Personally Controlled Electronic Health Record System: Legislation Issues Paper

Size: px
Start display at page:

Download "Personally Controlled Electronic Health Record System: Legislation Issues Paper"

Transcription

1 Personally Controlled Electronic Health Record System: Legislation Issues Paper Introduction The AMA has reviewed the Personally Controlled Electronic Health Record System: Legislation Issues Paper. The AMA s response to selected questions posed therein is set out below. Medical practitioners are already subject to a vast and complex array of regulatory and administrative requirements for the provision of medical services, the authoring of medical documents and the security of that information. The PCEHR legislation should seek to impose as few additional obligations on medical practitioners and other healthcare providers as possible. Where existing legislation or common law is applicable to medical information, additional legislative measures specifically for the PCEHR are not warranted. The AMA notes and supports the statements in the Issues Paper that support this principle. Fundamentally, the purpose of the legislation for the PCEHR should be to ensure that only people who have a genuine need and are authorised to do so are entitled to access a person s PCEHR. The legislation should also set out the framework under which the PCEHR system operator will function and the requirements on the repository operators. The Issues Paper specifically seeks feedback on how the legislative proposals support a PCEHR system as described in the PCEHR Draft Concept of Operations. Given that the Government recently sought submissions on the Draft Concept of Operations and a further draft incorporating those submissions has not been released, the AMA is concerned that the legislative proposals in the Issues Paper may pre-empt the final design of the PCEHR. The AMA has responded to the questions in the Issues Paper as asked, but refers to its submission on the Draft Concept of Operations in which important objections to the proposed design of the PCEHR are expressed. Question 3 What possible barriers are there to the participation of individuals through their authorised representatives? Medical practitioners need to be confident that the PCEHR system operator has carried out all the necessary checks before verifying the identity of a person claiming to be an

2 authorised representative of their patient. This obligation should be included in the legislation. In practice, medical practitioners will need to satisfy themselves that the person accompanying the patient is the authorised representative when decisions are being made to access information on the PCEHR and to post information onto the PCEHR about the health care event. Question 4 What other circumstances might need to be accommodated in the administrative arrangements for minors? We propose the following revision to Proposal 7 at the last 3 lines: Requests by minors under 14 years of age to manage their own PCEHR will be accepted by the PCEHR system operator on the written assurance of the individual's treating practitioner or other treating health professional that the individual is a mature minor whose circumstances warrant that the individual manages their own record. Question 5 What are the possible risks related to the creation and use of a pseudonymous PCEHR? A pseudonymous PCEHR will not provide any medical benefit to a patient in an emergency situation if that patient is identified under another name. Question 6 Are there other terms and conditions that should apply to healthcare provider organisations in regulating the eligibility of authorized users? In respect of Proposal 9 it is not clear to us whether the obligations for a registered healthcare provider that have been proposed are a barrier to using the PCEHR if the provider does not meet them, or whether the provider will incur penalties for failing to meet them after registering as a healthcare provider organisation. We do not support Proposal 10 for the legislation to provide a framework for standards with which healthcare provider organisations must comply. As stated above, we see no reason why this legislation should include a framework for yet another entity to set standards for the provision of medical services, the authoring of clinical documents, or the obligation for the safekeeping of medical information. Any standards imposed by legislation should apply only to the PCEHR system operator and repository operators. We note proposal 35 to not set requirements to support the security of the PCEHR system. Page 2

3 We assume Proposal 11 contemplates an audit process. The legislation should clarify what would need to be produced by the healthcare provider to prove that contracted service providers and administrative staff, must be identifiable in the healthcare provider organisation s local system. It should be within the healthcare provider s discretion to determine who within that organisation has a legitimate need to access the PCEHR system. The practicalities for some medical practices or hospitals mean that shared computer resources for administrative staff are often logged onto using generic identifiers such as User1. Constant logging on and logging off by individual staff each time they use the computer and access the PCEHR system will cause significant disruption to current workflow arrangements. To help minimise the administrative burden on healthcare providers the legislation and audit arrangements should allow healthcare providers to authorise users within their organisations by position title. In drafting the legislation it is important to be mindful that health practitioners access patient information every day, every time they treat a patient. The law should not create a disincentive to health practitioners in performing this activity. Similarly, administrative staff have access to patient information and the legislation should not disrupt current workflow arrangements. Question 7 What are the essential rules and standards with which a nominated healthcare provider should comply in relation to authoring and managing a shared health summary? In previous consultations with the Department of Health and Ageing and NeHTA the AMA has been assured that the PCEHR legislation would describe criteria for who could be the nominated provider. The requirement proposed in the PCEHR Draft Concept of Operations, that the nominated provider possesses an IHI is too broad. This category includes all healthcare professionals which all have significant differences in skills and knowledge. For medical practitioners to be able to rely on the shared health summary they need to be able be confident that another medical practitioner has considered and moderated the clinical information. The legislation should specify that the nominated provider could only be a medical practitioner or Aboriginal health worker. We do not agree with Proposal 12 or 13 to provide a framework for rules and standards for the nominated provider. The medical profession is already subject to regulation about authoring medical documents and good medical practice and is well versed in determining the clinically appropriate information to be included in a shared health Page 3

4 summary. There is no reason to treat authoring and managing a shared health summary in the PCEHR differently to other medical documents. Question 9. What are the essential obligations that should be met by repository operators? Repository operators should be obliged to use systems that are interoperable across the healthcare sector. It would be inappropriate for repository operators to influence the medical practice software market by the use of systems that have limited interoperability. Question 13 Are you aware of specific examples of information for which intellectual property rights might present a significant barrier to the use of the information in the PCEHR system? Medical practitioners have invested a significant amount of time in the production of health summaries for their patients. The current proposals for the PCEHR ask medical practitioners to voluntarily upload that work onto the system. Practitioners may view this as a request to give up their intellectual property for nothing. The AMA believes that medical practitioners should be properly remunerated for contributing to the PCEHR. Question 14 Can you identify any other options for records retention and can you identify any other issues regarding records management that have not yet been considered in this paper? The AMA considers the requirement for PCEHR repositories and portals to adopt the longest minimum jurisdictional requirement of 15 years to be reasonable. However, we question the consequent obligation on medical practitioners who practise in jurisdictions with lower minimum retention requirements in respect of documents downloaded from the PCEHR and incorporated in a patient s paper or local electronic record. The Issues Paper states that in many respects records on the PCEHR will be treated for legal purposes in the same way as currently existing medical records. We anticipate there may be situations where medical practitioners might need to produce PCEHR records in the course of Medicare Benefits Schedule, Pharmaceutical Benefits Schedule and Medical Board investigations and seek further discussions with the Department on this issue. Page 4

5 Question 15 Are there additional access functions for individuals that need to be included in legislation? The Draft Concept of Operations describes a PCEHR where these functions will be built into the system. Presumably, the system will not allow the individual to perform any other actions with their PCEHR. There appears to be no reason to also legislate these functions unless it is to provide a range of actions from which to create a sub-set of allowable activities by authorised representatives. Question 16 Should any specific restrictions apply to the extent to which an authorised representative can act on behalf of the individual within the PCEHR system? An authorised representative of a patient verified by the PCEHR system operator (see response to Question 3) should be able to carry out all the functions of the individual they represent. Question 20 Are there additional issues in relation to authorised users that should be addressed in the legislation or regulations? In order to answer this question it is necessary to understand what a healthcare provider would need to provide to prove during an audit that contracted service providers and administrative staff, must be identifiable in the healthcare provider organisation s local system. The proposed legislation should specifically include medical students as a category of authorised users who can access a PCEHR. It is important for medical students to have access to the PCEHR, so that they can access and contribute to a patient's e-health record as part of the medical team, just as they currently do with hospital records. Question 21 Should there be additional legislative provisions for emergency access to PCEHR information? Providing any additional legislative provisions for emergency access to PCEHR information would unnecessarily further complicate the legislative provisions. The proposal for an audit trail for accessing the PCEHR will allow individuals to pursue inappropriate use of the emergency access provisions through the existing channels for breaches of privacy. Page 5

6 Similarly, no additional offences or penalties should be created by the PCEHR legislation or related legislation in respect of emergency access to PCEHR information. Question 24 Are there any reasons why clinical information downloaded from the PCEHR system should be required to be handled differently to other information held by a healthcare provider in their local records? No, there should be no additional requirements on the healthcare provider for handling PCEHR information. However, the legislation should provide protections for healthcare providers from any legal consequences flowing from retaining a document downloaded from a PCEHR in their local records if the patient subsequently disallows that healthcare provider s access to the patient s PCEHR. Question 29 Is it appropriate to impose a penalty on the individual who requests a record from the PCEHR system when not entitled to do so? The offences proposed in Proposal 36 refer to registered healthcare providers. While we note Proposal 9 for healthcare providers to register with the PCEHR system operator, it is not clear what the purpose and effect of the combination of Proposals 9 and 36 will have. These proposals need more detailed consultation with healthcare providers about their intended purpose and what administrative obligations they will place on healthcare providers. We have taken the word request to include the conduct of a search of the PCEHR system for a patient s PCEHR. The current wording of this proposed offence would appear to capture events likely to be common in everyday medical practice when dealing with the PCEHR. It is probable that medical practitioners and their administrative staff will routinely request records from the PCEHR system to which they have not yet been granted access by the individual. This activity should not attract any penalty, particularly given the Government s desire that healthcare providers make use of the PCEHR. The system itself should prevent anyone who is not authorised to access an individual s PCHER from viewing the PCEHR. Consultations with Departmental officials have assured the AMA that this proposed offence is not intended to capture anything done in normal clinical practice. Accordingly, the wording of the offence should be changed to reflect the intention to capture cyber Page 6

7 crime or other fraudulent activity and be expressed to be applicable to all people and entities rather than focusing on healthcare providers. Finally, if the offences contemplated are in relation to cyber crime and fraud it should be sufficient to rely on existing legislation that makes those activities criminal offences. Question 33 What are your views about the preferred governance structures for the PCEHR system and national e-health elements more broadly? The governance arrangements must be transparent, accountable and developed in collaboration with key stakeholders. The legislation should set out the structure of the roles and functions of the PCEHR system operator. The legislation should also set out the structure and membership of the PCEHR system operator s board, including a requirement for the inclusion of practicing medical practitioners on the board. The AMA does not support the inclusion of compliance framework for standards or clinical governance proposed as issues to be managed by the PCEHR system operator on p.37 of the Issues Paper. As stated in responses above, it must not be a function of the PCEHR system operator or any other entity created under this legislation to set standards or monitor compliance with standards for healthcare provider organisations or healthcare providers. The PCEHR system operator should have functions related to the monitoring and regulation of the repository operators. The legislation should not contemplate a broader role for the body tasked with governance of the PCEHR in the broader ehealth sector in the future. Question 34 What would be your preferred single entry point for PCEHR privacy complaints? The AMA does not support the single entry point proposal for PCEHR privacy complaints. Privacy complaints about the PCEHR should be treated in the same way as any other privacy complaint. AUGUST 2011 Page 7

australian nursing federation

australian nursing federation australian nursing federation Submission to Department of Health and Ageing in response to the Personally Controlled Electronic Health Record (PCEHR) System Legislation Issues Paper August 2011 Lee Thomas

More information

Submission in Response to the Personally Controlled Electronic Health Record System: Legislation Issues Paper

Submission in Response to the Personally Controlled Electronic Health Record System: Legislation Issues Paper Submission in Response to the Personally Controlled Electronic Health Record System: Legislation Issues Paper August 2011 About National Seniors Australia With a quarter of a million individual members

More information

QUESTIONS AND ANSWERS HEALTHCARE IDENTIFIERS BILL 2010

QUESTIONS AND ANSWERS HEALTHCARE IDENTIFIERS BILL 2010 About Healthcare Identifiers QUESTIONS AND ANSWERS HEALTHCARE IDENTIFIERS BILL 2010 Q1. What is the Healthcare Identifiers Service? The Healthcare Identifiers (HI) Service will implement and maintain a

More information

EXPLANATORY STATEMENT. Issued by Authority of the Minister for Health. My Health Records Act My Health Records (Assisted Registration) Rule 2015

EXPLANATORY STATEMENT. Issued by Authority of the Minister for Health. My Health Records Act My Health Records (Assisted Registration) Rule 2015 EXPLANATORY STATEMENT Issued by Authority of the Minister for Health My Health Records Act 2012 My Health Records (Assisted Registration) Rule 2015 The My Health Records Act 2012 (the Act) enables the

More information

Personally controlled electronic health record (ehealth record) system

Personally controlled electronic health record (ehealth record) system Personally controlled electronic health record (ehealth record) system ehealth record System Operator Audit report Information Privacy Principles audit Section 27(1)(h) Privacy Act 1988 Audit undertaken:

More information

Submission of the Medical Indemnity Industry Association of Australia to the Senate Standing Committee on Community Affairs (January 2012)

Submission of the Medical Indemnity Industry Association of Australia to the Senate Standing Committee on Community Affairs (January 2012) Inquiry into the Personally Controlled Electronic Health Records Bill 2011 and the Personally Controlled Electronic Health Records (Consequential Amendments) Bill 2011 Submission of the Medical Indemnity

More information

Update on the new Electronic Health Record: PCEHR

Update on the new Electronic Health Record: PCEHR Briefing Paper November 2012 :: FOR GENERAL DISTRIBUTION Update on the new Electronic Health Record: PCEHR Background As of 1 July 2012, all Australians can create their own Personally Controlled Electronic

More information

NATIONAL PARTNERSHIP AGREEMENT ON E-HEALTH

NATIONAL PARTNERSHIP AGREEMENT ON E-HEALTH NATIONAL PARTNERSHIP AGREEMENT ON E-HEALTH Council of Australian Governments An agreement between the Commonwealth of Australia and the States and Territories, being: The State of New South Wales The State

More information

Queensland. Health Practitioner Regulation (Administrative Arrangements) National Law Act 2008

Queensland. Health Practitioner Regulation (Administrative Arrangements) National Law Act 2008 Queensland Health Practitioner Regulation (Administrative Arrangements) National Law Act 2008 Act No. 62 of 2008 Queensland Health Practitioner Regulation (Administrative Arrangements) National Law Act

More information

User Guide for Practice Managers

User Guide for Practice Managers Healthcare Identifiers Service User Guide for Practice Managers Designed to assist practice managers to implement the Healthcare Identifiers (HI) Service. PAGE A This publication was produced by the National

More information

Software Service Agreement.

Software Service Agreement. <Client Name> Version: 0.9 Issue Date: 25 August 2014 This document is issued in Strict Commercial Confidence. No part of this document may be reproduced or distributed in any form or by any means without prior written

More information

Information Governance and Management Standards for the Health Identifiers Operator in Ireland

Information Governance and Management Standards for the Health Identifiers Operator in Ireland Information Governance and Management Standards for the Health Identifiers Operator in Ireland 30 July 2015 About the The (the Authority or HIQA) is the independent Authority established to drive high

More information

Second Clinical Safety Review of the Personally Controlled Electronic Health Record (PCEHR) June 2013

Second Clinical Safety Review of the Personally Controlled Electronic Health Record (PCEHR) June 2013 Second Clinical Safety Review of the Personally Controlled Electronic Health Record (PCEHR) June 2013 Undertaken by KPMG on behalf of Australian Commission on Safety and Quality in Health Care Contents

More information

Chiropractic Boards response 15 December 2008

Chiropractic Boards response 15 December 2008 NATIONAL REGISTRATION AND ACCREDITATION SCHEME FOR THE HEALTH PROFESSIONS Chiropractic Boards response 15 December 2008 CONSULTATION PAPER Proposed arrangements for accreditation Issued by the Practitioner

More information

Policy on Public and School Bus Closed Circuit Television Systems (CCTV)

Policy on Public and School Bus Closed Circuit Television Systems (CCTV) DEPARTMENT OF TRANSPORT Policy on Public and School Bus Closed Circuit Television Systems (CCTV) Responsibility of: Public Transport Division TRIM File: DDPI2010/3680 Effective Date: July 2010 Version

More information

Guidelines on endorsement as a nurse practitioner

Guidelines on endorsement as a nurse practitioner Guidelines on endorsement as a nurse practitioner 7160 Introduction The National Registration and Accreditation Scheme (the National Scheme) for health professionals in Australia commenced on 1 July 2010

More information

AISA Position Statement: Mandatory Data Breach Notification in Australia

AISA Position Statement: Mandatory Data Breach Notification in Australia AISA Position Statement: Mandatory Data Breach Notification in Australia Overview Although AISA members are broadly in support of mandatory data breach notification in Australia they have a number of concerns

More information

Victorian Training Guarantee Compliance Framework

Victorian Training Guarantee Compliance Framework Victorian Training Guarantee Compliance Framework Published by the Communications Division for Higher Education and Skills Group Department of Education and Early Childhood Development Melbourne October

More information

Getting ready for the PIP ehealth incentive and PCEHR

Getting ready for the PIP ehealth incentive and PCEHR Getting ready for the PIP ehealth incentive and PCEHR PIP Requirement: R1 Integrating HI s Check if your clinical software system is or will be HI (HIPI-0, HPI-I and IHI) compliant. Install Individual

More information

NASH PKI Certificate for Healthcare Provider Organisations renewal confirmation

NASH PKI Certificate for Healthcare Provider Organisations renewal confirmation NASH PKI Certificate for Healthcare Provider Organisations renewal confirmation Please send your completed renewal confirmation to: Department of Human Services Fax number: 1800 890 698 Number of pages

More information

The review of the Personally Controlled Electronic Health Records System:

The review of the Personally Controlled Electronic Health Records System: APHA submission to The review of the Personally Controlled Electronic Health Records System: Proposals on how to improve the system Australian Private Hospitals Association ABN 82 008 623 809 November

More information

Preliminary Privacy Impact Assessment of the National Facial Biometric Matching Capability - Interoperability Hub

Preliminary Privacy Impact Assessment of the National Facial Biometric Matching Capability - Interoperability Hub December 2015 Preliminary Privacy Impact Assessment of the National Facial Biometric Matching Capability - Interoperability Hub Attorney-General s Department Response Identity crime is one of the most

More information

SRA Compensation Arrangements Review Consultation: The introduction of an eligibility criteria

SRA Compensation Arrangements Review Consultation: The introduction of an eligibility criteria SRA Compensation Arrangements Review Consultation: The introduction of an eligibility criteria May 2014 SRA Compensation Arrangements Review Consultation - who should be eligible to benefit from the SRA'

More information

Mandatory data breach notification in the ehealth record system

Mandatory data breach notification in the ehealth record system Mandatory data breach notification in the ehealth record system Draft September 2012 A guide to mandatory data breach notification under the personally controlled electronic health record system Contents

More information

Appendix A DRAFT INFORMATION MANAGEMENT PLAN

Appendix A DRAFT INFORMATION MANAGEMENT PLAN 1 Appendix A DRAFT INFORMATION MANAGEMENT PLAN Pacific Region Identity Protection Project PRIPP April 2004 Forum Eyes Only 2 ABBREVIATIONS Throughout this report the following abbreviations will be utilised:

More information

Overview of. Health Professions Act Nurses (Registered) and Nurse Practitioners Regulation CRNBC Bylaws

Overview of. Health Professions Act Nurses (Registered) and Nurse Practitioners Regulation CRNBC Bylaws Overview of Health Professions Act Nurses (Registered) and Nurse Practitioners Regulation CRNBC Bylaws College of Registered Nurses of British Columbia 2855 Arbutus Street Vancouver, BC Canada V6J 3Y8

More information

Custodian-Node data provision terms and conditions

Custodian-Node data provision terms and conditions Custodian-Node data provision terms and conditions Parties Node Operator Data Custodian Background A B C D E [Insert legal name of node][insert ACN/ABN/ARBN] of [Insert address]\ [Insert legal name of

More information

Connecting your healthcare: a guide to registering for an ehealth record

Connecting your healthcare: a guide to registering for an ehealth record ehealth Registration Booklet Connecting your healthcare: a guide to registering for an ehealth record ehealth.gov.au Congratulations for taking your first step towards the ehealth record system! Personally

More information

CLAIMS HANDLING GUIDELINES. for CTP Insurers

CLAIMS HANDLING GUIDELINES. for CTP Insurers CLAIMS HANDLING GUIDELINES for CTP Insurers Initially issued 2000 Reissued: 1 July 2004; 18 September 2006; 1 July 2008; 1 October 2008, 1 May 2014 INTRODUCTION The MAA Claims Handling Guidelines (the

More information

Data Governance in-brief

Data Governance in-brief Data Governance in-brief What is data governance? Data governance is the system of decision rights and accountabilities surrounding data and the use of data. It can involve legislation, organisational

More information

QUEENSLAND COUNTRY HEALTH FUND. privacy policy. Queensland Country Health Fund Ltd ABN 18 085 048 237. better health cover shouldn t hurt

QUEENSLAND COUNTRY HEALTH FUND. privacy policy. Queensland Country Health Fund Ltd ABN 18 085 048 237. better health cover shouldn t hurt QUEENSLAND COUNTRY HEALTH FUND privacy policy Queensland Country Health Fund Ltd ABN 18 085 048 237 better health cover shouldn t hurt 1 2 contents 1. Introduction 4 2. National Privacy Principles 5 3.

More information

COMPLIANCE FRAMEWORK AND REPORTING GUIDELINES

COMPLIANCE FRAMEWORK AND REPORTING GUIDELINES COMPLIANCE FRAMEWORK AND REPORTING GUIDELINES DRAFT FOR CONSULTATION June 2015 38 Cavenagh Street DARWIN NT 0800 Postal Address GPO Box 915 DARWIN NT 0801 Email: utilities.commission@nt.gov.au Website:

More information

Human Services Quality Framework. User Guide

Human Services Quality Framework. User Guide Human Services Quality Framework User Guide Purpose The purpose of the user guide is to assist in interpreting and applying the Human Services Quality Standards and associated indicators across all service

More information

How to Monitor Employee Web Browsing and Email Legally

How to Monitor Employee Web Browsing and Email Legally WHITEPAPER: HOW TO MONITOR EMPLOYEE WEB BROWSING AND EMAIL LEGALLY How to Monitor Employee Web Browsing and Email Legally ABSTRACT The Internet and email are indispensable resources in today s business

More information

COAG National Legal Profession Reform Discussion Paper: Trust money and trust accounting

COAG National Legal Profession Reform Discussion Paper: Trust money and trust accounting COAG National Legal Profession Reform Discussion Paper: Trust money and trust accounting Purpose The purpose of this Paper is to outline the Taskforce s preferred approach to regulation of trust money

More information

Council meeting, 10 February 2011. Professional indemnity insurance. Executive summary and recommendations. Introduction

Council meeting, 10 February 2011. Professional indemnity insurance. Executive summary and recommendations. Introduction Council meeting, 10 February 2011 Professional indemnity insurance Executive summary and recommendations Introduction In June 2010, the final report of the Independent review of the requirement to have

More information

Statutory duty of candour with criminal sanctions Briefing paper on existing accountability mechanisms

Statutory duty of candour with criminal sanctions Briefing paper on existing accountability mechanisms Statutory duty of candour with criminal sanctions Briefing paper on existing accountability mechanisms Background In calling for the culture of the NHS to become more open and honest, Robert Francis QC,

More information

Healthcare Professionals Crossing Borders Agreement

Healthcare Professionals Crossing Borders Agreement Healthcare Professionals Crossing Borders Agreement Contents 1. Healthcare Professionals Crossing Borders Agreement (the Agreement) 2 2. Background 5 2.1 EU Directives and Project Aims 5 2.2 Developing

More information

AUDIT AND RISK MANAGEMENT COMMITTEE CHARTER

AUDIT AND RISK MANAGEMENT COMMITTEE CHARTER MASTERMYNE GROUP LIMITED AUDIT AND RISK MANAGEMENT COMMITTEE CHARTER Purpose of Charter 1. The Audit and Risk Management Committee Charter (Charter) governs the operations of the Audit and Risk Management

More information

Westpac Business Debit MasterCard Application

Westpac Business Debit MasterCard Application Westpac Business Debit MasterCard Application Westpac Banking Corporation ABN 33 007 457 141 AFSL and Australian credit licence 233714 In order to apply for a Westpac Business Debit MasterCard, the following

More information

Privacy Statement. April 2015

Privacy Statement. April 2015 Privacy Statement April 2015 RACT Health Insurance is provided by GMHBA Limited. In this privacy statement, references to RACT Health Insurance are references to GMHBA Limited. References to RACT are references

More information

ACOT WEBSITE PRIVACY POLICY

ACOT WEBSITE PRIVACY POLICY ACOT WEBSITE PRIVACY POLICY Our commitment to privacy acot.ca (the Website ) is a website owned and operated by The Alberta College of Occupational Therapists ( ACOT ), also referred to as we, us, or our

More information

Authorized Subscribers

Authorized Subscribers Authorized Subscribers Obtaining a Digital Certificate following receipt of your Authorized Subscriber Membership number Instructions: April, 2013 Following the acceptance of your application to become

More information

DATA PROTECTION POLICY

DATA PROTECTION POLICY Reference number Approved by Information Management and Technology Board Date approved 14 th May 2012 Version 1.1 Last revised N/A Review date May 2015 Category Information Assurance Owner Data Protection

More information

Public consultation paper

Public consultation paper Public consultation paper September 2013 Proposed expanded endorsement for scheduled medicines Draft Registration standard for endorsement of registered nurses and/or registered midwives to supply and

More information

The Performance Review Standards

The Performance Review Standards The Performance Review Standards Standards of Good Regulation June 2010 The Professional Standards Authority The Professional Standards Authority for Health and Social Care is the new name for the Council

More information

How we deal with complaints and concerns

How we deal with complaints and concerns I Data Protection Act How we deal with complaints and concerns A guide for data controllers 1 Data Protection Act How we deal with complaints and concerns The ICO is the UK s independent public authority

More information

Draft guidance for registered pharmacies providing internet and distance sale, supply or service provision

Draft guidance for registered pharmacies providing internet and distance sale, supply or service provision Draft guidance for registered pharmacies providing internet and distance sale, supply or service provision September 2014 1 The General Pharmaceutical Council is the regulator for pharmacists, pharmacy

More information

Telecommunications (Interception and Access) Amendment (Data Retention) Bill 2014

Telecommunications (Interception and Access) Amendment (Data Retention) Bill 2014 Telecommunications (Interception and Access) Amendment (Data Retention) Bill 2014 AIIA response to Bill and Explanatory Memorandum January 2015 T 61 2 6281 9400 E W info@aiia.com.au www.aiia.comau About

More information

Public Advisory Statement. The Personally-Controlled Electronic Health Record. Frequently Asked Questions by Consumers

Public Advisory Statement. The Personally-Controlled Electronic Health Record. Frequently Asked Questions by Consumers http://www.privacy.org.au Secretary@privacy.org.au http://www.privacy.org.au/about/contacts.html Background Public Advisory Statement The Personally-Controlled Electronic Health Record Frequently Asked

More information

Mount Gibson Iron Limited Corporate Governance Policies and Practices Manual Shareholder Communication Policy

Mount Gibson Iron Limited Corporate Governance Policies and Practices Manual Shareholder Communication Policy 1 Introduction 1.1 Mount Gibson Iron Limited (the Company) is committed to the following objectives: (d) (e) Ensuring that shareholders and the market are provided with full and timely information about

More information

STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services

STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services STFC Monitoring and Interception policy for Information & Communications Technology Systems and Services Issue 1.0 (Effective 27 June 2012) This document contains a copy of the STFC policy statements outlining

More information

Council 23 July 2014 Consultation on draft Professional Indemnity Insurance Rules

Council 23 July 2014 Consultation on draft Professional Indemnity Insurance Rules 10 Council 23 July 2014 Consultation on draft Professional Indemnity Insurance Rules Classification Purpose Issue Public For decision GOsC is required to make changes to its Professional Indemnity Insurance

More information

Queensland Taxi Security Camera Program Changes

Queensland Taxi Security Camera Program Changes Queensland Taxi Security Camera Program Changes Frequently Asked Questions GENERAL INFORMATION 1. What is the taxi security camera program? It is a program administered by the Department of Transport and

More information

INSURANCE ACT 2008 CORPORATE GOVERNANCE CODE OF PRACTICE FOR REGULATED INSURANCE ENTITIES

INSURANCE ACT 2008 CORPORATE GOVERNANCE CODE OF PRACTICE FOR REGULATED INSURANCE ENTITIES SD 0880/10 INSURANCE ACT 2008 CORPORATE GOVERNANCE CODE OF PRACTICE FOR REGULATED INSURANCE ENTITIES Laid before Tynwald 16 November 2010 Coming into operation 1 October 2010 The Supervisor, after consulting

More information

Guideline: Medical supervision of Diabetes Registered Nurse Prescribing 2014

Guideline: Medical supervision of Diabetes Registered Nurse Prescribing 2014 Guideline: Medical supervision of Diabetes Registered Nurse Prescribing 2014 The Nursing Council of New Zealand has adapted this Guideline which was developed by the New Zealand Society for the Study of

More information

SECOND READING SPEECH

SECOND READING SPEECH SECOND READING SPEECH Ambulance Service Amendment Bill 2013 Mr Speaker The purpose of this Bill is to amend the Ambulance Service Act 1982 to better reflect contemporary ambulance practice and to provide

More information

Questions and answers for custodians about the Personal Health Information Privacy and Access Act (PHIPAA)

Questions and answers for custodians about the Personal Health Information Privacy and Access Act (PHIPAA) Questions and answers for custodians about the Personal Health Information Privacy and Access Act (PHIPAA) This document provides answers to some frequently asked questions about the The Personal Health

More information

Information Governance Framework. June 2015

Information Governance Framework. June 2015 Information Governance Framework June 2015 Information Security Framework Janice McNay June 2015 1 Company Thirteen Group Lead Manager Janice McNay Date of Final Draft and Version Number June 2015 Review

More information

AMA NSW AND ASMOF NSW Submission on Health Practitioners Regulation National Law

AMA NSW AND ASMOF NSW Submission on Health Practitioners Regulation National Law AMA NSW AND ASMOF NSW Submission on Health Practitioners Regulation National Law This submission is filed jointly on behalf of AMA NSW and ASMOF NSW. We note the submission of the Australian Medical Association

More information

Information Management and Security Policy

Information Management and Security Policy Unclassified Policy BG-Policy-03 Contents 1.0 BG Group Policy 3 2.0 Policy rationale 3 3.0 Applicability 3 4.0 Policy implementation 4 Document and version control Version Author Issue date Revision detail

More information

SUBMISSION FROM GREENBELT GROUP LIMITED

SUBMISSION FROM GREENBELT GROUP LIMITED SUBMISSION FROM GREENBELT GROUP LIMITED 1. Greenbelt Group Limited, (No.SC192378) of Abbotsford House, Abbotsford Place, Glasgow G5 9SS, (GGL) invites the Committee to have regard to the following submissions

More information

ICMA Private Wealth Management Charter of Quality

ICMA Private Wealth Management Charter of Quality ICMA Private Wealth Management Charter of Quality Preamble 1. The Private Wealth Management Charter of Quality ( the Charter of Quality ) is a voluntary standard of recommended minimum good market practice.

More information

Professional Competence. Guidelines for Doctors

Professional Competence. Guidelines for Doctors Professional Competence Guidelines for Doctors Professional competence at a glance What doctors need to know Contact the postgraduate training body most relevant to your day-to-day practice and enrol in

More information

OFFICIAL. NCC Records Management and Disposal Policy

OFFICIAL. NCC Records Management and Disposal Policy NCC Records Management and Disposal Policy Issue No: V1.0 Reference: NCC/IG4 Date of Origin: 12/11/2013 Date of this Issue: 14/01/2014 1 P a g e DOCUMENT TITLE NCC Records Management and Disposal Policy

More information

National Standards for Safer Better Healthcare

National Standards for Safer Better Healthcare National Standards for Safer Better Healthcare June 2012 About the Health Information and Quality Authority The (HIQA) is the independent Authority established to drive continuous improvement in Ireland

More information

Code of Ethics for Pharmacists and Pharmacy Technicians

Code of Ethics for Pharmacists and Pharmacy Technicians Code of Ethics for Pharmacists and Pharmacy Technicians About this document Registration as a pharmacist or pharmacy technician carries obligations as well as privileges. It requires you to: develop and

More information

How to revalidate with the NMC Requirements for renewing your registration

How to revalidate with the NMC Requirements for renewing your registration How to revalidate with the NMC Requirements for renewing your registration CONTENTS WHAT DOES THIS DOCUMENT DO?...3 WHAT IS REVALIDATION?...5 CHECKLIST OF REQUIREMENTS AND SUPPORTING EVIDENCE... 7 THE

More information

Firm Registration Form

Firm Registration Form Firm Registration Form Firm Registration Form This registration form should be completed by firms who are authorised and regulated by the Financial Conduct Authority. All sections of this form are mandatory.

More information

Insurer audit manual

Insurer audit manual Insurer audit manual Disclaimer This publication may contain work health and safety and workers compensation information. It may include some of your obligations under the various legislations that WorkCover

More information

IDENTITY ASSURANCE PRINCIPLES

IDENTITY ASSURANCE PRINCIPLES IDENTITY ASSURANCE PRINCIPLES PRIVACY AND CONSUMER ADVISORY GROUP (PCAG) V3.1 (for publication) CONTENTS 1. Introduction 3 2. The Context of the Principles 4 3. Definitions 6 4. The Nine Identity Assurance

More information

NATIONAL GUIDELINES FOR THE ACCREDITATION OF NURSING AND MIDWIFERY PROGRAMS LEADING TO REGISTRATION AND ENDORSEMENT IN AUSTRALIA

NATIONAL GUIDELINES FOR THE ACCREDITATION OF NURSING AND MIDWIFERY PROGRAMS LEADING TO REGISTRATION AND ENDORSEMENT IN AUSTRALIA NATIONAL GUIDELINES FOR THE ACCREDITATION OF NURSING AND MIDWIFERY PROGRAMS LEADING TO REGISTRATION AND ENDORSEMENT IN AUSTRALIA NATIONAL GUIDELINES FOR THE ACCREDITATION OF NURSING AND MIDWIFERY PROGRAMS

More information

Continuing Professional Development. FAQs

Continuing Professional Development. FAQs 4 May, 2010. Continuing Professional Development FAQs Q1. What is Continuing Professional Development (CPD)? A. Continuing professional development is the means by which members of the profession maintain,

More information

Submission to the Review of the General Insurance Code of Practice

Submission to the Review of the General Insurance Code of Practice Submission to the Review of the General Insurance Code of Practice 1 July 2009 Mr A.O. Libke Administrative Officer GPO Box 1705 Brisbane QLD 4001 Ph. 07 3229 6663 Email adminoffice@aicla.org Executive

More information

RISK MANAGEMENT AND COMPLIANCE

RISK MANAGEMENT AND COMPLIANCE RISK MANAGEMENT AND COMPLIANCE Contents 1. Risk management system... 2 1.1 Legislation... 2 1.2 Guidance... 3 1.3 Risk management policy... 4 1.4 Risk management process... 4 1.5 Risk register... 8 1.6

More information

PRIVACY POLICY. comply with the Australian Privacy Principles ("APPs"); ensure that we manage your personal information openly and transparently;

PRIVACY POLICY. comply with the Australian Privacy Principles (APPs); ensure that we manage your personal information openly and transparently; PRIVACY POLICY Our Privacy Commitment Glo Light Pty Ltd A.C.N. 099 730 177 trading as "Lighting Partners Australia of 16 Palmer Parade, Cremorne, Victoria 3121, ( LPA ) is committed to managing your personal

More information

Shared EMR Access Administrator (AA) Guide ~ External

Shared EMR Access Administrator (AA) Guide ~ External Shared EMR Access Administrator (AA) Guide ~ External Developed and maintained by: Information Stewardship Office (ISO) Information Sharing Framework Governance Committee (ISF GC) TABLE OF CONTENTS Purpose

More information

AlixPartners, LLP. General Data Protection Statement

AlixPartners, LLP. General Data Protection Statement AlixPartners, LLP General Data Protection Statement GENERAL DATA PROTECTION STATEMENT 1. INTRODUCTION 1.1 AlixPartners, LLP ( AlixPartners ) is committed to fulfilling its obligations under the data protection

More information

Getting ready for ehealth records

Getting ready for ehealth records Getting ready for ehealth records Medicare Local Support May 2012 Version 2 Contents Introduction 3 The ehealth record system 5 What is an ehealth record? 6 Why do we need an ehealth record system? 7 What

More information

Overview of the Impact of the Privacy Reforms on Credit Reporting

Overview of the Impact of the Privacy Reforms on Credit Reporting Overview of the Impact of the Privacy Reforms on Credit Reporting June 2012 Andrew Galvin, Partner 1 OVERVIEW 1.1 Credit Reporting Reform - Background When initially passed, the Privacy Act 1988 essentially

More information

Financial Adviser Regulations Discretionary Investment Management Services and Custody

Financial Adviser Regulations Discretionary Investment Management Services and Custody Financial Adviser Regulations Discretionary Investment Management Services and Custody MBIE-MAKO-6101733 ISBN 978-0-478-41375-5 Crown Copyright First Published July 2013 Corporate Law Labour and Commercial

More information

Should you have any questions please do not hesitate to contact the NIG Broker Support on 0845 600 8408* or by email to brokersupport@nig-uk.

Should you have any questions please do not hesitate to contact the NIG Broker Support on 0845 600 8408* or by email to brokersupport@nig-uk. Dear Broker Principal, RE: Access to the NIG Extranet (including The Hub). U K Insurance Limited, trading as NIG ( NIG/we/us ), has received an application from a member of staff at your organisation (

More information

Community Lifestyle Support Inc.

Community Lifestyle Support Inc. HUMAN SERVICES QUALITY FRAMEWORK STANDARDS - POLICIES DOCUMENT Q:/1 DATE REVEIWED: REFERENCE: GOVERNANCE AND August 2014 MANAGEMENT POLICY AUTHORISATION: STANDARD REFERENCE: NEXT REVIEW DATE: Management

More information

Department of the Premier and Cabinet Circular. PC030 Protective Security Policy Framework

Department of the Premier and Cabinet Circular. PC030 Protective Security Policy Framework Department of the Premier and Cabinet Circular PC030 Protective Security Policy Framework February 2012 PROTECTIVE SECURITY MANAGEMENT FRAMEWORK TABLE OF CONTENTS TABLE OF CONTENTS 2 1. PURPOSE 3 2. SCOPE

More information

GUERNSEY FINANCIAL SERVICES COMMISSION

GUERNSEY FINANCIAL SERVICES COMMISSION GUERNSEY FINANCIAL SERVICES COMMISSION LICENCE APPLICATIONS FOR ENTITIES ACTING IN RESPECT OF QUALIFYING INVESTOR FUNDS OR REGISTERED CLOSED-ENDED INVESTMENT FUNDS GUIDANCE In recent years, the Commission

More information

Trust accounting for law practices under the Legal Profession Act 2007 (Tasmania)

Trust accounting for law practices under the Legal Profession Act 2007 (Tasmania) Trust accounting for law practices under the Legal Profession Act 2007 (Tasmania) Part 1: About this seminar paper The purpose of this seminar paper is to summarise the key legislative changes to the handling

More information

Improving the ACT Building Regulatory System

Improving the ACT Building Regulatory System Improving the ACT Building Regulatory System Schedule of individual reform proposals Proposal Consultation responses Response Act/Regulation Design and Documentation 1.1 Minimum Design Documentation Guidelines

More information

005ASubmission to the Serious Data Breach Notification Consultation

005ASubmission to the Serious Data Breach Notification Consultation 005ASubmission to the Serious Data Breach Notification Consultation (Consultation closes 4 March 2016 please send electronic submissions to privacy.consultation@ag.gov.au) Your details Name/organisation

More information

Australian Charities and Not-for-profits Commission: Regulatory Approach Statement

Australian Charities and Not-for-profits Commission: Regulatory Approach Statement Australian Charities and Not-for-profits Commission: Regulatory Approach Statement This statement sets out the regulatory approach of the Australian Charities and Not-for-profits Commission (ACNC). It

More information

3. Structuring your company in the UK

3. Structuring your company in the UK 3. Structuring your company in the UK 3.1 Making sure the law is on your side The legal framework governing company registration in the UK The primary legislation governing the incorporation and registration

More information

Achieve. Performance objectives

Achieve. Performance objectives Achieve Performance objectives Performance objectives are benchmarks of effective performance that describe the types of work activities students and affiliates will be involved in as trainee accountants.

More information

GUIDEILINE FOR MONITORING STAFF COMPUTER USE

GUIDEILINE FOR MONITORING STAFF COMPUTER USE GUIDEILINE FOR MONITORING STAFF COMPUTER USE TRUST REF: B41/2007 APPROVED BY: Policy and Guideline Committee VERSION NUMBER: 1 DATE OF APPROVAL: 12 th November 2007 AUTHOR: DIRECTORATE: REVIEW DATE: Gareth

More information

INTRODUCTION 1. Janet(UK) agrees to provide to the Customer the JVCRS subject to these Terms.

INTRODUCTION 1. Janet(UK) agrees to provide to the Customer the JVCRS subject to these Terms. Terms and Conditions for use of the Janet Videoconferencing Recording Service ( Terms ) Reference: CONREF/LA/xxxx INTRODUCTION 1. Janet(UK) agrees to provide to the Customer the JVCRS subject to these

More information

Domestic and Family Violence Protection and Another Act Amendment Bill 2015

Domestic and Family Violence Protection and Another Act Amendment Bill 2015 Domestic and Family Violence Protection and Another Act Amendment Bill 2015 Explanatory Notes Short title The short title of the Bill is the Domestic and Family Violence Protection and Another Act Amendment

More information

2 We guarantee that concerns raised in line with the procedure detailed below will be handled sensitively and in confidence.

2 We guarantee that concerns raised in line with the procedure detailed below will be handled sensitively and in confidence. Whistleblowing (Public interest disclosure) Policy Introduction 1 The NMC is committed to an environment of openness, transparency and accountability. In doing so we would expect and encourage anyone who

More information

Pacific Smiles Group Privacy Policy

Pacific Smiles Group Privacy Policy Pacific Smiles Group Privacy Policy Pacific Smiles Group Limited and its related bodies corporate (PSG, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in

More information

DATA PROTECTION POLICY

DATA PROTECTION POLICY DATA PROTECTION POLICY Approval date: June 2014 Approved by: Board Responsible Manager: Executive Director of Resources Next Review June 2016 Data Protection Policy 1. Introduction Data Protection Policy

More information

DESIGNING AN EMISSIONS STANDARD FOR AUSTRALIA

DESIGNING AN EMISSIONS STANDARD FOR AUSTRALIA 55 DESIGNING AN EMISSIONS STANDARD FOR AUSTRALIA 5 The Authority proposes a standard that would apply from 2018 and be designed with a simple set of features to promote environmental effectiveness, policy

More information

Implementation of the EU payment accounts directive: Consultation response

Implementation of the EU payment accounts directive: Consultation response Implementation of the EU payment accounts directive: Consultation response November 2015 Implementation of the EU payment accounts directive: Consultation response November 2015 Crown copyright 2015 This

More information

Symantec Enterprise Vault Information Management and Compliance Factsheets

Symantec Enterprise Vault Information Management and Compliance Factsheets Australian businesses rely upon efficient timely settlement and a costly and longwinded information management practices to legal process. improve productivity and profit. Businesses that do not appropriately

More information