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:
      
        encourages cooperative access to medical records by patients. 
          It does not prohibit doctors from permitting their patients to view 
          records and even copy those records, where the doctor 
          deems it appropriate. [10] 
          
      
2.7 The AMA guidelines state:
      
        Where a doctor agrees to provide information to a patient from 
          the contents of records concerning the patient's medical treatment : 
          
        (a) The patient should be informed of all relevant factual information 
          contained in the record. 
        (b) However, the doctor's opinions and conclusions recorded in 
          the medical record will be released only at the discretion of the doctor 
          concerned. [11] 
          
      
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:
      
        The problem of lack of access in the private sector is compounded 
          by the increasing referral of clients away from public services to the 
          private sector. ... As a group particularly disadvantaged by assumptions 
          about the impact of disclosure, clear legislative rights are the only 
          solution. [19] 
          
      
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:
      
        Ownership of the medical file was not contested in Breen 
          v Williams, nevertheless the High Court did hold that 
          the records were the property of the doctor. The property in the physical 
          documents rested with the doctor, as did copyright in the documents 
          created by the doctor. [22] 
          
      
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:
      
        the provision of maternity allowances, widows' pensions, child 
          endowment, unemployment, pharmaceutical, sickness and hospital benefits, 
          medical and dental services (but no so as to authorise any form of civil 
          conscription), benefits to students and family allowances. 
      
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:
      
        The incidental power has had a very important operation in the 
          health field. The central activity authorised by the health and social 
          welfare power (s 51 23A) is the provision to members of the public of 
          a range of benefits, such as pharmaceutical, hospital and sickness benefits. 
          A mechanism adopted by the Commonwealth for providing those benefits 
          to people is the payment of a patient subsidy to doctors, pharmacists, 
          and nursing homes. Substantial regulation of those professions has been 
          undertaken, as a matter incidental to providing those benefits. This 
          incidental regulation has been approved by the High Court on two occasions. 
          [25] 
      
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:
      
        The college believes the matter of access to records is really 
          one of communication between the patient and the doctor and that most 
          of the problems that arise are from a failure of the process, which 
          we address within the educational program, that we provide for aspiring 
          general practitioners. We believe it is appropriate that patients be 
          given access to the information in their medical record and that it 
          is essential for their health and wellbeing that they fully understand 
          the matters contained within the record, which is the 
          property of the practitioner. The problems that arise 
          are usually those of a failure of communication. We believe it is the 
          communication that needs to be addressed. That really is a matter that 
          the profession is addressing at least in our case through our educational 
          process. [38] 
          
      
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:
      
        In many instances, refusal of access to their medical records 
          is the motivating factor for a health care consumer to pursue a complaint, 
          or bring a tort action, against a health care professional. Combined 
          with the evidence from jurisdictions where there is greater access ... 
          there has not been an increase in complaints or litigation from providing 
          ... access, the PIR determined that improved access was important, both 
          for patient information and autonomy and as a way of minimising the 
          need to resort to legal process to find out what has happened. [44] 
          
      
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:
      
        One of the issues consistently complained about to the HSC is failure 
          to provide access to personal medical records held by a privately treating 
          doctor or a private hospital. [48] 
        
      
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:
      
        ensure that the privacy of the health records of all health care 
          consumers is adequately protected, and they have equal rights of access 
          to their health records, whatever the nature of the health service used. 
          [50] 
      
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:
      
        More than anything else we have tried to ensure that whatever 
          we do is consistent with the Australian Commonwealth Privacy Act because 
          that is the thing we would like to tie in with most. [51] 
          
      
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:
      
        Given the uncertain constitutional position of the health sector 
          so far as the Commonwealth action is concerned, it is considered the 
          ACT legislation would have been necessary whatever the outcome of the 
          Commonwealth's own reform process had been ... the effort to coordinate 
          and assist with national consistency of policy in relation to privacy 
          issues has helped shape the ACT's proposals. [54] 
          
      
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:
      
        We have looked at both pieces of legislation and, while we have 
          not used exactly the same format as the New Zealand one because it is, 
          again, a legislative code from a big piece of privacy legislation with 
          a code underneath just for the health care area, what we have done is 
          try to design a piece of legislation which is actually about patient 
          access to health records, but with underlying privacy principles so 
          that we could have national consistency if we were to go down that route. 
          [55] 
      
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:
      
        Federal Council endorses AMA participation in discussion with 
          the Federal Government on the development of legislation that would 
          allow Australians non-retrospective access to medical records maintained 
          by doctors in private practice. [56] 
          
      
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:
      
        I might make a quick comment in relation to voluntary codes which 
          have been mentioned, because to an extent voluntary codes already exist. 
          The Australian Medical Association has a clear policy in relation to 
          the provision of information in medical records to patients, for example, 
          and I cannot help but notice from my experience that this has not really 
          affected the practice of members of the medical profession. [57] 
          
      
  
      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: 
      
        (a) consists of information relating to the physical or mental 
          health of an individual who can be identified from that information, 
          or from that and other information in possession of the holder of the 
          record; and 
        (b) has been made by or on behalf of a health profession in connection 
          with the care of that individual. [60] 
          
      
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:
      
        (a) to obtain from the agency confirmation of whether or not 
          the agency holds such health information; and 
        (b) to have access to that health information. [63] 
          
      
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:
      
        Matters referred to the Parliament of the Commonwealth by the 
          Parliament or Parliaments of any State or States, but so that the law 
          shall extend only to States by whose parliaments the matter is referred, 
          or which afterwards adopt the law. 
      
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. 
      Navigation: Previous Page | Index | Next Page
       
      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.