Who we are
We are Specialist Diagnostic Services Pty Ltd (ACN 007 190 043) trading as TML Pathology.
We provide pathology services to patients and commercial clients.
In conducting our business, we collect, use and disclose personal information. We understand the importance to our patients and other persons we test of maintaining privacy in relation to the personal information we hold.
What personal information do we collect and hold?
Personal information is information or an opinion about an identified person, or someone who is reasonably identifiable, whether or not the information or opinion is true and whether the information or opinion is recorded in a material form or not.
The types of personal information we may collect and hold about you include:
Billing and administration
Insurance membership number
Pathology tests requested
Date of Birth
Credit card number
Pathology test results
Pathologist clinical notes
Referring practitioner clinical notes
How do we collect and hold personal information?
We collect personal information about you in several ways, including from:
- information that is recorded on the pathology request form your health practitioner gives you when recommending that you obtain pathology services;
- other persons or entities who ask us to perform pathology services on your behalf (for example, the hospital/nursing home where you are a patient, a government department or your employer);
- someone who has responsibility for you (your parent, carer or guardian); and
- you directly.
When we receive a request to provide you with pathology services, we create a unique digital medical record for you. Every time we perform a pathology service for you, new information is added to your medical record.
We take reasonable steps to protect patient medical records from misuse, interference and loss and also from unauthorised access, modification and disclosure. These steps include ensuring that our information technology systems and processes comply with the requirements of the National Pathology Accreditation Advisory Council for information communication.
Why do we need your personal information and what do we do with it?
We collect, maintain, use and disclose personal information about you in order to provide you with appropriate care, treatment and services.
We use the information in your medical record:
We disclose your pathology results:
- to ensure that we provide the correct pathology services;
- to interpret your pathology results and to make an appropriate diagnosis;
- to provide you and/or your health practitioner with information that may assist you in managing and improving your health; and
- as a medical history for you as results of pathology services we provide to you are added to your medical record over time. This medical history allows our health professionals to provide you with better care as it assists with identifying changes to your health over time.
We may also disclose your complete pathology medical history, including all pathology results for all pathology services we have ever performed for you (regardless of who requested the relevant pathology services), to a registered health practitioner who requests this. We will only do this if we are satisfied as to the identity of the registered health practitioner, and they confirm to us that this is required solely for them to deliver health care personally to you.
- to the person who requested the pathology service on your behalf (normally your health practitioner);
- to anyone else specified in the request for the pathology service (your health practitioner may request that we disclose your pathology results directly to you or to other health practitioners who are involved in your treatment);
- to other persons not specifically listed in the request for the pathology service but who claim to be providing health care services to you and we are satisfied that their claim is genuine (we will only do this if we are reasonably satisfied that they are a registered health practitioner, or you have consented to this occurring, or there appear to be other reasons why this is appropriate for your health care);
- where the pathology service was requested on your behalf by your employer or a government department, to that employer or government department;
- to you personally or to anyone else you may request or consent to in writing, provided you supply us with any information we may request from you in order to be reasonably satisfied that the request is genuinely from you (eg; certified identification documents); and
- where the pathology service provides a positive result to a COVID-19 test, to the relevant government authority.
For some specific pathology tests (such as full blood counts, electrolytes, liver function tests and other serology and immunology pathology tests), it is accepted clinical practice that we must give your health practitioner not only the test result for the test your health practitioner has requested but also the results of all tests of the same nature that we have performed for you previously (regardless of who requested those tests). Past results assist your health practitioner to determine whether or not your current test result is abnormal.
In some circumstances, it may be necessary for us to obtain confirmatory testing from a third party laboratory or, for highly specialised pathology services, we may need to arrange for a reference laboratory to perform the required pathology services on our behalf. In these circumstances, we will disclose personal information about you to these third parties for the limited purpose of obtaining the necessary pathology services.
Operating our business
We use, and where necessary disclose, your personal information to manage our accounts and obtain payment for the services we provide. Specifically, we will use and, where necessary, disclose your personal information to obtain payment from, as appropriate, Medicare Australia, you, your private health insurance fund or from any organisation responsible for payment of any part of your account, such as the Department of Veterans Affairs. This may also extend to disclosure of your personal information to a debt collector or a credit-checking agency. We also use, and where necessary disclose, your personal information for data entry and data analytics purposes.
If the circumstances require, we may disclose your personal information to our insurers.
We may use your personal information to:
Teaching and research
- give you important information about our products and services;
- advertise to you particular products and services that may be of interest to you; and
- give you reminders in relation to obtaining services from us (for example where your health care needs require regular, periodic pathology services).
We may use your personal information for internal teaching purposes or to monitor, evaluate, plan and improve the services we provide. We will only use de-identified information (information that does not contain any personal details that may reasonably identify you) for these purposes, unless the service we provide is to you.
Entities undertaking research (such as Cancer Councils, universities and pharmaceutical companies) periodically request data from our medical records. We will only provide identified data in response to these requests when authorised to do so by the Privacy Act 1988 (Cth).
We may be required by law to disclose your personal information without your consent.
What happens if we do not collect your personal information?
If you don’t provide us with all the personal information we request, we may not be able to provide pathology services to you. We aim to only collect as much personal information from you as we need to provide you with services and to allow us to obtain payment for those services.
Do we transfer personal information overseas?
We may disclose your personal information to wholly owned subsidiaries of our parent company, Healius Ltd, or to third parties, which are based in India, Malaysia and the Philippines. These companies provide billing, payment and other administrative services, data-entry and data analytics services to us. We take reasonable steps to ensure that these companies do not breach the requirements of the Privacy Act 1988 (Cth) and other State and Territory legislation that may be applicable.
Can you access your personal information we hold?
You may request access to the personal information we hold about you. You can also request that corrections be made to it. We will respond to your request within a reasonable time.
There are some circumstances where we are not required to give you access to or correct your personal information. We will normally give you a written notice setting out our reasons for not complying with your request and informing you of how you can complain about our refusal.
There is no fee for requesting access to your personal information or for us to make corrections. However, we may charge a fee for our costs involved in collating and providing you with access to any personal information. If charged, that fee is payable before access is given.
What to do if you would like to make a complaint about a breach of the Australian Privacy Principles
If you have any concerns about how we handle your personal information or you wish to make a complaint on the basis that we have breached the Australian Privacy Principles prescribed by the Privacy Act 1988 (Cth), please contact us. If you would like to make a complaint, you will need to send us a written complaint (see details below).
We will endeavour to respond to your complaint within a reasonable time after it is made.
How to contact us
You can contact our Privacy Officer in the following ways: