Senate Community Affairs Committees

REPORT ON ACCESS TO MEDICAL RECORDS

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CHAPTER 2 - IMPETUS FOR REFORM ACCESS TO MEDICAL RECORDS

Impetus for legislation: Implications of the Breen v Williams High Court Decision, 1996

2.1 The High Court of Australia has confirmed that the common law is currently the only binding law applying to medical records held in the private sector and does not place any obligation on the holder of the medical record to make that record available to a patient. [1] The Court clearly stated that medical records were the sole property of the doctor and that they held all rights associated with ownership. The Court's decision confirms that patients in the private health sector suffer from a legal disadvantage. Patients whose records are created and reside in the private health care sector do not enjoy the same rights as patients whose records reside in the public health sector.

2.2 Consumers of government-funded and/or public health care services in Australia have rights of access to their medical records under Freedom of Information legislation (FOI). [2] The objective of FOI is to give the right of access to information held in the pubic record and the only excuse for not complying with this legal obligation is that an agency holding such information bears the onus of proving that a document is exempt. [3] Under certain State regulations governing private hospitals, day procedure centres and nursing homes, access to medical records is also ensured. [4] Consumers who are treated in publicly funded hospitals, community health centres, clinics, receive publicly funded psychiatric services, or whose medical records are held by government agencies, are able to request access to their medical records under FOI. Medical practitioners in the public system prepare their medical records in the knowledge that a patient can obtain access under FOI and many doctors' practices already bridge both the private and public sectors. [5]

2.3 Exemptions to access are, nevertheless, applied in the public health sector on two main grounds. Consumers may be refused access to their medical records held in publicly funded institutions or agencies if it is believed that it would be detrimental to the `mental or physical health' of the consumer, [6] or if giving access would `involve unreasonable disclosure of information concerning the personal affairs of any person', or may place the community at risk. [7]

2.4 In recent years, with the exception of South Australia and Northern Territory, Health Complaints Commissioners have been appointed in States and Territories to cover both the public and private sector. [8] Each Commission operates under statutory guidelines which encourage `reasonable access' to information in health records, except where prohibited by law or where the information is in personal notes of the health service provider. In its report, Whose Health Records, the Public Interest Advocacy Centre (PIAC), pointed out that there is no consensus on what constitutes `reasonable access'. [9]

2.5 In the private health sector, patients requiring access to their medical records for any purpose must rely upon the cooperation of medical practitioners (and other health service providers) to provide such access. Viewed from a patient's need for information, access to a medical record may simply involve initially sighting the record and obtaining a verbal and/or written explanation about the contents of record. Other patients may require full copies of the record.

2.6 The Australian Medical Association (AMA) has issued guidelines in 1993 in relation to patient access to medical records. The AMA encourages its members to `inform' patients about the contents of their medical records. It should be noted that approximately 50 per cent of registered medical practitioners are members of the AMA, thus the AMA's voluntary guidelines cover only half of the registered medical profession. In its submission the Committee was advised that the AMA:

2.7 The AMA guidelines state:

2.8 The Royal Australian College of General Practitioners (RACGP) `encourages medical practitioners to provide patients with a health summary containing accurate and objective health information including test results'. [12] Access to medical records in the private health sector is always at the discretion of the medical practitioner concerned, and, if access is refused, patients may request assistance and advice from the relevant Health Complaints Commissioner or State Ombudsman.

2.9 The High Court's decision removes any ambiguity surrounding the issue of ownership of private sector medical records and confirms that records remain the intellectual property of the medical practitioner who has written them. In order to obtain access to a personal medical record, if consent to access is refused after all other avenues have been explored (such as utilising a Health Complaints Commissioner), a patient may then resort to civil action. Legal proceedings are commenced by issuing a writ to permit the process of `orders of discovery' to proceed after which documents may be subpoenaed. [13] The necessity to resort to legal proceedings inevitably places at risk any relationship of trust which may have been established between patient and doctor.

2.10 In the context of a review of the adversarial system of litigation, the Australian Law Reform Commission (ALRC) has noted its concerns relating to the `damaging effect' of legal proceedings. The ALRC notes that features of the `adversarial system have been criticised as contributing to (among other things) excessive costs and delays, overservicing, lack of accountability and an unduly confrontational approach to dealing with disputes'. [14] The ALRC advised that they had already received a number of submissions to their inquiry dealing with the problems of discovery in litigation. In particular, submissions have referred to `the enormous public cost in what is admitted by most people to be a crisis-laden litigation system for people having to institute a claim in order to find out whether they should be in the courts at all'. [15]

2.11 Patients in the private health system, denied access to their medical records and forced to resort to litigation, are thus confronted with all the steps involved in the legal discovery process. FOI legislation which is not available to patients in the private health care system, is generally assumed to be a safeguard and a means of access to medical records for patients in the public health system. The Mental Health Legal Centre (MHLC) made the point that even for those people whose records are subject to FOI legislation, `the very real concern [is] that the power to refuse to provide records will be exercised in a way which denies any real provision of information can be a strong deterrent'. [16]

2.12 Evidence submitted to the Committee suggests that FOI is limited when exemptions are claimed. [17] MHLC asserted that people with psychiatric disabilities who have received or receive treatment in the public health sector, have also been denied access to their medical records on the basis that disclosure might be `prejudicial to the physical or mental health or well-being of the person', a refusal which is `exercised widely'. [18] The exercise of exemptions may result in litigation and exemptions may also be exercised in a way which actively discriminates against one group of patients.

2.13 MLHC referred to the growing practice of mixing public and private health sector medicine and the referral of patients to the private health sector who, by the nature of such referrals, become effectively `disqualified' from access to medical records under FOI:

2.14 In the Breen v Williams appeal, the High Court was not asked to adjudicate on FOI. What some evidence given to the Committee strongly suggests, however, is that people using psychiatric services often face particular difficulty in gaining access to their medical records, [20] a point affirmed in PIAC's report, Whose Health Records. [21]

2.15 MHLC is a Victorian-based organisation and its clients' adverse experiences may reflect practice in Victoria. The Chair of the NSW Privacy Committee commented in evidence that there had been `no problem and no difficulty' in access to records for psychiatric patients within the public health system in NSW. There are clearly differences in access experienced from State to State. Federal legislation would remove these differences under one nationally observed regime.

2.16 The High Court in the Breen v Williams judgment called for a legislative response. However, in the continuing legal hiatus, the ability of private health sector patients to gain access to their medical records has not been positively assisted. Evidence taken by the Committee suggests that while representatives of peak medical associations agree in principle with the concept and general practice of providing patients with explanations and health summaries, patients' access to their medical records will continue to be impeded while medical practitioners utilise the common law and the assertion of copyright and intellectual property rights.

2.17 The AMA referred to copyright in its submission, stating:

2.18 The Committee is aware that the issue of copyright is complex in relation to an individual's ability to gain access to their medical records. The Committee does not accept that medical practitioners and other health providers should make use of the mechanisms afforded by copyright to deny access to medical records. It may be necessary to exempt medical and other health records specifically from the Copyright Act to remove any interpretive ambiguities in relation to a legislative access to medical records scheme.

2.19 The Committee recognises that any extension of privacy legislation into the private health sector will require detailed consideration to prevent any inconsistency between the access principles of the Privacy Act so far as access to personal information is concerned, and the Copyright Act. [23]

2.20 In pursuing the right of access to medical records for patients in the private health care sector, Health Complaints Commissioners have taken the issue of copyright into account but have rejected its application to medical records. The ACT Commissioner for Health Complaints (ACTCHC), argued that it was `highly unlikely that the intention of Parliament in creating legislation to protect copyright in literary works had in mind the protection of the health records of doctors'. [24] The issue has not impeded the impetus for reform and the ACTCHC has prepared a Government Position Paper on forthcoming legislation which will protect the privacy of personal health records and permit access to personal health records in both the public and private health sectors in Australian Capital Territory.

 

The Australian Constitution

2.21 Although health policy and the provision of health care is now a major activity of the Commonwealth Government, the Australian Constitution does not incorporate `health' explicitly into its provisions for legislative powers. The Commonwealth thus has limited constitutional power over many health services. The powers of the Parliament to make laws for the Commonwealth are set out in Section 51 of the Constitution. The power over certain welfare matters are set out in Part 23A which refers to:

2.22 It is beyond the scope of the inquiry's specific reference and this report to deal in detail with any constitutional problems inherent in establishing a federal scheme providing patient access to medical records. The Commonwealth has a limited power to regulate matters that are incidental to a subject listed in s 51. One constitutional expert has argued that:

2.23 There are a number of alternative ways that legislation could be drafted. The absence of an explicit legislative power has not prevented experts from commenting upon the means of creating a single scheme for health or access to medical records, which may draw authority or validity from many different Commonwealth heads of power. [26] Senator Neal's amendment which proposed a scheme linked exclusively to Medicare payments and agreements between health providers and the Health Insurance Commission, has a number of limitations. However, it demonstrated one legislative model scheme for patient access to medical records which might be achieved under Commonwealth powers.

2.24 The Commonwealth could, for example, seek to extend its privacy legislation to the private health sector by using a range of constitutional heads of power, including the corporations power, social services power and the external affairs power. [27] The Government has said after promising to do so during the election, that it will not seek to extend Privacy legislation into the private sector on the grounds of reducing regulatory burdens and compliance costs. [28]

2.25 This unexpected announcement surprised many who had made submissions to the Committee, especially those who had taken into account the Government's Discussion Paper `Privacy Protection in the Private Sector', produced by the Attorney-General's Department and released in September 1996. [29] From the majority of submissions received, the Committee was aware that the preferred legislative option was to secure privacy and access to medical records by means of extending Commonwealth Privacy legislation on a national basis, for application to individuals and organisations, incorporated or not, which would automatically cover the private health sector. The definition of the scope of the intended privacy regime was set out in the Government's Discussion Paper. [30]

2.26 Other legislative solutions put forward include: (a) a separate Act along the lines of the United Kingdom legislation (Access to Health Records Act 1990); (b) extension of existing privacy legislation along the lines of the New Zealand model (Health Information Privacy Code 1994); (c) extension of existing freedom of information legislation (Freedom of Information Act 1982); (d) a Commonwealth-State and Territory cooperative scheme; and, (e) a model based on Commonwealth credit reporting legislation.

2.27 From submissions received, it is evident that people want access to their medical records made a right not a privilege and demand clear and comprehensive legislation stating those rights. [31] Consideration of the issues regarding the appropriate Constitutional head of power under which a Bill might be pursued should result in a serious consideration of the means of enacting legislation which makes access to medical and health records a real right.

 

State and Territory initiatives

2.28 The anomalous situation which patients in the private health system have found themselves has given rise to a number of initiatives in the States and Territories. As noted earlier, Health Care Complaints Commissioners have been appointed in all States and Territories with the exception of South Australia and Northern Territory. [32] Patients, as consumers of health services, have increased expectations of what the medical profession can achieve, and expect to have the same rights of access to their medical records whether they receive treatment in the public or private health sector. Many patients have been surprised to discover that they do not have any legal right of access to their medical records in the private health sector.

2.29 Consumer advocacy groups have played a significant role in advancing changes in attitudes towards patients' rights of access to their medical records. Many medical practitioners have responded positively to consumer demand for better communication about individual health records and procedures, and professional medical organisations have instituted voluntary codes of practice to encourage medical practitioners to share information with patients.

2.30 The recognised requirement for informed consent to treatment has also had a direct bearing on this new era of cooperation. [33] PIAC's report, Whose Health Records, refers to court decisions over the past ten years in Australia which have made the medical professions `more accountable and led to greater recognition of consumer rights'. PIAC cites the High Court's judgment in 1992 in Rogers v Whitaker for a doctor's obligation to `provide a consumer with sufficient information to allow them to give informed consent to treatment'. [34] Such landmark decisions have in many ways changed the doctor-patient relationship, although provision of access to medical records in private general and specialist medical practice has remained legally unresolved.

2.31 The AMA, the peak medical association, and the Royal Australian College of General Practitioners (RACGP), [35] have produced guidelines setting out standards and codes of practice for dealing with patients. The National Health and Medical Research Council (NHMRC), the prime funding body for Australian health and medical research, has also produced a Guideline for Medical Practitioners on Providing Information to Patients in 1993. [36] The RACGP has recently produced an Interim Code of Practice for Computerised Medical Records in General Practice, of particular relevance to the issue of privacy of records when they are being used and shared electronically. The Interim Code includes a section dealing with patient access to medical records. This states: `Patients should be permitted to have access to their medical record upon request. The only exception should be where access is likely to cause serious harm or distress to the patient'. [37]

2.32 The RACGP informed the Committee that the matter of access to records was one of communication between doctor and patient and one of education:

2.33 Members of the RACGP responded to this issue in a recent survey conducted by the RACGP. Their survey canvassed a range of issues including patient access to medical records. 76 per cent of respondents indicated that they agreed that legislation which presently does not allow patients to have access to their medical records should not be changed. [39]

2.34 Medical practitioners therefore may state the principle that access to medical records and privacy of medical records is one simply of communication, education and cooperation. In practice, fears of possible litigation as well as strongly-held views on medical records being the sole property of the medical practitioner, often prevents patients gaining automatic access to their records.

2.35 Professor Deborah Saltman, Professor of General Practice, confirmed that many doctors fear `the potential liabilities of disclosing their records'. In evidence, Professor Saltman stated, from the results of extensive research conducted in Australia, that there is `a strong desire by all aspects of the community for access to medical information'. [40] This view was reiterated by the Australian Federation of AIDS Organisations (AFAO), not only in relation to access but also to improved health outcomes. AFAO stated that overseas research indicates that `the more active a role a person has in determining the course of their health care, the better health outcomes can be expected'. [41]

2.36 This desire for information is, however, often countered by doctors' fears of legal action. Professor Saltman supported legislation that would ensure a right of access of records and clarify the position on ownership of records. [42]

2.37 The final report of the Professional Indemnity Review (PIR) also noted that doctors feared litigation. PIR pointed to doctors' fears that patients might `lose confidence in the health care system and the advice of health care professionals' if patients were more aware of the `unknowns and risks' which might be revealed in medical and health records. [43]

2.38 The PIR report observed that such fears were often unfounded and that lack of access was often the cause of litigation:

2.39 Certain initiatives have already been taken to create a legislative right of access to medical records in the States. New South Wales has regulations covering records held in private hospitals, day procedure centres and nursing homes. Consumers in NSW now have similar rights to access and to amend their records as those available to consumers in public health services under FOI. While this particular extension of legislative rights is welcome, patients of private medical practitioners do not enjoy these rights.

2.40 New South Wales established a Health Care Complaints Commission (HCCC) in 1994 to receive, investigate and prosecute complaints arising out of the delivery of health services in New South Wales. [45] The HCCC also has a conciliation role. The HCCC was established under the Health Care Complaints Act 1993 (NSW) as an independent statutory body reporting directly to the Health Minister and a parliamentary committee established under the Act. In its first Annual Report, the Commissioner's Foreword noted that `access to, and ownership of, medical records will continue to be an issue supported by high profile legal cases and legislative reform in other States and Territories'. [46] In 1995-96, the HCCC received 37 complaints about records, representing 4.5 per cent of complaints received against doctors. [47]

2.41 Victoria's Health Services Commission (VHSC) was established in 1988 to `receive, investigate and resolve complaints about the manner in which health services have been provided, the failure of a provider to give a health service and the provision of a service unreasonably'. The Commission's Guiding Principles are set out in the Preamble to the Victorian Health Services (Conciliation and Review) Act 1987. The VHSC's submission noted that:

2.42 The VHSC reported that it currently handled 7000 enquiries about health matters per year. Of the 7000 enquiries, 2000 become formal complaints requiring some intervention by HSC officers, and 200 of these, that is, 10 per cent, are about the rights of health service users to have adequate information about their treatment options and to see their personal records. [49]

2.43 The ACT Government has begun the process of developing its own privacy and access to medical records legislation through the office of the ACT's Commissioner for Health Complaints. The ACT Government has had a long-standing interest in ensuring that the privacy of the health records of health consumers is adequately protected and that health care consumers have access to them. It is proposed that forthcoming legislation will:

2.44 The ACT Government is moving towards legislation which will establish a set of privacy principles which are consistent with the eleven principles already enacted in section 14 of the Commonwealth's Privacy Act. The ACT Health Care Complaints Commissioner reiterated the spirit and intention of the ACT's proposed legislation:

2.45 This move was consistent with the Commonwealth Attorney-General's announcement made in September 1996, that the Commonwealth government intended to seek the extension of the Privacy Act to the private sector to the full extent of the Commonwealth's constitutional power.

2.46 Since that time, however, the Commonwealth has announced its intention that privacy legislation would not extend to the private sector. The Prime Minister expressed concerns regarding proposals by the States and Territories to implement a privacy regime for the private sector at the Premiers Conference held in March 1997. An appeal was made to Premiers and Chief Ministers `not to introduce legislation on this matter within their own jurisdictions'. The States and Territories were offered instead the services of the Federal Privacy Commissioner `to assist business in the development of voluntary codes of conduct and to meet privacy standards'. [52] The Commonwealth Minister for Health, Dr Wooldridge, suggested later in a press interview that Commonwealth action in relation to medical records would be limited to a `voluntary code'. [53]

2.47 The ACT Government has taken into account the Government's reversal but will continue with its own legislative program while continuing discussions on voluntary codes with the Commonwealth. The ACTCHC rationale is set out in the ACT Government's Position Paper:

2.48 The Committee noted that the ACTCHC had examined other models of legislation related to access to medical records, in particular the UK and New Zealand legislation, to produce a workable and comprehensive model for the ACT. National consistency was a primary aim of the ACT's legislation:

2.49 The Committee was presented with evidence on voluntary codes in relation to access to medical records and the issue is discussed in greater detail in Chapter 5. Here it is sufficient to note that the AMA has now opted for a voluntary code and a cooperative approach to access rights to medical records. In its submission, however, the AMA noted that in 1995 its Federal Council considered and discussed patient access to medical records and endorsed the provision of legislation. A formal AMA resolution read as follows:

2.50 The day-to-day experience of Health Care Complaints Commissioners, supported by statistics suggests, however, that voluntary codes are not a fail safe mechanism and provide no guarantees of access. The ACT Commissioner for Health Complaints made the following observation:

 

International legislative measures

2.51 Evidence provided to the Committee indicated that legislative measures overseas had provided models for the proposed Australian Capital Territory legislation on access to medical records. Ms Fiona Tito, consultant to the ACT Health Complaints Commissioner, indicated that both the United Kingdom's Access to Health Records Act 1990, and the New Zealand Health Information Privacy Code 1994 had been carefully considered in relation to proposed legislation (see Paragraph 2.43 above).

2.52 Canada has relied upon the common law right of access after the Canadian Supreme Court decided in 1992 that a patient is entitled to reasonable access to see and copy their doctor's records. [58] Significantly, the High Court of Australia rejected the fiduciary argument put forward in the Canadian case of McInerney and McDonald in its interpretation of Australian common law in the case of Breen v Williams.

2.53 Many state governments in the United States of America had introduced separate legislation governing consumers' access to `part of their medical record' in the 1980s. According to PIAC's report, `by 1995, 50 States had a law on the subject, some covering only hospital records or doctors' records and some specifically excluding mental health records'. The US Senate passed the Medical Records Confidentiality Act in 1995 which provides consumers with a national right of access and a right to seek amendment to their medical records. [59]

2.54 The UK legislation, the Access to Health Records Act 1990, came into effect in November 1991 as a result of a decision of the European Court of Human Rights which held that refusal to allow access by the applicant to certain health records was in breach of Article 8 of the European Convention for the Protection of Human Rights and Fundamental Freedoms 1950. The UK legislation defines a health record as one which:

2.55 The UK legislation extends to health records made or held in both public and private sectors and covers registered medical practitioners, registered dentists, registered opticians, registered pharmaceutical chemists, registered nurses, midwives and health visitors, registered chiropodists, dietitians, occupational therapists, orthoptists and physiotherapists, clinical psychologists, child psychotherapists and speech therapists, art and music therapists employed by a health service body, and a scientist employed by a health service body as a head of department. [61] Reviews of decisions to refuse access to a health record is by application to a court. [62]

2.56 New Zealand's Privacy Act 1993 provides for codes of practice to be issued by the Privacy Commission to regulate information practices of particular agencies and sectors. The Health Information Privacy Code 1994, applies specifically in the health sector to ensure the protection of individual privacy.

2.57 The Health Information Privacy Code has twelve Rules. Rule 1: Purpose of collection of information; Rule 2: source of health information; Rule 3: collection of health information from individual; Rule 4: manner of collection of health information; Rule 5: storage and security of health information; Rule 6 access to personal health information; Rule 7: correction of health information; Rule 8: Accuracy etc., of health information to be checked before use; Rule 9: retention of health information; Rule 10: limits on use of health information; Rule 11: limits on disclosure of health information; Rule 12: unique identifiers.

2.58 Rule 6 of the Code provides individuals, or their representatives, to a right of access to personal health information, providing that information is held in a way that is readily retrievable. The individual concerned is entitled:

2.59 Prior to the Government's announcement not to extend privacy legislation into the private sector, the Commonwealth Attorney-General had proposed that legislation similar to the New Zealand model would be enacted to protect records containing personal information held within the private sector. The Attorney-General's Discussion Paper referred to the application of the statutory Information Privacy Principles (IPPs). [64]

 

Commonwealth/State cooperative agreements

2.60 One of the perceived stalling points preventing national access legislation which would ensure equal access to medical records in the public and private health sectors, has been the Commonwealth's apparent lack of constitutional power to legislate directly over health matters. Senator Neal's amendment attempted to utilise the Medicare system as a positive means of ensuring access to medical records by extending Medicare provider agreements. Under the proposed scheme, providers would have been required, `to allow access to medical records that the provider holds about an individual if an application is made in writing for that access'. [65]

2.61 The Commonwealth has achieved national uniformity in legislation in a number of key areas. Corporations law, Trade Practices law (specifically restrictive trade practices in connection with National Competition policy), and Occupational Health and Safety law provide working examples of Commonwealth/State cooperation resulting from either application laws as above, or referral powers passed from the States to the Commonwealth under s. 51 ( 37) of the Australian Constitution.

2.62 An example of a Commonwealth/State cooperative arrangement operating under the Corporations Law is the Australian Securities Commission (ASC) which is an independent body providing a central registry and Regional Commissioners. The ASC, among its listed commissions, administers national scheme laws `effectively but with a minimum of procedural requirements', and ensures that `documents, and information is available as soon as possible for access by the public'. [66] This working arrangement provides a feasible model which could be adapted for an access scheme in Australia.

2.63 The States and Territories acting in concert and with the encouragement of the Commonwealth have enacted uniform consumer credit laws, including a Consumer Credit Code. Queensland enacted template legislation which was then applied by the other States and Territories. [67]

2.64 Section 51 (37) of the Australian Constitution covers:

2.65 Dr John McMillan, author of Commonwealth Constitutional Power over Health, states in his study that `periodic attempts or proposals are made in Australia to create joint Commonwealth/State cooperative schemes. That device has been used variously for formulating policies, for administering programs, and for devising model codes'. [68] Referral of State powers makes it possible to extend the scope of Commonwealth power by intergovernmental agreements as opposed to constitutional amendment. [69] Furthermore, in relation to the federal provision of health policy and services, the Commonwealth has a responsibility to ensure that there is equality in service provision. [70] This equality of service should extend to guarantee an individual's right of access to their own medical and health records in the public and private health sectors.

2.66 As noted earlier, constitutional questions should not be used to dismiss or delay the enactment of legislation which guarantees the right of access. Australians should have a right of access which patients and health consumers in other countries, namely the United Kingdom, New Zealand, Canada and the United States of America, can freely exercise without resorting to litigation.

2.67 Without entering into a constitutional debate about `civil conscription', it is possible to design a legislative scheme which will enable the Commonwealth to coordinate State and Territory privacy legislation and consolidate a register of medical and health records system based upon current and past professional registrations in the States and Territories. Such a system would also record storage, transfer of records in, for example, the sale of a medical practice, storage of records retained after the decease of a medical practitioner, and the destruction of record all practical problems associated with records which are discussed further in following chapters.

2.68 What is required is sufficient political will to bring about Commonwealth legislation to provide equal rights for all health consumers to ensure individuals' access to their medical and other health records.

Recommendation 1: The Committee notes the limited constitutional heads of power for the Commonwealth to legislate in this area. Accordingly, the Committee recommends that this legal problem needs to be addressed without delay. Such consideration would identify the most appropriate means of enacting national legislation to make access to medical and other health records a real right.

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FOOTNOTES

[1] High Court of Australia [1995-1996 186 CLR 71].

[2] Freedom of Information Act 1982 (Clth) ss 11, 41; Freedom of Information Act 1989 (NSW) ss 16, 31; Freedom of Information Act 1982 (VIC) ss 13, 33.

[3] Open government: a review of the federal Freedom of Information Act 1982, Australian Law Reform Commission, Report No. 77, p.29.

[4] Private Hospitals Regulation 1996 (NSW), Day Procedures Regulation 1996 (NSW), Nursing Homes Registration 1996 (NSW). The 1996 regulations supersede 1990 regulations of the same title.

[5] Submission No.54, p.9 (DHFS).

[6] FOI Act 1989 (NSW) s31(4); FOI Act (VIC), s16.

[7] For example, confidential communications are protected under Freedom of Information Act 1982 (Clth) s41, and Freedom of Information Act 1989 (NSW) s31 (2) and schedule 1, clause 6; Freedom of Information Act 1982 (VIC) s31.

[8] South Australia has no Health Complaints Commission but the State Ombudsman's Office receives and investigates health-related complaints. The Northern Territory Government has recently approved the establishment of an independent Health Complaints Commissioner to cover the public and private health sectors. The NT Health Complaints Commission will operate under its own legislation and it is anticipated will be in operation from 1 January 1998.

[9] Whose Health Records: Attitudes to consumer access to their health records and the need for law reform, Amanda Cornwall, Public Interest Advocacy Centre (PIAC), October 1996, p.13.

[10] Submission No.34, p.23 (AMA) (emphasis in original).

[11] Point 3, Explanatory Guidelines, Australian Medical Association Guidelines on Patients' Access to Records Concerning Their Medical Treatment, 1993.

[12] Submission No.14, p.2 (RACGP).

[13] Transcript of Evidence, p.20 (ALRC).

[14] Review of the adversarial system of litigation: An introduction to the inquiry, ALRC, 12 September 1996.

[15] Transcript of Evidence, p.20 (ALRC).

[16] Submission No.27, p.1 (MHLC).

[17] Exemptions to access are discussed in more detail in Chapter 6.

[18] Submission No.27, p.1 (MHLC).

[19] ibid.

[20] ibid.

[21] Whose Health Records: Attitudes to consumer access to their health records and the need for law reform, Amanda Cornwall, Public Interest Advocacy Centre (PIAC), October 1996, p.15.

[22] Submission No.34, p.9 (AMA).

[23] Submission No.33, p.20 (ACTCHC).

[24] Submission No.33, p.19 (ACTCHC).

[25] John McMillan, Commonwealth Constitutional Power over Health, Consumers' Health Forum Inc (CHF), c.1992, pp. 23-4. The `two occasions' referred to `pharmaceutical benefits', see British Medical Association v Commonwealth (1949) 79 CLR 201, 204, 274-5, and `hospital and nursing home benefits', see Part V of the National Health Act 1953 (Clth), ibid.

[26] ibid, pp.18-19.

[27] Submission No.33, p.7 (ACTCHC). Refers to Australian Constitution, Section 51 (20), (23A), (29).

[28] Press release, `Privacy Legislation', Prime Minister, 21 March 1997.

[29] Discussion Paper: Privacy Protection in the Private Sector, Attorney-General's Department, September 1996.

[30] ibid, p.5.

[31] Submission No.27, p.1 (MHLC).

[32] See Footnote 8.

[33] See, for example, Gummow J on `informed consent' re: Rogers v Whitaker [1992 175 CLR 479], cited in High Court of Australia, Breen v Williams [1995-1996 186 CLR 71], at 124-5.

[34] Whose Health Records: Attitudes to consumer access to their health records and the need for law reform, Amanda Cornwall, Public Interest Advocacy Centre (PIAC), October 1996, p.12.

[35] See, Paragraphs 2.7 and 2.8 above.

[36] The Guideline for Medical Practitioners on Providing Information to Patients, Commonwealth of Australia, 1993, was produced to assist doctors in obtaining informed consent to treatment from consumers, p.7.

[37] The Royal Australian College of General Practitioners: Interim Code for Computerised Medical Records in General Practice, February 1993, Point 5, p.6. (Additional information).

[38] Transcript of Evidence, p.63 (RACGP) (emphasis added).

[39] RACGP Membership Survey, October-December 1996, p.7. `This survey was sent out a numerically equal sample from each State and the ACT. Members were proportionally sampled in each membership category according to the overall status in that State. Total sample response was 1120, invalid 12, valid sample 1108, valid replies 886, percentage 80%. The high response rate indicates that these results are representative of the whole sample', ibid., p.1, (Aditional Information).

[40] Transcript of Evidence, pp.167-8. Professor Saltman referred to a survey conducted by the General Practice Professorial Unit (University of Sydney) on a random sample of 400 older people in an older population in Sydney. 395 respondents indicated that they wanted access to Medicare information `hospital use, pharmaceutical use and doctor visits', ibid, p.167.

[41] Transcript of Evidence, p.102 (AFAO). Mr Chris Ward, Legal Policy Analyst cited information from the US journal, AIDS Patient Care, December 1992. Also referred to were findings from a study by Katoff, Rabkin and Remein, `A psychological study of long-term survivors of AIDS', ibid., pp.273-74.

[42] Transcript of Evidence, p.170 (Professor Deborah Saltman).

[43] Review of Professional Indemnity Arrangements for Health Care Professionals: Compensation and Professional Indemnity in Health Care, A Final Report, November 1995, Commonwealth Department of Health and Family Services, p.24.

[44] ibid, p.77.

[45] Health Care Complaints Commission, Annual Report 1994-95, p.9.

[46] ibid, p.7.

[47] ibid, p.8.

[48] Submission No.53, p.3 (VHSC).

[49] ibid, pp.2-3.

[50] Health Records - Privacy and Access, An ACT Government Position Paper, Draft, 6 April 1997, Preface, p.iii.

[51] Transcript of Evidence, p.191 (ACTCHC).

[52] Press release, `Privacy Legislation', Prime Minister, 21 March 1997.

[53] Jodie Brough, `Patients to see their private medical files', Sydney Morning Herald, 19 March 1997, p.7.

[54] Health Records: Privacy and Access, ACT Government Position Paper, May 1997, p.18.

[55] Transcript of Evidence, p.195 (ACTCHC).

[56] Submission No.34, p.5 (AMA).

[57] Transcript of Evidence, p.191 (ACTCHC).

[58] McInerney and McDonald (1992) 93 DLR (4th) at 415.

[59] Whose Health Records: Attitudes to consumer access to their health records and the need for law reform, Amanda Cornwall, Public Interest Advocacy Centre (PIAC), October 1996, p.11.

[60] Section 1, Access to Health Records Act 1990 (UK).

[61] ibid, section 2.

[62] ibid, section 8.

[63] Health Information Privacy Code 1994 (NZ), Rule 6 (1) (a) (b), p.18.

[64] Discussion Paper: Privacy Protection in the Private Sector, Attorney-General's Department, September 1996, pp.6-12.

[65] Senator Neal's amendment to the Health Insurance Amendment Bill (No 2) 1996, 19AD (4) Content of Agreement.

[66] From the Australian Securities Commission Act 1989 - s1(2), Australian Securities Commission Annual Report, 1995-96, p.4.

[67] The Uniform Consumer Credit Laws Agreement 1993 of the States and Territories.

[68] John McMillan, Commonwealth Constitutional Power over Health, Consumers' Health Forum Inc (CHF), c. 1992, p.83.

[69] ibid, p.85.

[70] ibid, p.82.