‘my health’ privacy policy
1.0 Introduction
The ‘my health’ app is a method by which you may access your health information from the My Health Record system. The ‘my health’ app allows you to access, download, store and share your health information from your My Health Record. If you are an authorised representative (such as a parent, guardian, or carer) or a nominated representative for another person with a My Health Record, you can access that person’s health information via the ‘my health’ app.
Access to your own and any another person’s My Health Record via the ‘my health’ app’ will be permitted in accordance with the My Health Record privacy policy.
1.1 ‘my health’ app owner
The ‘my health’ app is owned and operated by the Australian Digital Health Agency (the Agency). The Agency is the System Operator of the My Health Record system in accordance with the My Health Records Act 2012 (Cth). The Agency manages your personal information in accordance with the Privacy Act 1988 (Cth) and the Agency privacy policy.
1.2 ‘my health’ app service provider
The ‘my health’ app was developed by the Agency in partnership with a service provider. Chamonix IT Management Consulting (SA) Pty Limited is the Agency’s solution delivery partner for the development and delivery of the ‘my health’ app and manages your personal information in accordance with the Privacy Act and this privacy policy.
2.0 Information needed to use the ‘my health’ app
The first time you log into your My Health Record via the ‘my health’ app, you will need to verify your identity. To do this, you will be transferred to myGov where you will be required to log into myGov using your myGov username and password. The ‘my health’ app does not collect your personal information but will use your personal information within your myGov account.
2.1 Use of COVID-19 related data
The ‘my health’ app allows you to access, download, store and share your COVID-19 related information, such as your COVID-19 digital certificate and any PCR test results uploaded to your My Health Record.
The ‘my health’ app is not a COVID-19 contact tracing and tracking app.
The ‘my health’ app uses the dates of your COVID-19 vaccinations, sourced from the Australian Immunisation Register via My Health Record, to calculate and display the due dates of a subsequent COVID-19 vaccination or booster.
3.0 Security of your personal information in the ‘my health’ app
The Agency is committed to the security of your personal information and has invested significant resources in providing security features in the ‘my health’ app. All transactions made through the ‘my health’ app are made through securely encrypted channels. The security features are described in the My Health Record privacy policy.
3.1 Access to the ‘my health’ app
Access to the ‘my health’ app is controlled through device level authentication either via biometrics or optionally using a 6-digit app Personal Identification Number (PIN) that you control. Your ‘my health’ app PIN you choose should be hard to guess and not shared with others or written down.
If you forget your app PIN, your ‘my health’ app will provide the option to start over and re-link your My Health Record.
3.2 What to do if you think your security has been compromised
If you know or suspect your PIN has been compromised, or if you have any other concerns about the security of your ‘my health’ app, you should change your PIN immediately. Find out how to change your PIN.
If you are concerned about any aspect of the security of your ‘my health’ app, contact us by email to [email protected]
3.3 Accessing the ‘my health’ app outside Australia
The ‘my health’ app functions globally where there is coverage.
3.4 Protection of your device
The ‘my health’ app does not interfere with, disrupt, damage, or access in an unauthorised manner your device, other devices or computers, servers, networks, application programming interfaces (APIs), or services. This includes other apps on your device, any Google or Apple service, or an authorised carrier’s network.
4.0 How your health information is available through the ‘my health’ app
The primary purpose of the ‘my health’ app is to allow you to access, download, store and share health information accessible through your My Health Record or if you are an authorised representative or a nominated representative for another person with a My Health Record, you can access that person’s health information via the ‘my health’ app.
4.1 Accessing your health information
You can use the ‘my health’ app to securely access and view an applicable My Health Record. The health information you access through the ‘my health’ app can be viewed in the app for as long as the app is open. No health information you access will be retained on your device when you log out or close the app unless you have selected to download that information. An internet connection is necessary for the ‘my health’ app to access your My Health Record.
4.2 Downloading your health information
You can use the ‘my health’ app to download certain documents from an applicable My Health Record to be stored on your device. Items such as proof of vaccination documents and health documents may be downloaded and stored on your device.
Downloaded information is not synchronised with the latest information in your My Health Record. Accessing your health information directly from your My Health Record through your ‘my health’ app will provide you with the most up-to-date information.
4.3 Sharing your personal information
The ‘my health’ app allows you to share your health information with other people or organisations directly.
You should only share your health information if you are confident that the recipient needs to access this information and they will manage your information responsibly. You may share information such as proof of vaccination documents and health documents.
The ‘my health’ app does not record the people or organisations with whom you share your information.
4.4 Using the ‘my health’ app to upload your health information
You cannot currently upload health information from the ‘my health’ app to your My Health Record.
5.0 Whose information can I access through the ‘my health’ app?
You can access your own health information from My Health Record through the ‘my health’ app if you have a My Health Record. You may also be able to access the health information on the My Health Records of other people, such as your children and dependants if you are their authorised representative or other people if you are their nominated representative.
5.1 Accessing your health information through the ‘my health’ app
The ‘my health’ app allows you to access your own health information directly from the My Health Record as described above.
5.2 Accessing your child’s or dependant’s record
When a My Health Record is created for a child, one or both parents are usually set up as an authorised representative. If you are an authorised representative in My Health Record for your child or a dependant in the My Health Record, you can access their health information in My Health Record through the ‘my health’ app.
Find out how to become an authorised representative. You will be required to show evidence of your parental responsibility or legal authority to act on behalf of the individual.
5.3 What happens when your child or dependant turns 14?
Once your child turns 14, they can start to manage their own My Health Record. Parents or legal guardians will no longer have access to it.
If your child wants you to have access to their record, they can invite you to be their nominated representative.
5.4 Accessing another person’s health information through the ‘my health’ app
Someone who wants you to have access to their My Health Record can invite you to be their nominated representative in the My Health Record system. They can give you general, restricted, or full access. This access permission will be in place when you view their health information through the ‘my health’ app.
If you cannot access the My Health Record of the person or people you might expect, it might be because that person does not have a My Health Record or they may not have allowed you access as a nominated representative.
You do not require a My Health Record of your own to access the My Health Record of anyone for whom you are a nominated or authorised representative.
6.0 How to allow other people to access your My Health Record
If you want to allow another person to have access to your My Health Record, you can invite them to be a nominated representative in your My Health Record.
Once the process to make another person your nominated representative is completed, it will be reflected in their ‘my health’ app.
6.1 Removal of access for nominated representatives
A person for whom you are the nominated representative may change or cease your access to their My Health Record at any time without providing notice to you. Any change to or cessation of your access to a person’s My Health Record as a nominated representative will be almost immediately reflected in their ‘my health’ app.
If you have invited someone to access your My Health Record as a nominated representative, you can change or remove their access at any time. Any change to or cessation of this access to your My Health Record as a nominated representative will be almost immediately reflected in their ‘my health’ app.
7.0 Using the ‘my health’ app to access and modify your information
7.1 Access to and correction of your information in your My Health Record
Under the Privacy Act you are able to access and seek correction to your personal information held in My Health Record. This is described in the My Health Record privacy policy.
Currently, you cannot modify your health information in My Health Record via the ‘my health’ app.
7.2 Updating your PIN
You can use the account settings screen in your ‘my health’ app to update the PIN used to login to the app.
8.0 Using your information for reporting and analytical purposes
During the onboarding process you will be asked to consent to the ‘my health’ app providing de-identified data about your device, device location, system and application software to the Agency.
The Agency uses this data for reporting, analysis and identifying system improvements. The de-identified data that is collected by the Agency is classified by Google as ‘sensitive user data’. All data is protected using HTTPS in transit using Australian Government-approved cryptographic algorithms.
The sensitive user data collected by the Agency is how long you spend accessing the various screens within the ‘my health’ app, your device’s location, and information about your device’s system and application software which describe the transactions between you and the ‘my health’ app. The Agency uses this information to monitor and improve the ‘my health’ app. It does not share this information with third parties or use this information for any other purpose. This data will be used in accordance with the Terms of Use.
No personal information will be used for reporting and analytical purposes.
The ‘my health’ app does not collect any information when the app is not in use.
Once you consent to the 'my health’ app Terms of Use, the ‘my health’ app collects de-identified, sensitive user data which is sent to a secure environment operated by the Agency. This environment has undergone an Information Security Registered Assessors Program (IRAP) assessment through the Australian Signals Directorate to ‘OFFICIAL: Sensitive’ which exceeds the requirements of the Australian Government Protective Security Policy Framework (PSPF) for handling of de-identified data.
8.1 Use of your data for research and other purposes
De-identified My Heath Record data is used for research and public health purposes. Find out more about sharing your My Health Record data for research, including how to opt out.
8.2 Security of your data
The ‘my health’ app handles and secures your personal and sensitive user data in accordance with modern cryptography. Personal user data means your personally identifiable information. Sensitive user data means how long you spend accessing the various screens within the ‘my health’ app and information about your device, your device’s location, and system and application software which describe the transactions between you and the ‘my health’ app.
The Agency transfers all data with HTTPS using Australian Government-approved cryptographic algorithms in-line with PSPF requirements. The ‘my health’ app is subject to Static Application Security Testing (SAST) as well as independent code review and penetration testing by a CREST approved tester, in accordance with Open Web Application Security Project (OWASP) guidelines.
8.3 Retention and deletion of your data
The Agency uses sensitive user data to monitor and improve functionality of the ‘my health’ app. It does not use personal user data for this purpose.
All data within the Agency environment including backup, retention and destruction is audited in accordance with PSPF requirements and ‘OFFICIAL: Sensitive’ controls defined in the Australian Government Information Security Manual (ISM). The environment and its governing policies and procedures are subject to IRAP certification.
8.4 Sale of ‘my heath app’ data
The Agency does not sell or monetise your ‘my health’ app personal or sensitive user data under any circumstances.
9.0 Required disclosure of your personal information
9.1 Required disclosure of your health information
In limited circumstances, the Agency may be obliged to disclose your health information. These circumstances are described in the My Health Record privacy policy.
In accordance with the My Health Record privacy policy, such a disclosure will only be made to an Australian entity. There is no requirement in Australian privacy law for the disclosure of your personal information stored on your ‘my health’ app to any overseas entity.
10.0 Authorised collection, use and disclosure of your personal information
Your personal information stored on your My Health Record may be disclosed under certain circumstances.
The circumstances include:
- disclosure to you or your authorised representative or nominated representative
- disclosure to another individual or entity with your consent
- disclosure to another individual or entity when the information is related to the purpose for which it was collected, and you would reasonably expect such a disclosure to be made
- when the disclosure is in relation to a Permitted General Situation under the Privacy Act
- when the disclosure is in relation to a Permitted Health Situation under the Privacy Act
- when the disclosure is reasonably necessary for enforcement activities conducted by or on behalf of an enforcement body.
All of these types of disclosures are permitted under the Privacy Act and would usually be made to an Australian entity but may, in unusual circumstances, be made to an overseas entity.
The ‘my health’ app will not disclose your device location or the usage patterns or usage history of your ‘my health’ app to another entity unless required to by law.
11.0 Deletion of the ‘my health’ app
You may delete the ‘my health’ app from your device at any time. There are no costs or penalties associated with the deletion of this app.
Deleting the ‘my health’ app will not affect your My Health Record. If you delete the ‘my health’ app, you will still have access to your My Health Record from your device’s web browser. Your device will not retain any record of interactions between the ‘my health’ app and the My Health Record system.
Any information previously downloaded or shared from your ‘my health’ app prior to deletion will not be recalled or removed if you delete the ‘my health’ app. All downloaded information will remain on the device and all information that was shared will remain with the recipient(s).
11.1 Reinstallation of the ‘my health’ app after deletion
If you delete the ‘my health’ app, you can re-install it at any time either on the same or another device. This will be a new installation as described above and no records of previous usages of the deleted ‘my health’ app will be available.
11.2 Cancelling your My Health Record and how this will affect the ‘my health’ app
If you cancel your My Health Record, there will be no health information of your own for the ‘my health’ app to access. You will, however, still be able to access the health information of people for whom you are an authorised representative or a nominated representative.
12.0 Pseudonyms and anonymity
12.1 Pseudonyms
Usually, you will need to use your correct identification to use the ‘my health’ app. However, if you use My Health Record with a pseudonym, you can use the same pseudonym for the ‘my health’ app.
12.2 Anonymity
The ‘my health’ app cannot be used anonymously.
13.0 Complaints about the ‘my health’ app
If you have a complaint about the way in which the ‘my health’ app has handled your personal information you are encouraged to refer it to the Agency. We take complaints very seriously and will work with you to resolve any complaint.
Alternatively, you may refer your complaint directly to the Office of the Australian Information Commissioner (OAIC).
14.0 Contact details and further information
You can submit questions about the ‘my health’ app or My Health Record via our online form.
You can call the My Health Record help line on 1800 723 471. The help line is available 24 hours, 7 days a week. This is a free call (call charges apply from mobile phones).
If you need an interpreter, please call TIS National on 131 450.
For hearing or speech assistance, contact the National Relay Service or call 1300 555 727.
15.0 Changes to this privacy policy
This privacy policy is regularly reviewed and may be updated periodically. Please review this policy on a regular basis to ensure you are familiar with any changes. The ‘my health’ app will provide an alert on screen to view updates to this policy if and when this occurs.