POLICY ON MANAGEMENT OF PERSONAL & HEALTH INFORMATION

Victorian Cytology Service (VCS) has been contracted by the Commonwealth to establish and manage the National HPV Vaccination Program Register (HPV Register) on the Commonwealth’s behalf. The Register was established under legislation passed in 2007.

The HPV Register is a confidential database that collects information (including personal and health information) about HPV vaccinations given in Australia.

The management and staff of VCS appreciate that personal and health information is held by the organisation. The organisation has strict confidentiality and privacy practices in place and all staff are required to abide by these. Any third party who may potentially have access to the HPV Register is required to sign a confidentiality statement.

All personal information is managed from the premises of VCS or its authorised subcontractors. In accordance with prudent business practice, backup tapes of the information system on which the HPV Register is located are stored in a secure facility off-site. Where any services associated with the HPV Register are subcontracted and the subcontractor may have access to personal information, VCS will ensure that the subcontractor is required to abide by strict privacy requirements in relation to that information.

How personal information is collected?

Information about HPV vaccinations given in schools is provided by state and territory governments to the HPV Register. Information about HPV vaccinations given in the community is provided to the HPV Register by the health professional who gives the vaccination.

What personal information is held?

VCS will only collect and hold personal and health information about an individual which is relevant or related to the performance of its role in maintaining the HPV Register.

The personal information held on the HPV Register may include the name, date of birth, gender, address, indigenous status, school, contact telephone number, and Medicare Number of an individual receiving a vaccination as well as the name, address and Medicare Provider Number of the immunisation provider.

An individual's HPV vaccination history is the only health information recorded on the Register. This information may include details about when and where the HPV vaccine was administered and what HPV vaccine was administered.

In the case of children*, the name of a parent or guardian may also be recorded on the HPV Register
* A child, for the purposes of the HPV Register is:

  • <14 yrs in NSW
  • <16 yrs in SA and NT
  • <18 yrs in other States and territories

How personal information is used?

The personal and health information held about an individual on the HPV Register is used for the following purposes: 

  1. Providing an Immunisation Completion Statement when the course of vaccinations is completed. This is provided to individuals who were vaccinated unless they have elected to Opt-out of correspondence (see Opt-out process below). 
  2. Providing an Immunisation History Statement. This is provided to individuals vaccinated through the schools program when a vaccine dose is overdue, unless they have elected to Opt-out of correspondence (see Opt-out process below). 
  3. Providing a vaccination Reminder Letter to individuals vaccinated through schools program when a vaccine dose is overdue, unless they have elected to Opt-out of correspondence (see Opt-out process below). 
  4. Providing Overdue Dose Reports and Dose Exception Reports to school and community-based immunisation providers. 
  5. Providing access either by telephone or online (where access is granted) to Medical Practitioners and other immunisation providers to an individual’s Immunisation Record.
  6. Information from the Register may be provided to researchers for ethically-approved health research. This will usually involve de-identified information, i.e. summary statistics that do not identify an individual. 
  7. To cross reference vaccination information held by the HPV Register with information from the Pap test registries and cancer registries that are currently maintained by states and territory governments.

To whom is information disclosed?

Personal information about an individual may be disclosed to the following parties: 

  1. An individual’s Immunisation Provider. 
  2. An individual’s Medical Practitioner. 
  3. A representative of the individual (e.g. an authorised representative or lawyer), with their written consent. 
  4. In the case of children*, to the parent or guardian of the child as recorded on the HPV Register. 
  5. The Department of Health & Ageing upon written request. 
  6. Pap test and Cervical Cancer Screening Registers operated by States and Territories.

VCS does not disclose an individual's personal or health information to any overseas organisation or person (other than the individual).
‚Äč

Opting-Off the Register

An individual, or in the case of a child*, their parent/guardian, may elect not to have their personal and immunisation details recorded on the HPV Register. This is referred to as Opting-Off the Register.

To opt-off the Register you should indicate to your Immunisation Provider that your personal details are not to be forwarded to the HPV Register.

If you wish to have your personal information removed from the HPV Register, you (or in the case of a child*, their parent/guardian) should make a request in writing to the Register’s Medical Director (at the details set put below).

Opting-Out of correspondence

A person, or in the case of a child*, their parent/guardian, may elect not to receive any correspondence, such as completion statements or reminder letters, from the HPV Register. This is referred to as Opting-Out of correspondence. When a person opts-out of correspondence, personal details and vaccination history are still recorded on the HPV Register and the usual correspondence to Immunisation Providers and Medical Practitioners will still occur. However, the individual will not receive any of the correspondence that is usually sent to individuals as described above.

To opt-out of correspondence, you need to advise us by telephone or in writing.

HOW AN INDIVIDUAL OBTAINS ACCESS TO THEIR OWN PERSONAL INFORMATION

VCS will provide an individual with access to their personal and health information at no cost. You may also request correction of your personal information and health information.

The following section describes how a person should proceed.

  1. A request for access to or correction of personal information may be in writing or by telephone (subject to rules governing the release of personal information). (A form is available on request - Request for Personal Health Records).
  2. The person should provide sufficient identification so that the authenticity of the request can be assessed by VCS staff.

VCS will endeavour to respond to any request for access or correction within 10 working days of receipt of the request.

HOW TO MAKE A COMPLAINT REGARDING YOUR PRIVACY?

If you have any concerns or complaints about the manner in which VCS has handled your personal or health information, please contact us in writing at the below address. We will endeavour to resolve your complaint promptly and will provide a written response to you. 

Contact details for the Register are:

Postal Address: The Medical Director
NHVPR
PO Box 310
East Melbourne Victoria 8002
Web Address: www.hpvregister.org.au

HPV Register Contact Centre: 1800 478 734

Alternatively, you may wish to direct your complaint to the Office of the Australian Information Commissioner. 

The Office of the Australian Information Commissioner can be contacted at:

Web Address: www.oaic.gov.au
Email: enquiries@oaic.gov.au
Postal Address: Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

NHVPR-Pub-1 V6