Coroner or a Court under a subpoena.
- If you have agreed to participate in a trial, in accordance with your consent given in respect of that trial or as otherwise permitted under the Privacy Act 1988 or other relevant laws.
In addition to the above, VCS Foundation Ltd. may also disclose your information in other circumstances and to other persons if you have given your express or implied consent, or if we are permitted or required to do so by law (including under the Privacy Act 1988 and the Health Records Act 2001).
VCS Foundation Ltd. does not disclose an individual’s personal or health information for any testing carried out on Australian specimens to any overseas organisation or person (other than the individual).
My Health Records
If you have chosen to participate in the My Health Record program operated by the Commonwealth Department of Health, VCS Pathology may access personal information stored in your My Health Record if you have set the access controls to allow this. When requested to do so, VCS Pathology may upload your personal and health information electronically to the My Health Record system.
If you do not wish VCS Pathology to access personal information stored in your My Health Record, or to upload health information to it, you may opt out or choose to modify access controls within the My Health Record system.
Does my information have to be provided to Medicare Australia for the Practice Incentive Program Cervical Screening Initiative?
You have a choice as to whether VCS Pathology discloses your personal information to Medicare Australia for the Practice Incentive Program Cervical Screening Incentive (PIP-CSI). Under the PIP-CSI, the Government provides additional money to general practitioners to screen women who are two or more years overdue for their cervical screening test. The PIP-CSI is run by Medicare Australia.
Further information about the PIP-CSI is available on Medicare Australia’s website (www.medicareaustralia.gov.au).
In order for accurate statistics to be available for each general practitioner, VCS Pathology sends information to Medicare Australia about each woman who has a cervical screening test reported by VCS Pathology. On a four weekly basis, the following information is sent from VCS Pathology to Medicare Australia: name; address; date of birth; and Medicare Number. This is done after a four-week delay in order to provide time for notifications that an individual does not want their information sent to Medicare Australia.
If you prefer that your information not be sent by VCS Pathology to Medicare Australia for the PIP-CSI, please notify us by email (email@example.com) or by writing to the following address:
Professor Marion Saville
VCS Foundation Limited
PO Box 178
CARLTON SOUTH VIC 3053.
Even if you decide that you do not want your information to be sent to Medicare Australia for the PIP-CSI, we are still very happy to report your cervical screening test and we will continue to offer you our full range of services.
How an individual may obtain access to, or correction of, their health information
You may request access to information VCS Foundation Ltd. holds about you. We will give you access to your information, unless we have a reason to limit or refuse access under the Privacy Act 1988 (or another relevant law). If we limit or refuse access to your information, we will provide reasons. If we give you access to your information, we will not charge you for that access.
You may also request the correction of your personal and health information we hold if you believe it is inaccurate. We will take reasonable steps to amend your information if we consider the information we hold about you is inaccurate, incomplete or out of date.
Results of pathology tests are normally provided to the health care practitioner who ordered the test. The best way to get your results is in consultation with your healthcare practitioner so that your practitioner can explain your results in the context of your health care.
The following section describes how you may request access to or correction of your information.
- Your request should be in writing (an application form is available from us on request) and be addressed to the Executive Director at the contact details set out below.
- You should provide sufficient identification so that the authenticity of the request can be considered to be satisfactory by the Executive Director of VCS Foundation Ltd.
- Upon lodgement of a request, the Executive Director of VCS Foundation Ltd. will oversee the process whereby your personal and health information is made available to you, or corrected, subject to the requirements of applicable privacy and health records laws.
- Where applicable, the personal and health information will be provided in printed form to you or alternatively you may visit the VCS Pathology to personally view your records by appointment.
- VCS Pathology will ordinarily respond to these requests within 25 working days of receipt of the request.
More detailed information on access to, or correction of, health information relating to the Compass Trial can be found in the Compass Privacy Statement.
How to make a complaint regarding your privacy?
If you have any concerns or complaints about your privacy or the manner in which VCS Foundation Ltd. has handled your personal or health information, please contact us in writing at the address below. We will endeavour to resolve your complaint promptly and will provide a written response to you.
Contact details for VCS Foundation Limited:
The Executive Director
VCS Foundation Limited
PO Box 178
Carlton South VIC 3053
If we are unable to resolve your complaint satisfactorily, you may wish to direct your complaint to the Health Complaints Commissioner or to the Office of the Australian Information Commissioner.
Contact details for the Victorian Health Complaints Commissioner:
Health Complaints Commissioner
570 Bourke Street
Melbourne VIC 3000
The Australian Information Commissioner is the statutory office-holder responsible for the regulation of privacy laws in Australia in accordance with the Privacy Act. The Office of the Australian Information Commissioner (OAIC) website contains more information about the Privacy Act, including the Australian Privacy Principles and information about how to make a privacy complaint.
Who is responsible for this policy?
The VCS Foundation Ltd. Director Corporate Services is responsible for this policy and can assist with any queries about:
- how your personal information is collected, held, used or disclosed by VCS Foundation Ltd.
- how to obtain access to or request correction of your personal information
You can contact our Director Corporate Services through the contact details below:
Director Corporate Services
VCS Foundation Limited
PO Box 178
Carlton South VIC 3053