1. OBJECTIVE AND OUTCOME
1.1.1 The purpose of this document is to outline how we comply with confidentiality and privacy obligations. We respect the privacy of everyone who interacts with our company on any platform. As a result, we would like to inform you regarding the way we would use your Personal Information.
1.1.2 Oncolab diagnostics is a pathology laboratory concerned with diagnostic and monitoring pathology services in South Africa.
1.1.3 As an organisation, Oncolab Diagnostics Pty (Ltd) principal concern is and always will be the welfare of the patients who test with the laboratory. A high level of trust and confidentiality is required to ensure the confidence of the patients we serve.
1.1.4 Patients will be assured that:
1.1.4.1 their privacy will be protected when testing with Oncolab Diagnostics Pty (Ltd).
1.1.4.2 the information collected and retained in our records is correct and up-to-date, and
1.1.4.3 that they can access their own test results.
2. DEFINITION/ABBREVIATION
2.2.1. Refer to https://oncologysa.sharepoint.com/sites/OncolabQM/Lists/Definitions%20and%20abbreviations/
3. RESPONSIBILITIES
3.1 Information officer
3.1.1 Responsible for the implementation of and adherence to the POPI act.
3.2 Deputy information officer
3.2.1 Assist information officer with all POPI related matters.
3.3 Laboratory staff
3.3.1 It is the responsibility of all staff members working in the laboratory to follow the instructions as described in this document.
4. INFORMATION COLLECTION
4.1.1 Oncolab Diagnostics Pty (Ltd) recognises that the information we collect is often of a highly sensitive nature and as an organisation we have adopted the highest privacy compliance standards relevant to Oncolab Diagnostics Pty (Ltd) to ensure that all personal information is protected.
4.1.2 For administrative and billing purposes, and to enable the patients to be attended to by other medical practitioners and services, patient information is shared with different medical practitioners and other healthcare providers. Oncolab Diagnostics Pty (Ltd)therefore may collect and process personal information regarding the patients (including health information) for the purpose of providing accurate, up to date and clinically relevant results that are related to his/ her condition to clinicians and other laboratories and services that may require this in order to provide appropriate care.
4.2 Definition of Personal Information
4.2.1 According to the POPI Act ‘‘Personal Information’’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. The POPI Act, has more specific examples if required.
4.2.2 Personal information collected will generally include:
4.2.2.1 the main member of the Medical Scheme, the person responsible for payment of the account, patient's name, address, telephone number and Medical Scheme information,
4.2.2.2 current drugs or treatments used by the patient or other care or health related information,
4.2.2.3 previous/current medical history, including, where clinically relevant, a family medical history, and
4.2.2.4 the name of any health service provider or medical specialist to whom the patient was referred to.
4.2.3 Oncolab Diagnostics Pty (Ltd) may access information:
4.2.3.1 provided directly by the patient,
4.2.3.2 provided on the patient's behalf with the patient's consent,
4.2.3.3 from a health service provider who refers the patient to the laboratory for testing.
4.3 Use or disclosure of personal information
4.3.1 Personal information collected by Oncolab Diagnostics Pty (Ltd) may be used, shared or disclosed:
4.3.1.1 for the purpose advised to the patient at the time of collection of the information,
4.3.1.2 as required for delivery of the health service to the patient,
4.3.1.3 as required for the ordinary operation of our services
4.3.1.4 as required under compulsion of law, or
4.3.1.5 where there is a serious and imminent threat to an individual's life, health, or safety, or a serious threat to public health or public safety.
4.3.1.6 Oncolab Diagnostics Pty (Ltd) may use or disclose personal information with medical practitioners who provide medical treatment and care to the patient and with related third parties, including but not limited to the purpose of quality assurance, training, billing, liaising with Medical Schemes regarding payments and as may be required by the practice's insurers.
4.3.1.7 Other companies in our industry when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing.
4.3.1.8 Where we have a duty or a right to disclose in terms of law or industry codes.
4.3.1.9 Where we believe it is necessary to protect our rights.
4.4 Accuracy of information
4.4.1 Oncolab Diagnostics Pty (Ltd) is committed to ensuring the patient’s information is accurate and has processes in place to ensure that the accuracy of this information is maintained.
4.5 Security of information collected
4.5.1 Other than as described in this Policy or permitted under privacy principles, Oncolab Diagnostics Pty (Ltd) uses its reasonable endeavours to ensure that identifying health information is not disclosed to any person unnecessarily or irresponsibly.
4.5.2 Due to the sensitive nature of the information collected by the practice to provide its services, extra precautions are taken to ensure the security of that information. Information may be stored electronically and / or in hard copy form.
4.5.3 Our security policies and procedures cover
4.5.3.1 computer and network security
4.5.3.2 Physical security
4.5.3.3 Secure communications
4.5.3.4 Investigating and reacting to security incidents
4.5.3.5 Monitoring access and usage of personal information
4.5.3.6 Retention and disposal of information
4.5.3.7 Security in contracting out activities or functions
4.5.3.8 Governance and regulatory issues
4.5.4 Oncolab Diagnostics Pty (Ltd) requires its employees to observe obligations of confidentiality during their employment with all staff as well as contractors or third parties signing Confidentiality Agreements.
4.6 How long are medical records kept?
4.6.1 Oncolab Diagnostics Pty (Ltd) keeps health information indefinitely.
4.7 Accessing your information
4.7.1 On request, patients may have access to their medical records held by Oncolab Diagnostics Pty (Ltd), except in circumstances where access may be denied under the Promotion of Access to Information Act or other laws. For example, access can be denied when letting a patient see their records would pose a serious threat to the patient's life or health, or the life or health of someone else (such as a relative, the health service provider, staff, or other patients).
4.7.2 The threat must be significant, for example where there is a serious risk the patient may cause self-harm or harm to another person if they saw the information. The threat can be a risk of danger to physical or mental health but does not need to be imminent - it can be a serious threat that might occur sometime after access is granted.
4.8 Can medical records be transferred to a medical practitioner who did not request the original testing?
4.8.1 Patients have the right to attend a medical practitioner of their choice and are free to request their medical records at any time. It remains the laboratory’s responsibility to ensure that these medical records reach the correct medical practitioner.
4.9 How can this be arranged?
4.9.1 There is a professional obligation for a medical practitioner to provide a new treating medical practitioner with all the information that they need to take over a patient's care.
4.9.2 This is usually done by the patient completing an Authorisation for Release of personal Information' form and producing an original source of identification for the receptionist to make a copy of.
4.10 Website privacy
4.10.1 Oncolab Diagnostics Pty (Ltd) website, Linkedin page and Facebook page contains links to other sites. Please be aware that Oncolab Diagnostics Pty (Ltd) is not responsible for the privacy practices of any linked sites. We encourage users who leave our site to read the privacy statements of each linked website that they choose to visit. All links to external sites are provided for patients’ convenience. The information, products and advertisements contained in the linked sites are neither approved nor endorsed by Oncolab Diagnostics Pty (Ltd), and Oncolab Diagnostics Pty (Ltd) is not responsible for such information, products, or advertisements.
4.10.2 Patients’ privacy is important to us, and we want them to feel comfortable visiting our website. Any personal information that patients give to us, including e-mail addresses, will be used only in the following ways:
4.10.2.1 personal data given to us by you will be securely stored,
4.10.2.2 we will not provide personal data to any third party without your permission,
4.10.2.3 if we join with a third party to provide services and the patient signs up for those services, we will not share their name and other contact information necessary for our partner to provide the services to the patient,
4.10.2.4 we may share aggregate demographic information with our affiliates. This is not linked to any personal information that can identify our patients or any other visitor to our web site.
4.11 Changes to the Privacy Policy
4.11.1 Oncolab Diagnostics Pty (Ltd) has the right to change the Privacy Policy at any time. If there are updates to Oncolab Diagnostics Pty (Ltd)’s Privacy Policy, we will address the changes promptly and update the revision date of this document.
4.12 Obtaining further information
4.12.1 If patients require more information regarding Oncolab Diagnostics Pty (Ltd), its services and facilities, they can:
4.12.1.1 ask a staff member, or
4.12.1.2 access our website.
4.13 Contact information
4.13.1 For any queries regarding our Privacy Policy, please contact:
The Information Officer/Manager Oncolab Diagnostics Pty (Ltd) P O Box 12555 Hatfield 0028
4.14 Disclaimer
4.14.1 While we make every effort to protect your privacy, we may need to disclose personal information when required by law where we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our company or site.
5. RECORDS
5.1.1 All documents will be filed as per SOP-5004.
6. REFERENCES
6.1.1 POPI Act 2013
7. FORMS
7.1.1 FORM 1 AUTHORISATION FOR RELEASE OF PERSONAL INFORMATION
7.1.2 FORM 2 PATIENT INFORMATION AND TERMS & CONDITIONS OF VISITING ONCOLAB DIAGNOSTICS