Skip to main content

Work from home, competitive remuneration and more - Become a PRO radiologist

Privacy Policy

Professional Radiology Outcomes Pty Ltd (PRO Radiology)

1. Introduction

Your privacy is important to us. This Privacy Policy explains how PRO Radiology collects, uses, holds, discloses and protects personal information, including health information. We are committed to protecting the privacy of patients, referrers and our people, and to complying with our obligations under the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Healthcare Identifiers Act 2010 (Cth), the My Health Records Act 2012 (Cth), and applicable state and territory health records legislation.

PRO Radiology provides specialist radiology and diagnostic imaging services. We hold patient information on IT infrastructure and Cloud-based systems that are Australian-domiciled. Authorised referring practices submit referrals and worksheets to us, Radiologists contracted to us interpret those images and provide diagnostic radiology Reports, and authorised referrers view reports and images, through our online portals.

By providing your personal information to PRO Radiology — for example, by attending a clinic which refers your health information to us, receiving a referral that names us, or using our portals — you consent to us collecting, using, processing through our Software, and disclosing your personal information as described in this policy.

Part A — Information for patients

This Part A applies to patients— that is, individuals whose imaging, reports or related clinical information we hold.

A.1 What kind of personal information we collect

The personal and sensitive information we collect about patients may include:

  • Identity and contact: your name, address, contact details (phone, email, address), date of birth, sex and gender, and an emergency contact.
  • Clinical: your medical history (including medications and allergies relevant to imaging), referral details, results of any imaging or related tests, and information provided by your referrer or another treating practitioner.
  • Imaging and reports: medical images of you, and the diagnostic reports prepared from those images.
  • Government and insurance identifiers: Medicare number, Individual Healthcare Identifier (IHI), Department of Veterans' Affairs (DVA) number, WorkCover or TAC claim details, your My Health Record (MHR), and private health insurance details where relevant to billing or claims.
  • Billing: payment and account details necessary for charging and reconciliation.
  • Feedback: any complaints, compliments, or correspondence you provide to us.

A.2 How and when we collect personal information

We typically collect your personal information either directly from you or from third parties such as your referring practitioner; another treating healthcare provider; your private health insurer or Medicare; your responsible person (see A.5 below); or other sources reasonably required to deliver our services to you. This may happen:

  • When your referrer submits a referral and case documents on your behalf to us through our online portal.
  • When you contact us to make an enquiry.
  • When you complete a patient information or consent form before an examination.
  • During the imaging procedure itself, including any health questionnaire completed for safety reasons.
  • When we generate and issue reports relating to your care.
  • When we issue billing in connection with our services.

A.3 Why we collect, use and disclose personal information

We collect, hold, use and disclose your personal information primarily for the following purposes:

  • To provide diagnostic imaging and associated services to you.
  • To produce and communicate reports to your referrer.
  • To administer billing, claims handling and account management.
  • To ensure your records are correctly linked with the relevant healthcare professionals involved in your care.
  • To uphold quality assurance, accreditation, audit, complaint handling, and clinical education activities.
  • To verify your identity, respond to your enquiries, and follow up where required for your continuing care.
  • To upload information to your My Health Record in accordance with your record settings (see A.6 below).
  • To carry out internal business activities, including information-technology operations, security, risk management, and continuous improvement.
  • To comply with our obligations under Australian law.

Because these uses are necessary to provide and document your healthcare, we do not seek your separate consent for them on each occasion. By engaging with us as a patient, you are taken to consent to the uses set out above and the disclosures described below.

In the course of providing our services, we may disclose your personal information to:

  • Your treating practitioners — including your referrer, your general practitioner, specialists and allied health professionals involved in your care.
  • Other healthcare providers to whom you have been referred.
  • The Australian Digital Health Agency (ADHA) System Operator, for information uploaded to your My Health Record under section A.6.
  • Organisations funding your care — Medicare, the Department of Veterans' Affairs, WorkCover and TAC authorities, and private health insurers.
  • Government and regulatory authorities, courts, tribunals and law-enforcement agencies, as required or authorised by Australian law.
  • Our third-party service providers (described in Part D, §D.2 and §D.8 below).
  • Researchers undertaking ethics-approved research projects, where you have consented, the information has been deidentified or the disclosure is otherwise permitted by law.
  • Authorised representatives where you have nominated them (see A.5).
  • Any party involved in a prospective or actual transfer of our assets, business or company, where appropriate confidentiality protections apply.

A.4 Access to your information through our portals

We operate online portals as part of our service. Referring practices submit referrals and patient case documents through our secure online portal, Radiologists contracted to us view and interpret your images to generate diagnostic radiology Reports, and referrer’s view reports and images through our referrer report and image viewer portal. Information uploaded by referring practices, our Radiologists, or accessed by referrers through these portals is handled in accordance with this Privacy Policy.

Access to the portals is granted only to authorised and authenticated users (User) and is subject to terms of access that include obligations of confidentiality, privacy, and use of the portal only for legitimate clinical purposes. Each User is responsible for ensuring that any individual using the portal on their behalf complies with the same obligations. Portal access is logged and monitored, and suspected misuse may result in revocation of access and referral to the relevant regulator.

A.5 Anonymity, pseudonymity, and responsible person consent

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym. However, because of the nature of diagnostic imaging, it is generally not practicable for clinical services. Anonymous or pseudonymous identification creates an unacceptable patient-safety risk, may contravene the Australian Commission on Safety and Quality in Healthcare's Patient Identification standards, may prevent you from claiming under Medicare or your private health insurance, and is inconsistent with our obligation to maintain accurate health records.

Where you are unable to provide consent or communicate with us (for example, due to incapacity or because you are a minor), PRO Radiology may interact with a responsible person on your behalf in accordance with the Privacy Act. A responsible person may include a parent or guardian, a spouse or de facto partner, a close family member, a person with an enduring medical power of attorney, or a nominated emergency contact.

Where you have nominated an authorised representative in writing, we may correspond with that representative on your behalf, subject to our being satisfied of their authority.

A.6 My Health Record participation

PRO Radiology is a registered healthcare provider organisation participating in the mandatory My Health Record system. Where the law and your record settings permit, we submit clinical information about your imaging — such as your imaging report and exam metadata — to your My Health Record.

Your control over what is in your My Health Record sits with the Australian Digital Health Agency (ADHA) as the System Operator. You may modify the access controls on your record, restrict particular providers, or opt out, through the ADHA. We will respect any preferences you communicate to us about uploads to your record. Withdrawing your consent to MHR upload does not affect our other obligations to provide and document your healthcare.

PRO Radiology's access to and use of the My Health Record system is governed by an internal access policy maintained under My Health Records Rule 2016 reg 14, owned by our Privacy Officer.

A.7 Artificial intelligence and digital tools

PRO Radiology may use technology tools — including artificial intelligence (AI) and machine learning — to support the delivery of our services. Where we use such tools, they may support functions including speech recognition for radiology report dictation; image-analysis assistance to support detection and measurement; appointment-booking support; quality-assurance and / or Peer review of reports. Where AI tools process your personal or sensitive information, that processing is subject to the same privacy, security and consent obligations as the rest of our operations.

AI-generated outputs (including any AI-assisted findings on imaging) are reviewed by a qualified radiologist before being included in a report or communicated to a referrer. We do not use AI tools to make automated decisions that have legal, medical or similarly significant effect on you without human review.

If we introduce or substantially change our AI use in a way that materially affects how your information is handled, we will update this Privacy Policy and, where appropriate, communicate the change.

Part B — Information for referring practitioners and other health professionals

This Part B applies to referring practitioners and other health professionals who use PRO Radiology services.

B.1 What kind of personal information we collect about you

Where you are a referring practitioner or other health professional who uses our services, we may collect:

  • Identity and contact: name, role or profession, place of employment, address, contact details.
  • Professional identifiers: provider number, area of specialisation, AHPRA registration where relevant, Healthcare Provider Identifier (HPI-I) where used.
  • Practice details: details of the referring practice or hospital, and access requirements for our portals.
  • Engagement data: referral patterns, communications with us, and your portal usage.
  • Feedback: any complaints, compliments, or correspondence you provide.

B.2 How we use your personal information

We collect, hold, use and disclose your personal information to:

  • Receive referrals and provide our services to your patients.
  • Issue reports and communicate clinical findings to you.
  • Provide you with portal access to view reports and images for patients you have referred to us.
  • Manage administrative matters such as billing, account management, and practice accreditation processes.
  • Conduct quality assurance, education, and clinical-research activities consistent with the Privacy Act.
  • Comply with our obligations under Australian law.
  • Communicate with you about our services and matters that may be of professional interest to you (see B.4 below).

B.3 Portal access terms

Access to our referrer report and image viewer portal is granted on the basis of a written user-access agreement. By being granted portal access, you commit to use the portal only for the purpose of providing a medical service to your own patients; to keep your credentials confidential; to ensure any practice staff using your access comply with the same obligations; and to notify us immediately of any suspected unauthorised access. Portal access is logged and reviewed; suspected misuse may result in access revocation and referral to the relevant regulator.

B.4 Direct marketing and professional communications

We may contact you (for example, by email) about PRO Radiology services, education events, system changes, and related matters that we reasonably believe may be of professional interest. We may also contact you about products or services of others where we believe they may be relevant to your practice.

You may opt out of receiving direct-marketing communications from us at any time, using the unsubscribe link in any such communication or by contacting our Privacy Officer (Part D, §D.13). Opting out of direct-marketing communications will not affect service-related communications about your patients or your portal access.

Part C — Information for employees, contractors and candidates

This Part C applies to current and former employees, contractors and consultants of PRO Radiology, and to individuals who apply for work with us. Where employee-record exemption under the Privacy Act applies, certain provisions of the Australian Privacy Principles may not apply to records and practices directly relating to employees. PRO Radiology nevertheless commits to the handling described in this Part C, where allowable by law.

C.1 What we collect about you

Information we may collect about employees, contractors and candidates includes:

  • Identity and contact details.
  • Recruitment information — résumé, application materials, references, qualifications, and results of police or background checks where conducted.
  • Employment information — employment history, contracts, role and reporting structure, performance records, tax file number, visa and work-rights status.
  • Payment information — bank account, superannuation and payroll details.
  • Health information — including vaccination status, results of drug or alcohol tests where lawful and applicable to the role, allergies, and dietary requirements where you have provided them.
  • Access and security records — credentials, access logs, and records of compliance with our information-security training.

C.2 Why we collect, use and disclose this information

We use the information described in C.1 for purposes including:

  • Assessing applications for employment or engagement and conducting reference and background checks.
  • Managing the engagement, including payroll, performance management, leave, training, and other administrative matters.
  • Providing and managing your access to PRO Radiology IT infrastructure and systems.
  • Meeting our obligations under workplace laws and tax laws.
  • Complying with our security and risk-management obligations, including investigation of suspected misconduct.
  • On termination of engagement, recovery of assets and revocation of access.

C.3 Who we share this information with

Where lawful and necessary we may share employee, contractor and candidate information with:

  • Referees you have provided when applying for a role with us.
  • Police or background-check providers, where engaged in connection with your application or engagement.
  • Our professional advisors (for example, legal, accounting, HR).
  • Government and regulatory authorities where required or authorised by Australian law.
  • Our third-party service providers (Part D).

Part D — How we manage personal information

This Part D applies across all the audiences described in Parts A, B and C.

D.1 Storage and security

We hold personal information electronically and (to a limited extent) on paper. We take reasonable steps to protect that information from misuse, interference and loss, and from unauthorised access, modification and disclosure. These steps include:

  • Storing patient information on IT infrastructure and systems that are Australian-domiciled.
  • Encrypting personal information at rest and when it is transmitted electronically, using industry-standard cryptographic methods.
  • Restricting administrative access to systems holding scoped data to authorised personnel, supported by multi-factor authentication and secure remote-access controls.
  • Operating an information-security programme covering identity and access management, vulnerability management, change management, backups, incident response, and business continuity.
  • Training staff and contractors on their privacy and security responsibilities.
  • Engaging our service providers under requirements that include obligations to notify us if they suspect or confirm a data breach.
  • Reviewing and improving our information-security practices on an ongoing basis.

Although we take steps to protect your information, we cannot guarantee the security of any information transmitted over the internet. You provide information to us over the internet at your own risk.

D.2 Disclosure to overseas recipients

PRO Radiology stores and processes patient information within Australia. We do not deliberately transfer patient information overseas in normal operation and we do not store data in countries outside of Australia. Some of our service providers (for example, providers of software-as-a-service, endpoint security, credential management, and similar operational tools) may process limited support metadata internationally as part of providing services to us, and some consultant radiologists providing preliminary or second-opinion reviews may access data from outside of Australia through the secure online portal. The main countries where such overseas data processing or access may occur are Canada, United States, India, Northern Macedonia and the UK. We require that all overseas service providers handle personal information consistently with the Australian Privacy Principles and our contractual privacy commitments.

Some referrers may access our referrer portal from overseas locations. This is a network-access pattern rather than a deliberate transfer of patient information abroad.

Where a cross-border disclosure occurs, we take the steps required by APP 8 to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to the information, unless an exception under APP 8.2 applies (such as where you have consented after being informed that APP 8.1 will not apply).

D.3 Retention

Our minimum retention periods reflect Australian legal obligations and clinical best practice:

  • Health records collected while you were an adult — for at least seven (7) years from the last occasion we provided health services to you, or longer where state legislation requires.
  • Health records collected while you were under the age of 18 — at least until you turn 25, or longer where state legislation requires.
  • Business and financial records — retained per Australian Taxation Office and Corporations Act 2001 (Cth) requirements.
  • Employee records — retained per Fair Work Act 2009 (Cth) requirements.

Where a legal hold, ongoing investigation, or contractual obligation requires longer retention, the longer period applies.

D.4 Government-related identifiers

We use and disclose government-related identifiers — Medicare number, Individual Healthcare Identifier (IHI), Healthcare Provider Identifiers (HPI-I and HPI-O), Department of Veterans' Affairs (DVA) number and MHR identifiers — only for purposes permitted under the Privacy Act and the Healthcare Identifiers Act 2010. We do not adopt government-related identifiers as our own internal identifier for any individual.

D.5 Access to, and correction of, your personal information

You have the right to ask for access to the personal information we hold about you, and to ask us to correct information that is inaccurate, incomplete, out-of-date or misleading. We aim to respond within 30 days of your request.

Where you are a patient, we recommend that you obtain your imaging results in consultation with your referrer, who can interpret the results in the context of your wider care. Our radiology report is able to be made available to you seven (7) days after it has been made available to your referrer, to give your referrer the opportunity to contact you about any clinically significant findings.

To request access or correction, please contact our Privacy Officer (§D.13). To protect your privacy, we will ask you to verify your identity before providing access or making a correction; this typically requires two forms of identification (for example, a current photographic driver's licence and a recent utility bill or council-rates notice showing your address).

We may charge a reasonable fee for providing access where this is permitted under APP 12; we do not charge a fee for making a request. We will tell you about any fees before they are incurred.

Some access requests may be refused where the Privacy Act permits us to do so — for example, where giving access would create a serious threat to life, health or safety, would unreasonably impact the privacy of other individuals, or is otherwise required or authorised by law to be refused. Where applicable we will tell you the reason and advise you of any next steps.

D.6 De-identified information and secondary use

We may de-identify your personal information — that is, remove identifiers so that you can no longer be identified — and use or disclose the de-identified information for purposes including statistical analysis, service-quality reporting, internal training and education, and (where conducted) research and machine-learning development. Once information has been de-identified to the standard required by the Privacy Act, it is no longer personal information about you.

We do not sell personal information. Where we engage third parties to assist with de-identification or with the use of de-identified information, those third parties are bound by our standard privacy and security requirements.

D.7 Unsolicited personal information

If we receive personal information about you that we did not solicit, we will determine whether we could have lawfully collected it through our usual means. If we could have, we will handle it under this Privacy Policy. If we could not have, we will destroy or de-identify the information as soon as practicable, unless we are required to retain it by law.

D.8 Cookies and our websites

If you use our websites, our systems may record information such as the date and time of your visit, the pages you accessed, and any information you downloaded. We may use cookies — small files that recognise your browser between sessions — to maintain session continuity and remember your preferences. We may use third-party analytics services to help us understand how our websites are used; those services have their own privacy policies. You can configure your browser to refuse cookies, but some parts of our websites may not have full functionality if you do. Our websites may contain links to other sites; we are not responsible for the privacy practices of those sites.

D.9 State and territory health-records legislation

In addition to the federal Privacy Act 1988 (Cth) and the Australian Privacy Principles, we comply with applicable state and territory health-records legislation — including the Health Records Act 2001 (Vic) and the Victorian Health Privacy Principles for patients in Victoria; the Health Records and Information Privacy Act 2002 (NSW) and the NSW Health Privacy Principles for patients in New South Wales; and the Health Records (Privacy and Access) Act 1997 (ACT) for patients in the Australian Capital Territory. Where state or territory legislation imposes more stringent requirements, the more stringent requirement applies.

D.10 Notifiable data breaches

If we become aware of a suspected or confirmed data breach affecting personal information we hold, we will assess the breach under the Notifiable Data Breaches scheme established by Part IIIC of the Privacy Act 1988 (Cth). Where the breach is determined to be an eligible data breach likely to result in serious harm, we will notify affected individuals as soon as practicable and notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable and in any case within 30 days of becoming aware. Where the breach involves information uploaded to the My Health Record system, we will also notify the Australian Digital Health Agency System Operator.

D.11 Designated officers

PRO Radiology is required by Australian law and by Australian Digital Health Agency operational requirements to appoint specific officers to govern its participation in the Healthcare Identifiers Service and the My Health Record system, and to be the contact point for individuals exercising privacy rights:

Privacy Officer

Function: Manages this Privacy Policy and the My Health Record access policy; first contact for privacy enquiries and complaints; conducts NDB-scheme assessments.
Statutory basis: Privacy Act 1988 (Cth) APP 1.5; OAIC guidance; My Health Records Rule 2016 reg 14.

Responsible Officer (RO)

Function: Legally accountable for PRO Radiology's participation in the Healthcare Identifiers Service and the My Health Record system.
Statutory basis: Healthcare Identifiers Act 2010 (Cth); Healthcare Identifiers Regulation 2010; ADHA HPOS operational requirements.

Organisation Maintenance Officer (OMO)

Function: Administers user access to the HI Service and MHR system on behalf of PRO Radiology.
Statutory basis: ADHA HPOS operational requirements.

At PRO Radiology's current scale, one individual may legally hold more than one of these roles. Contact details for the Privacy Officer are in §D.13 below.

D.12 Service-related communications

From time to time we will contact you about important matters relating to your care or the services we provide — for example, to confirm or change appointments, to follow up on imaging where clinically appropriate, to advise of a recall, or to communicate billing or claim information. These communications are not marketing and you cannot opt out of them while you have an active relationship with PRO Radiology.

D.13 Privacy complaints and contacting us

If you have a question about this Privacy Policy, want to access or correct your personal information, or want to make a privacy complaint, please contact our Privacy Officer:

  • Privacy Officer: Michael Paholski
  • Email: Privacy@PRORadiology.com.au
  • Phone: 1300 243 110 (Australia)
  • Post: Suite 570, 45 Avalon Parade, Avalon Beach, NSW, 2107

We will acknowledge your complaint within five (5) business days and aim to provide a substantive response within 30 days.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC):

  • Phone: 1300 363 992
  • Online: www.oaic.gov.au

If your concern relates to health records covered by state legislation, you may also contact the relevant state regulator (for example, the Health Complaints Commissioner in Victoria, or the Privacy Commissioner of NSW).

D.14 Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version, with its effective date, is published on our website at www.PRORadiology.com.au/privacy-policy.