Work from home, competitive remuneration and more - Become a PRO radiologist
Work from home, competitive remuneration and more - Become a PRO radiologist
Professional Radiology Outcomes Pty Ltd (PRO Radiology)
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.
This Part A applies to patients— that is, individuals whose imaging, reports or related clinical information we hold.
The personal and sensitive information we collect about patients may include:
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:
We collect, hold, use and disclose your personal information primarily for the following purposes:
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:
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.
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.
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.
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.
This Part B applies to referring practitioners and other health professionals who use PRO Radiology services.
Where you are a referring practitioner or other health professional who uses our services, we may collect:
We collect, hold, use and disclose your personal information to:
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.
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.
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.
Information we may collect about employees, contractors and candidates includes:
We use the information described in C.1 for purposes including:
Where lawful and necessary we may share employee, contractor and candidate information with:
This Part D applies across all the audiences described in Parts A, B and C.
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:
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.
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).
Our minimum retention periods reflect Australian legal obligations and clinical best practice:
Where a legal hold, ongoing investigation, or contractual obligation requires longer retention, the longer period applies.
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.
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.
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.
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.
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.
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.
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.
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:
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.
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.
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.
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.
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:
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):
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).
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.