Healthcare identifiers and consumer privacy protection:

In its submission to the Senate Community Affairs Legislation Committee, PIAC argues that the Healthcare Identifiers Bill 2010 (Cth) (the Bill) provides insufficient detail and certainty around core elements of the proposed Healthcare Identifiers Service to be passed by the Federal Parliament. In particular, PIAC notes its concern that the Bill has been developed outside the framework of reforms to health privacy rights and procedures under the Privacy Act 1988 (Cth) and fails to properly recognise and protect the right to privacy of healthcare recipients particularly through failing to impose strong information security requirements and failing to hold the service operator liable for breaches of privacy. PIAC also raises concerns about the range of matters to be dealt with through regulations, including matters at the core of the Healthcare Identifiers Service. PIAC also considers the provisions of the Bill in detail and provides comment on a range of amendments to clarify, strengthen and improve the Bill.

This submission follows the earlier PIAC response to the Exposure Draft Healthcare Identifiers Bill 2010 and PIAC notes that some of its concerns have been addressed by the Federal Department of Health and Ageing following its consultation on the Exposure Draft.