Seven Steps to Embed Privacy Into Your Healthcare Operations via Policies and Procedures
We get it. The mention of policies and procedures doesn’t always elicit an enthusiastic response nor an immediate jump of joy. Nevertheless, understanding the ways in which policies and procedures can be leveraged to embed privacy into the modern-day healthcare practice is incredibly important for Australian Health Service Providers. This importance is perhaps even more stressed by the recent changes to the Privacy Act, as introduced by the Privacy and Other Legislation Amendment Bill 2024. This blog therefore highlights some of the key steps that Health Service Providers can take to embed privacy into their healthcare operations via policies and procedures.

Figure 1: Seven steps that organisations of all sizes can take to embed privacy into their operations via policies and procedures.
Seven Steps to Embed Privacy Into Your Healthcare Operations via Policies and Procedures
1) Understanding Your Obligations
Understanding your compliance obligations is the first step. While reading legislation might not be everyone’s idea of fun, the Office of the Australian Information Commissioner (OAIC) offers a wealth of guides and information on their website to help health service providers understand their specific obligations. Health Service Providers must take the time to fully understand what exactly these obligations entail and put a plan together to put these into practice.
2) Creating and Updating a Privacy Policy
Create a privacy policy that clearly outlines how your organisation handles personal information. It’s not enough to set and forget; consistently update the policy to ensure it reflects current practices and legislative requirements.
3) Developing an Organisational Privacy Management Plan
Next, develop a privacy management plan. This plan should outline specific, measurable goals and targets to implement your requirements under the Privacy Act and embed privacy into your operations. This plan is ultimately your road map towards protecting your patient’s data and privacy.
4) Establishing Accountability and Communication
Clear and documented lines of accountability and communication are essential. Define who is responsible for privacy within your organisation and who can be contacted regarding privacy questions or concerns. In smaller organisations, this may be a single person wearing multiple hats. However, in larger organisations this might involve multiple different individuals and departments.
5) Conducting a Data Inventory and Analysis
Once the abovementioned key foundations for your privacy program are established, conduct an inventory and analysis of how your organisation handles personal information. As part of this, it is important to identify the types of data stored, accessed, and transmitted as part of your operations.
6) Developing a Data Breach Response Plan
All health service providers should develop a data breach response plan. This plan, which you hope never to use, is critical in the event of a data breach. It should set out key actions, procedures, and lines of authority in the unfortunate event of a data breach.
7) Privacy and Cybersecurity Training
In addition to these steps, it’s vital to provide ongoing privacy and cybersecurity training for your staff. Regular training sessions can help employees understand the importance of privacy and cybersecurity, recognise potential threats, and know how to respond appropriately.
Conclusion
Embedding privacy within your healthcare operations is achievable. While the abovementioned steps may seem intimidating at first, breaking down each of these items into achievable sub-goals within your privacy management plan will help to create a logical roadmap for implementing these changes. In doing so, you will take the important steps towards enhancing the privacy of your healthcare operations and protecting your patient’s data.
If you find that you need assistance with implementing the above privacy measures, we are here to help! Just Protect offers a comprehensive set of Privacy Advisory services that are tailored towards the unique needs of Australian Health Service providers. What’s even more exciting is that our solutions can be scaled to organisations of all sizes – from sole operators to multi-location entities.
References
- Office of the Australian Information Commissioner, Privacy guidance for organisations and government agencies
- Parliament of Australia, Privacy and Other Legislation Amendment Bill 2024 Explanatory Memorandum
- Office of the Australian Information Commissioner, Australian Privacy Principles
