Why the line between systems matters
The Privacy Act covers every organisation that provides a health service and holds health information, regardless of turnover.
Under APP 11, you must take reasonable steps to protect that information from misuse, loss and unauthorised access, and destroy or de-identify it when it is no longer needed.
Health service providers are also the sector that reports the most data breaches to the OAIC: 18% of notifications in the first half of 2025.
Most practices have a well-protected clinical system. The exposure usually sits in Microsoft 365: referrals in an unowned shared mailbox, reports saved to a desktop, patient detail in a Teams chat, a former staff member's mailbox that still holds years of correspondence. None of that is a practice management system problem, and none of it is fixed by a better practice management system.