Primary care insights

Information collected and generated by the thousands of users of Telstra Health has the potential to provide valuable information about the health and health care of Australians and can be used to improve the safety, quality and efficiency of care.

The ability to draw insight from large data sets like this complements traditional forms of research, by providing the following benefits:

• An understanding of populations based on many current data points, more accurate and detailed than self-reported behaviour and more efficient to collect
• Better representativeness that comes from large samples
• The ability to discover important correlations and information to support causal studies, without needing to start with a particular hypothesis.

Telstra Health believes it must play a role in addressing the market need for data-based insight and analysis of primary health care data. Awareness of the value of such data held in general practices for public good and for commercial purposes has continued to grow. At the same time, awareness of the need to protect privacy of patients and confidentiality of practices is only increasing.

Data protection and transparency is paramount to Telstra Health. We want to ensure that parties interested in accessing primary healthcare data do so with appropriate consent, with full transparency and with proper data governance protections in place. This is why Telstra Health is offering practices, data contributors and patients with the ability to choose whether to have their relevant data used for the Research Program This framework sits within MedicalDirector's robust data governance model that ensures that external organisations are only provided with de-identified and aggregated outputs.

Creating a facility to access data-based insights and analysis through Telstra Health allows for leadership in new research methodologies while at the same time ensuring data contributors benefit from being part of the initiative and protecting the sensitivity of all information through appropriate de-identification and aggregation.

Data contributors can include any MedicalDirector Clinical user who collects or generates clinical information including general practitioners, specialists, registrars, registered nurses, allied health care practitioners and any other relevant health care professional.

By being part of the Telstra Health aggregated data-based research process you will receive access to certain high-level analysis and insights derived from all the projects that Telstra Health is engaged to conduct in the form of a quarterly report.

Some aspects of the work that is performed may contain information that is commercially sensitive and/or confidential to our project sponsors and therefore will not be accessible to data contributors.

If you would like to talk to the MedicalDirector team about a project you’d be interested in conducting, please send an email to MDResearch@medicaldirector.com.

Telstra Health's approach to data governance is addressed by its Data Code of Conduct and is underpinned by five tenets summarised below:

Trust 

As a central principle, we must uphold the social licence that our customers and the public have granted to us.

Our customers expect that we cause no harm to them, their relationship with their patients (and their communities) or to the general public.

Telstra Health is committed to ensuring that any use of data adheres to the relevant legislative, regulatory and governance requirements, and receives ongoing external legal review from leading practitioners of health information and privacy laws in Australia.

For projects for which ethics approval is desired or required, Telstra Health will contribute to an Ethics Committee submission on behalf of a project sponsor.

Safety 

Telstra Health has adopted the ‘five safes’ framework for managing risk related to use and disclosure of data.

The Research Program is designed to prevent the collection, use or disclosure of identifiable patient level 'personal information' or 'sensitive information' (within the meaning of privacy laws) by Telstra Health and Telstra Health takes steps to address re-identification risk.

Our data-based analysis and insight processes apply the ‘10 and 3 rule’ whereby no single cell of any output will be provided to an external organisation where the underlying data are in respect of 10 or fewer patients, or patients from 3 or fewer medical practices.

In addition, each individual piece of analysis will be reviewed by the research team to further assess and manage for any risk of reidentification in the aggregated output that is provided externally.

Control 

Telstra Health believes strongly in allowing individuals to control access and use of their own health information.

Participation in data-based research by data contributors will require either them, or their practice, to actively choose to do so. Where you are a data contributor, you will be contributing de-identified data with respect to your consultations only, along with de-identified data relating to your patients that are not specific to a particular consultation.

If a data contributor wishes to cease participating in the Research Program then we will act on that request.

[For Telstra Health customers on versions 3.19 and above], you can update your consent settings through the “User” window.

If you are a data contributor, you should inform your patients that:

de-identified data might be collected as a result of their patient consultation;

they have the ability to opt-out from the process;

the de-identified information may (if they have not opted out) be used for research projects that may be made available by Telstra Health to fee paying project sponsors; and

the output of these projects will only ever use aggregated data.

You can assure patients that these projects will never use, and project sponsors will never have access to, their patient information in identified form.

If a patient makes it known to a data contributor that they wish to cease participating in the Research Program (i.e. that they do not wish for their data to continue to be used in the de-identification process), then we will act on that request promptly upon this preference being made known to Telstra Health.

Once the relevant patient record is open, the patient can be opted out through the “Patient” window (alongside consent preferences for My Health Record and PIP QI).

Utility 

Projects, and the external organisations Telstra Health chooses to work with, must satisfy a requirement (determined by Telstra Health) to be aligned with the Telstra Health vision (to realise a connected and improved digital health experience for all) and purpose (to improve lives through digitally-enabled care for our community).

Telstra Health will not enter into an agreement with an external organisation which permits that external organisation to use aggregated data-based research to re-identify data and then individually target a patient.

Data and analysis provided to our clients or partners is subject to use strictly for the purposes outlined in our agreements with them.

For further information please see “What types of projects will the data be used for?” and “What types of projects will the data NOT be used for?”.

Transparency 

The Telstra Health Privacy Policy is always publicly available.

Telstra Health continues to evolve internal policies to ensure they keep pace and are consistent with community expectations as to the use and management of relevant information.

Telstra Health will, whilst respecting partner and client confidentiality, make some form of output available from projects.

Telstra Health may have a commercial relationship whereby Telstra Health provides de-identified, aggregated data insights to fee paying project sponsors.

You should discuss the following with your patients:

• de-identified data might be collected as a result of their patient consultation;
• they have the ability to opt-out from the process;
• the de-identified information may (if they have not opted out) be used for data-based research projects that may be made available by Telstra Health to fee paying project sponsors; and
• the output of these projects will only ever use aggregated data.

You can assure them that these projects will never use, and project sponsors will never have access to, their patient information in identified form.

Once the relevant patient record is open, the patient can be opted out through the “Patient” window (alongside consent preferences for My Health Record and PIP QI). For practices using older versions of MedicalDirector Clinical, opt-out can be managed via the MD Research widget from the sidebar menu.

If the widget is not installed click on the “Sidebar settings”, click “Check for New/Updated Widgets” in the “New Widgets” window, tick “MD Research” widget, click “Download and Install” when prompted, allow requested permissions and click “Save”. Once the widget installation is complete, the MD Research widget will then be available in the sidebar menu.

Where a patient has opted-out, de-identified data will no longer be collected as a result of their patient consultation for use in Telstra Health data-based research, regardless of which health care professional is treating the patient.

If you are a data contributor, we will deliver a prompt on an annual basis to remind you that you are participating in the Research Program and information on how to opt-out.

Should you change your mind about being a data contributor at any time, you can update your consent settings through the “User” window and unticking the checkbox to "Participate in de-identified MedicalDirector research data collection".

Telstra Health will collect the following examples of de-identified information on behalf of a data contributor and their patients (provided the data was not collected during a consultation with a non-consenting health care practitioner or with respect to a patient that has opted-out):

• Patient demographics
• Behavioural factors such as smoking status
• “Reason for visit”
• Biometric measurements including weight and blood pressure
• Pathology and radiology tests ordered and, in certain instances where decipherable and not containing personal information, results
• For referrals, the type of specialist and the subject and description of referral
• Prescription and vaccination details.

Telstra Health will not collect name, date of birth except month and year, address, IHI, medicare number and phone number.

Access to unstructured data within the product suite is extremely limited and is subject to further consideration on a case-by-case basis. Exceptions may include:

• Extraction of key words and terms within clinical notes where appropriate de-identification techniques are available
• Free-text inputs for reason for visit fields, medication dosage/frequency and pathology/radiology orders
• Other free-text inputs may be considered on a case-by-case basis where appropriate de-identification techniques are available

If you would like to learn more about the specific types of de-identified data collected as part of the Research Program please contact us at MDResearch@medicaldirector.com.

Telstra Health will be guided by our vision (to enable ideal healthcare) and mission (to be the trusted leader in digital health) in choosing which projects to pursue and what external organisations to work with.

Telstra Health will work with both public and private organisations in determining opportunities to pursue as data-based research projects. The types of organisations which Telstra Health may choose to engage with include research bodies, health insurers, government departments, pharmaceutical companies and Primary Health Networks (PHNs). Some de-identified, aggregated data insights may be made available by Telstra Health to fee paying project sponsors. Some projects will be performed on a pro-bono basis by Telstra Health.

All projects, regardless of whether a project sponsor fee is charged by Telstra Health, will be assessed against the Telstra Health vision, mission and the Data Code of Conduct.

For projects for which ethics approval is desired or required, Telstra Health will contribute to an Ethics Committee submission on behalf of a project sponsor.

Should you choose to be a data contributor, you will be asked for feedback on the types of projects that you would like Telstra Health to be involved in, including:

• Uncovering patterns in disease prevalence, including up to date reporting on interaction of primary health care with pandemic incidence
• Enhancing existing Telstra Health products and launching new ones
• Population health statistics
• Social determinants of health outcomes
• Optimising decisions for building healthcare services that best meet demand
• Projects that better target preventive care services to areas in need
• Projects that help to avoid admission of patients to hospitals
• Understanding patterns in treatment behaviour of clinicians across different conditions
• Analysis of post treatment outcome and comparisons to no- treatment or alternative- treatment.

Telstra Health will not be engaged in any project that:

• requires the provision of patient-level data by Telstra Health to an external organisation
• seeks to reidentify any patient for any purpose or has the purpose of directly targeting a single patient outside of the clinical setting
• seeks to reidentify any practice for any purpose or directly targets a single practice or clinician for any reason
• is aimed at producing insight specifically relating to people of Aboriginal and Torres Strait Islander descent
• may have the consequence of causing unjustified harm to any individual
• is not in keeping with our vision (to enable ideal healthcare) and mission (to be the trusted leader in digital health).

Note that the requirements of any government initiative in this area, such as the PIP QI, will be addressed separately to the Telstra Health data-based research capability (although we note that the philosophy for safer data governance practices with respect to data aggregation adopted by this initiative is in keeping with the Department of Health sponsored Doll Martin review outcomes for the PIP QI Eligible Dataset).

Telstra Health may publish reports and share findings with data contributors and the broader community. Any sponsor of a Telstra Health data-based research project that wishes to publish a report about a project will be required to submit the draft report to Telstra Health for its review and approval before publication.

Telstra Health will not work for any organisation that it identifies as deriving primary revenue from selling tobacco, alcohol, gambling products, weapons, fossil fuels or products or services deemed by Telstra Health to be harmful when used as intended. Telstra Health will have discretion to accept or reject any proposed project that is not in keeping with the Telstra Health vision and mission.

All MedicalDirector Clinical customers can export the aggregated Practice Incentive Program Quality Improvement ("PIP QI") Eligible Dataset regardless of whether they decide to participate in the Research Program and without the use of a third party data extraction tool.

To access the aggregated Eligible Dataset, open MedicalDirector Insights, select the “Reporting” menu and then select “PIP QI” from the dropdown list. To export the measures, select “Export to JSON file” from the top right hand corner of the screen. The exported aggregated eligible data set will then appear as a JSON file on your desktop for you to provide to your local PHN.

Submitting your PIP QI measures via MedicalDirector does not require the extraction and sharing of any information other than the aggregated Eligible Dataset and is in keeping with the Telstra Health data-based research data governance framework with respect to the management of reidentification risk.

Regardless of how you choose to submit the Eligible Dataset, you should discuss the PIP QI incentive program with your patients and inform them that de-identified data may be collected as a result of their consultation (if they do not opt-out) and that this de-identified information is provided to the PHN. Patients can be opted-out of the Telstra Health aggregated Eligible Dataset through the “Patient” window (alongside consent preferences for My Health Record and the Research Program).

The data extraction process undertaken in connection with the Research Program does not depend on the use of any other data extraction tools. Telstra Health believes that the vast majority of queries that a third-party organisation may have regarding primary health care can be answered by analysing data within the practice and its practice management software providers, without extracting patient level data to, or via, an external organisation. Telstra Health does not intend to pursue projects that require external organisations to extract or access patient-level data.