+ How can I be assured that Primary Health Insights is compliant with legislation and is safe and trustworthy?

Primary Health Insights has its own Data Governance Framework which ensures the storage and use of data on the platform is secure and complies with all national and state privacy legislation as well as the data sharing agreements executed between individual general practices and their PHNs.

Privacy Impact Assessments are completed for all data sets when they are uploaded to a PHN’s secure lockbox and into a collaboration zone. These Assessments are based on guidance provided by the Office of the Australian Information Commissioner.

The platform is subject to annual cyber security reviews and independent penetration tests to ensure security and privacy is maintained and the technology configuration is up to date with respect to the latest threats and risks.

+ What happens if there is a data breach?

A notifiable data breach process is in place which meets the requirements of the Office of the Australian Information Commissioner (OAIC) and the Notifiable Data Breach (NDB) legislation.

+ Will the same data extraction products still be used to extract practice data from my clinical information system (CIS)?

Primary Health Insights imposes no requirement to change data extraction tools, which remain the individual choice of each PHN. The design of the platform includes compatibility with existing data extraction tools.

+ What general practice data will be stored on Primary Health Insights?

Participation in, and use of, Primary Health Insights is voluntary for PHNs. Whilst PHNs determine their individual data storage requirements, it is anticipated that all participating PHNs will use Primary Health Insights to store data extracted for the purpose of PIP QI. Any additional general practice data stored on Primary Health Insights will be governed by the Data Sharing Agreements in place between PHNs and their participating general practices.

While PHNs have agreements with Primary Health Insights for the use of data, the data sharing relationship for a general practice is governed by the terms and conditions of the data sharing agreement it has with its PHN. Your data sharing agreement should cover:

what data is collected from the practice
what data extraction tool / method is used to extract data from the practice
PHN use of the general practice data e.g. for population health planning
third party use or access to data e.g. data sharing for research or planning, who the data may be shared with
data governance arrangements for the PHN management of general practice data
procedures for termination of data sharing e.g. what happens to collected data in the event of withdrawal from data sharing, or closure of the PHN
other requirements or obligations specific to the PHN

Primary Health Insights has been established to ensure the terms of the individual PHNs’ Data Sharing Agreements are not contravened by its operations. Anything specified in your current data sharing agreement will not be changed by the transition to data storage using Primary Health Insights unless agreed to by your PHN and amended accordingly in revised data sharing agreements with its participating practices. Your Data Sharing Agreement is the document that governs what you share with the PHN and how that data can be used. Please refer to this document first if you have any concerns about data sharing.

+ Does this storage arrangement mean that my data is shared or compared with other general practices?

No. The arrangements for sharing data within your PHN, or for its use in comparative reports, is governed by the terms of the Data Sharing Agreement between you and the PHN. The use of Primary Health Insights as the data storage method for your PHN does not change or contravene any existing data sharing arrangements. At the present time, data is not used to identify “high” or “low” performing practices, including PIP QI data, which does not calculate payments based on the achievement of performance targets.

The Agreement made with the Australian Institute of Health and Welfare (AIHW)to participate in Primary Health Insights does not provide AIHW with access to any data held by a PHN, including data shared by general practices, stored in Primary Health Insights or otherwise.

Any data sharing between PHNs and the AIHW within the platform may only occur in line with agreements that define which data sets are to be shared and for what purposes, and which in turn comply with the Data Sharing Agreements held by PHNs with the general practices in their area.

Data shared by PHNs with the AIHW cannot be used, or allowed to be used, for any performance benchmarking or financial audit undertaken by a Commonwealth or State government agency or any other funding body. The sharing and use of your practice’s data remains subject to the terms of your current data sharing agreements held with your PHN and does not change because PHN or another organisation does or does not use Primary Health Insights.

+ Will de-identified general practice data be shared within the broader Primary Health Network for improved health planning?

Possibly, if in compliance with the Data Sharing Agreements in place between the practice and PHN.

PHNs will determine which data can be shared with other PHNs to form larger regional, state or national data sets for the purposes of gaining deeper insights and unlocking previously unseen trends and correlation based on:

Data Sharing Agreements in place with data providers
the Data Set Privacy Impact Assessment toolset which helps determine whether they should share de-identified data and what controls must be in place
all PHNs participating in data sharing arrangement will have visibility of the Impact Assessment.

+ I understand how my PHN currently uses my data, but will Primary Health Insights make my data accessible to other third parties?

As part of the PIP QI technical specifications, data extracted for the purpose of PIP QI compliance will be shared with the Australian Institute of Health and Welfare (AIHW). The Primary Health Insights platform enables this transfer to happen in a highly secure and encrypted way. Primary Health Insights is also intended to provide PHNs with the capability to securely share de-identified general practice data to support improved health planning with approved government organisations (i.e. AIHW). What data is shared, and how it is shared, is the responsibility of the individual PHN, and will require compliance with existing Data Sharing Agreements between each PHN and its participating practices, as well as the use of the Data Set Privacy Impact Assessment toolset. Any additional sharing of data with a third party will be governed by the Data Sharing Agreement between each PHN and its participating practices.

+ Is my data now stored in Primary Health Insights?

The extent of data storage is determined by each PHN. It is anticipated that all participating PHNs will use Primary Health Insights to store data extracted for the purpose of PIP QI. If amendments to your data sharing agreement are required to ensure ongoing compliance once Primary Health Insights is used as their data storage platform, these amendments will be made prior to completing data migration to Primary Health Insights. Please contact your PHN for information specific to your practice.

+ What happens if we do not want our practice data stored on Primary Health Insights?

If your practice has a data sharing agreement with your PHN, and your PHN decides to utilise Primary Health Insights to store its data, then it is likely that your general practice data will be stored on Primary Health Insights. However, this arrangement is governed by the terms of the data sharing agreement your practice has with its PHN. If you object to having your data stored on Primary Health Insights, you should address this with your PHN to determine exactly what data is collected and stored on the platform, and whether there are any other storage methods available via the PHN.

+ Do I need to inform my patients about the data migration, or about where data is stored?

It is up to each practice to determine what information is provided to patients in relation to data use, sharing and storage. However, practices accredited against the RACGP Standards for general practices (5th ed) must have a privacy policy that outlines how the practice manages confidentiality and patient health information (Criterion C6.3). This should include explanations of how and why the practice collects, stores, uses, protects, and discloses personal health information, and guidelines for disclosure of patients’ health information to a third party (which would include the PHN, and consequently Primary Health Insights). It may be sufficient to include information about the sharing of data with the PHN, and methods for patients to opt-out, should they have concerns. Your PHN may be able to provide you with resources or patient education material (such a flyers) to explain the benefits of data sharing to your patients and the methods your practice uses to keep its patients’ health information safe.

+ What happens if a patient doesn’t want data shared with Primary Health Insights?

Methods for patients to opt out of data sharing are controlled at the practice level. If your practice uses a commercial data extraction tool (such as Primary Sense, Pen CS or POLAR), it will have functions to omit non-consenting patients. If you use another method of data extraction, you must ensure it has a way for patients to opt out of having their data shared, should they not provide consent to do so.

Practices that are concerned about whether patient opt-out will affect their PIP QI payments should refer their queries to Services Australia at pip@humanservices.gov.au or 1800 222 032 or refer to the PIP QI Guidance documents. Neither Primary Health Insights or PHNs administer the Practice Incentives Program and are therefore not able to provide you with information relating to your practice’s eligibility or participation.

+ Who operates the Primary Health Insights Platform? Is it Government or a private entity?

Primary Health Insights operates under an unincorporated joint venture involving Primary Health Networks. Participation is voluntary. The development of Primary Health Insights was funded by the Australian Government, operations and enhancements are funded by the particpating PHNs. The platform is operated by WA Primary Health Alliance (consisting of three Primary Health Networks: Perth North, Perth South, and Country WA).

+ Is there any financial benefit for anyone (including general practices) in the use of Primary Health Insights?

No. The collection and storage of data by Primary Health Insights does not provide any direct financial benefit to any of the parties involved.

Data stored in Primary Health Insights may contribute to broader secondary financial benefits. An example of this would be Practice Incentives Program Quality Improvement incentive payments to practices, for which one obligation is the sharing of data (and this data will be stored on Primary Health Insights for participating PHNs).

The vision for Primary Health Insights is to assist PHNs in building a better primary health system, including strengthening the understanding of population health and the responsiveness to health needs of general practice. This could lead to improved financial outcomes for general practices.

+ Do GP reports look different from Primary Health Insights? How do they compare to the analytic reports supplied from my data extraction products?

Primary Health Insights will provide PHNs with greater data analysis, and reporting tools and capabilities, which they can use to work with practices to continually enhance and improve their service offering in terms of analytics. Some reports may look different to those you currently receive. Please contact your PHN for further information.

+ How will Primary Health Insights protect the data of small populations?

Primary Health Insights and the PHNs are committed to protecting consumers’ health data in accordance with Australian Privacy Principles and the Privacy Act 1988 (Cth) and state-based legislation. All PHNs have published Privacy Statements.

For communities with small populations, sometimes served by one general practice, there is a risk of patients being re-identified. Primary Health Insights provides guidance to PHNs regarding additional governance and technical procedures for this data including:

specific risk and privacy impact assessments
detailed data sharing agreements between the general practices in small communities and their PHNs
appropriate data suppression algorithms to maintain consumer anonymity.

+ When will the Australian Institute of Health and Welfare's (AIHW) participation in Primary Health Insights commence?

The Agreement with the AIHW has been signed and the establishment of a separate and individually secure lock box for their use will be established. Onboarding processes, including a data governance audit, is expected to be completed before the end of the year.

+ Will the AIHW have access to general practice data?

Many general practices share a significant level of de-identified data with their PHNs. The Agreement made with the AIHW to participate in Primary Health Insights does not provide AIHW with access to any data held by a PHN, including data shared by general practices, stored in Primary Health Insights or otherwise.

+ Do I need to change the way I submit my PIP QI data? Will this change in the future?

No, you do not need to make any changes to the way you submit your data for PIP QI. If this process should change in the future, you will be notified and supported to make any necessary changes to your systems and procedures.

Your current data sharing agreements do not need to change because of the AIHW’s participation in the Primary Health Insights platform.

+ Where can I find information about the PHNs’ National Data Governance Framework?

Information about this can be found here

+ What benefits can I expect for my practice from the AIHW’s participation in PHI?

The AIHW brings over 30 years of experience and expertise in statistical analyses and data science, data development and management, data standards, social science, data linkage, epidemiology, people-centred data and more. Its participation in Primary Health Insights will enable processing improvements that enhance data quality and comparability as well as assisting in the development of advanced analytics capabilities, enabling PHNs to provide greater insights to general practices about their local population’s health.

Frequently Asked Questions