Inclusive Counselling Collective Privacy Policy 

Current as of: 03/01/2024

Introduction

This privacy policy is to provide information to you, our client, on how your personal information (which includes your progress notes) is collected and used within our practice, and the circumstances in which we may share it with third parties. 

Why and when your consent is necessary 

When you register as a client of our practice, you provide consent for our social workers and practice staff to access and use your personal information so they can provide you with the best possible care. 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 therapeutic and other support services to you. Our main purpose for collecting, using, holding and sharing your personal information is to manage your care. We also use it for directly related business activities, such as NDIS financial claims and payments, practice audits and accreditation, and business processes.

What personal information do we collect? 

The information we will collect about you includes your:

  • names, date of birth, addresses, contact details 

  • personal information including medical history, important life events, social history, family history and risk factors 

  • NDIS number (where available) for identification and claiming purposes 

How do we collect your personal information? 

Our practice may collect your personal information in several different ways.

  1. When you make your first appointment our practice staff will collect your personal and demographic information via our client information form. 

  2. During the course of providing therapeutic and other support services, we may collect further personal information. 

  3. 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. 

  4. 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 care providers, such as specialists, allied health professionals, hospitals, education services and community care services.

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, clinical supervisors, or information technology providers 

  • with other care providers

  • when it is required or authorised by law (e.g. court subpoenas) 

  • when it is necessary to lessen or prevent a serious threat to a client’s life, health or safety or public health or safety, or it is impractical to obtain the client’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 (Child Safety and the Queensland Police Service sometimes require notification)

  • during the course of providing care services, through Splose

Only people who need to access your information will be able to do so. Other than in the course of providing care services or as otherwise described in this policy, our practice will not share personal information with any third party without your consent.

We will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.

Our practice will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying our practice in writing. 

Our practice may use your personal information to improve the quality of the services we offer to our clients through research and analysis of our client data. 

We may provide de-identified data to other organisations to improve mental health outcomes, increase service provision and secure funding via grants. The information is secure, clients cannot be identified, and the information is stored within Australia. You can let our staff know if you do not want your information included. 

How do we store and protect your personal information?

Your personal information may be securely stored at our practice in various forms. These forms include paper and electronic records. 

Our practice stores all personal information securely. Paper records are all stored within a locked cabinet inside a locked room. Electronic records are stored on a secure online system, Splose. Splose created daily backups of data, encrypts it and stores it securely off-site. Splose is compliant with all relevant Australian Privacy legislation and requirements and uses industry-standard AES-256 encryption. 

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 may request access to their medical records. We require you to put this request in writing and our practice will respond within 30 business days. 

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 to your care worker.  

How can you lodge a privacy-related complaint, and how will the complaint be handled at our practice?

We take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. We will then attempt to resolve it in accordance with our resolution procedure. 

Our practice can be contacted via:

You may also contact the OAIC. Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992. 

Privacy and our website 

Our website collects user data including your location, IP address, pages you visit on our website, and what operating system and device you use. This information helps us understand how people interact with our website and what we can do to improve our reach. Our website may contain information or links to other websites and service providers. We do not take responsibility for your use and engagement with these third parties. Please note the inclusion of third-party service information does not mean that we are endorsed by, or are endorsing, these parties. We take no responsibility for your privacy when accessing third party websites and services.