The submission expresses PIAC’s serious concerns about the policy process referred to in the paper. They are:
- That there has been a failure to release completed Privacy Impact Statements (PIAs) commissioned by the National e-health Transition Authority (NEHTA). Without the PIAs, PIAC and other organisations and individuals cannot appropriately respond to the contents of the discussion paper.
- That the proposed national legislative framework for health privacy could be deferred until after the ‘Health Identifier Service’ is in place (governance issues).
- The status of Part B of the Discussion Paper.
The submission also addresses other major concerns arising from the content of the discussion paper. These are:
- The proposal allows for use or disclosure of sensitive information, including health information, when there is ‘threat to an individual’s welfare’. PIAC considers that such a broad and vague exception to accepted privacy principles has the potential to totally undermine consumer confidence in the maintenance of confidentiality in e-health and other health records.
- Under the proposals, an individual will not be able to get Medicare benefits without using a verified IHI.
In the submission, PIAC urgently requests a response indicating when those PIAs will be made publicly available and that the time for public response to the Discussion Paper be extended to allow consumer and community groups to digest the findings of the PIAs and then provide informed responses to the very considerable changes in the way health care operates in Australia that are proposed in the discussion paper.