| Project Objectives / Summary:
The transition of the Divisions of General Practice Program to outcomes based funding (OBF) stimulated an increased interest in the collection of patient information for program evaluation purposes.
The North West Melbourne Division identified that the current collection, handling and storage of individual patient information raised significant issues for patient privacy. No appropriate protocols existed for the collection and storage of patient information. The development of minimum standards and protocols and documentation of the ethical considerations for protecting patient confidentiality was recognised as required.
- The North West Melbourne Division undertook the following activities:
Development of protocols for the collection and storage of patient information by Divisions;
- Identification of suitable infrastructure for the electronic storage and transfer of patient information by Divisions;
- Development of a patient consent procedure and form;
- Development of protocols for general practitioner participation in the collection and storage of patient information by Divisions; and
- Identification of Divisions' legal liability where patient recall is undertaken by Divisions.
Project Collaboration:
- Whitehorse Division of General Practice
- Dandenong Division of General Practice
- General Practice Divisions of Victoria
- Melbourne University
- Monash University
- Consumer's Health Forum (CHF)
- GP Network
Project Outcomes:
- The guidelines were professionally printed and disseminated to all Divisions and all other stakeholders.
- A flyer "Personal Health Information Privacy and Divisions of General Practice" was printed and disseminated to the same group. The flyer is aimed at GPs and consumers to educate them in the role of the Divisions, why they collect data and to summarise how Divisions manage personal health information as outlined in the guidelines.
Recommendations:
That ADGP support the principle of Ethics committees for Divisions of General Practice auspiced by the SBOs. The Terms of Reference should be developed and approved by ADGP and include the following four main roles:
- State Based Ethics Committees
- Review and approve projects collecting personal health information;
- Monitor adherence to guidelines;
- Establish a complaints mechanism; and
- Disseminate information to GPs on their role in protecting personal health information from being sent to Divisions.
- That Divisions' Funding Contracts include a clause on the requirement to adhere to the Guidelines for Divisions of General Practice for the Management of Personal Health Information.
- That ADGP encourage SBOs to conduct workshops on the guidelines.
- That personal health information privacy issues be included in SBO and ADGP conferences.
- That ADGP determine the retrospectivity of the guidelines. While the issues of retrospective implementation have been considered, it is beyond the scope of this project to determine where exceptions may be made for established projects/programs. For example, the practicalities of retrospective implementation may differ for a project six months from completion as opposed to a five year project that commenced only six months prior.
- That ADGP give consideration to adapting the guidelines to a code to be approved by the Office of the Privacy Commissioner. As part of the development of the Privacy Amendment Bill it has been recommended to use a co-regulatory model whereby "privacy protection (is) based on flexible industry codes developed in co-operation with the Privacy Commissioner (and) backed by a legislative scheme." (Executive Summary and Recommendations presented to Parliament, 2000)
Disseminating Project Information:
Publications:
"Guidelines for Divisions of General Practice for the Management of Personal Health Information" and "Personal Health Information Privacy and Divisions of General Practice" sent to:
Divisions - 375 (3 to each Division)
SBOs - 6
ADGP - 50
RACGP - 10
CHF - 5
CAF - 10
Health Issues Centre - 10
Steering Committee - 10
People who provided feedback - 6
Conferences:
Presentation at the National Divisions of General Practice Forum 2000, Brisbane 23-25 August 2000
Lessons:
This project was slightly ahead of its time in some aspects, given the Privacy legislation that came into effect in December 2001. This demonstrates its innovative characteristics. It was not only a relevant project but was well conducted by the Division. The dissemination activity undertaken by the Division was thorough, of a professional standard, and undertaken promptly. The protocols developed aspects of the project have proved to be consistent with the December 2001 Privacy legislation.
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