Why and when your consent is necessary
When you register as a patient or commercial client of our practice, you provide consent for our therapists, consultants and practice staff to access and use your personal information so they can provide you with the best possible service. Only staff who need to see your personal information will have access to it. If we need to use your information for anything else, we will seek additional consent from you to do this.
Why do we collect, use, hold and share your personal information?
Our practice will need to collect your personal information to provide services to you. Our main purpose for collecting, using, holding and sharing your personal information is to better understand your needs in relation to the products and services that we provide, and facilitate the delivery of services to you. We also use it for directly related business activities, such as financial claims and payments, practice audits and accreditation, and business processes (eg staff training, website optimisation).
What personal information do we collect?
Depending on the services you are seeking, the information we may collect about you includes your:
- names, date of birth, addresses, contact details
- medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors
- personal financial information
- racial or ethnic origin, political, philosophic or religious beliefs and affiliations, sexual orientation or practices, criminal record
Dealing with us anonymously
You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.
How do we collect your personal information?
Our practice may collect your personal information in several different ways.
- When you make your first appointment our therapists, consultants or practice staff will collect your personal and demographic information via your registration.
- During the course of providing therapeutic or consulting services, we may collect further personal information.
- We may also collect your personal information when you visit our website, send us an email or SMS, telephone us, make an online appointment or communicate with us using social media or digital technologies.
- In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:
- your guardian or responsible person
- other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services and pathology and diagnostic imaging services
- Your employer if referred for Clinical Supervision, Executive Coaching or via an Employee Assistance Program
When, why and with whom do we share your personal information?
We sometimes share your personal information:
- with third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with APPs and this policy and we will limit access to only that information required.
- with other healthcare providers
- when it is required or authorised by law (eg court subpoenas)
- when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent
- to assist in locating a missing person
- to establish, exercise or defend an equitable claim
- for the purpose of confidential dispute resolution process
- when there is a statutory requirement to share certain personal information (eg some diseases require mandatory notification)
- when clients are accessing therapy services through an Employee Assistance Program, information provided to the employer is limited to the date, time, duration, cost and name of employee
- when clients are accessing executive coaching services through an employer, unless otherwise disclosed prior to first appointment, information provided to the employer is limited to key themes aggregated across the employee base (such as leadership development, conflict resolution, work/life balance), in addition to date, time, duration and name of employee.
Parents, guardians or persons responsible for a minor, do not automatically have the right to access their information. A person of any age has the absolute right to the privacy of their material. Their consent would be required prior to any disclosures and it would have to be deemed to be in the interest of the child for any disclosures to take place. Ultimately the disclosure of information pertaining to a minor is at the discretion of the counselor/therapist. Equally, the disclosure of information pertaining to any other client, where that client is deemed incapable of judging whether or not disclosure should occur, in their own interest, is at the discretion of the therapist.
Our practice may use your personal information to improve the quality of the services we offer to our patients through research and analysis of our patient data.
Within professional standards and normal professional practices, de-identified information may be presented to a clinical supervisor, or occasionally used to contribute to research within the profession, or as a case history in a training environment, or in professional publications to improve mental health literacy and clinical practice (such as How Two Love and Meaning-fullness). We change identifying details that are not pertinent to the case in such instances so that there is no chance of recognition and, for publications, may further conceal through the amalgamation of more than one case. If de-identification is not possible then the material is not used.
Using key communication platforms such as Microsoft Suite, Google Suite, Apple iCloud, Zoom and the like, means that personal information may be transmitted or stored outside Australia. We only disclose personal information to our overseas service providers when it is necessary for the services they provide to us. Other than through the use of these technologies, we will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.
Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.
Our clinical practice will not use any personal information obtained in the course of you seeking or undertaking health services for marketing any of our goods or services directly to you without your express consent. We may use personal information obtained in the course of you seeking our commercial advisory services (as distinct from clinical services) for marketing any of our goods or services to you. You may opt out of direct marketing at any time by notifying our practice in writing.
How do we store and protect your personal information?
Your personal information may be stored by our practice in various forms including hard copy and electronic records. Our practice stores all personal information securely. Hard copy records are maintained in locked filing cabinets within secured buildings. Electronic records are maintained in secure storage environments with robust password protection. Nevertheless, you should keep in mind that no internet transmission is ever completely secure.
How can you access and correct your personal information at our practice?
You have the right to request access to, and correction of, your personal information.
Our practice acknowledges patients’ rights to access their medical records, with any request for notes to be submitted in writing. Notes collected within a therapy practice may consist of information beyond ‘medical records’ as part of the therapeutic process. For this reason, the ‘medical record’ may be presented in a summary form, representing a medical account of consultations to date. We will do our best to respond in a reasonable time. Fees for complying with this request will be commensurate with the hourly clinical rate of the associated therapist preparing the medical record.
Our practice will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we will ask you to verify that your personal information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing direct to your therapist or consultant, or via email@example.com.
How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?
We take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner. We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia). Generally, the OAIC will require you to give them time to respond before they will investigate:
Office of the Australian Information Commissioner (OAIC)
Complaints must be made in writing
Telephone: 1300 363 992
Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Privacy and our website
How to contact us
Telephone : +61 8 9383 3132
Email : firstname.lastname@example.org
Privacy Officer, Amygdala Consulting Pty Ltd
First Floor, Claremont Medical Centre
206 Stirling Hwy,
Claremont West Australia 6010
Policy review statement