Privacy Policy

Family Connection Counselling Privacy Policy version 2.0, 16 February 2024.

Our approach to privacy

Family Connection Counselling respects your privacy and is committed to complying with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act“).

To enable ongoing care and total quality improvement within this practice and in keeping with the Privacy Act and the Australian Privacy Principles, we wish to provide sufficient information on how your personal health information may be collected, used, stored, or disclosed by us and record your consent or restrictions to this consent.

In this privacy policy:

  1. “we”, “us”, “this practice”, ‘the practice”, “our”, and “Family Connection Counselling” refer to Family Connection Counselling ABN 86129733834;
  2. “Practitioner” refers to a fully trained counsellor, psychology or counselling student, and other allied health professionals;
  3. “you” or “your” means either:
    1. The person/s receiving individual or family counselling services from this practice;
    2. The Practitioner/s to whom we provide supervising services regarding their health practice independent of this practice; or
    3. The person/s receiving health services that involve disclosing their personal information to the Practitioner/s;
  4. “Website” means our website at familyconnection.net.au; and
  5. capitalised/italicised words are defined below.

We will use your personal health information only for the purposes for which it is collected or as otherwise permitted by law, and we respect your right to determine how your personal health information is used or disclosed.

You can give your consent to our collection, disclosure and usage of your/ the client’s personal health information:

  1. By ticking ‘yes’ to the Privacy Consent section when you complete the ‘online client intake form’ we emailed to you when you made your first or subsequent booking with us for our individual or family counselling services (“Counselling Services“); or
  2. By signing a hard copy of the Client Information & Privacy Collection and Consent Form and emailing it to info@familyconnection.net.au or posting it to us at PO Box 515, South Fremantle WA 6162;
  3. You enter into a formal supervision/feedback arrangement with us to provide professional supervisor service and support of your Practitioner counselling practice (“Practitioner Support Services“).

1. We may collect personal information from you when:

  1. You receive Counselling Services from us;
  2. You use the Website to collect, record, and store your health information in electronic format for later access, retrieval and use on the Website by you and other persons authorised by you;
  3. You are a Practitioner receiving Practitioner Support Services and disclose such information about your client/s to us;
  4. Your Practitioner seeks Practitioner Support Services from us, and the Practitioner has obtained a ‘Client Privacy Consent’ form from you regarding disclosing your personal health information; or
  5. We conduct online or other health surveys we ask you to complete when you have an account with us or otherwise procure services from us.

2. The types of personal information we may collect from you include:

  1. general personal details such as your name, gender, contact number, address, and email address;
  2. demographic information such as your age, gender, and State or Territory residence;
  3. your financial or billing information (such as billing address, bank account, and payment information);
  4. your health information, including psychological and physical health;
  5. information about your medical history, such as prior medical diagnosis and testing, current and previous use of certain medications, and health habits;
  6. only where relevant and with your consent, sensitive information about your health.

3. What methods do we use to collect your information?

We may collect information by several different methods. Examples may include notes and data collected from observations and conversations with you in consultations, medical test results, health fund and health insurance details, and details obtained from other healthcare providers (for example, GP correspondence).

The third-party provider’s privacy policy for the payment processing system to us (STRIPE) is at stripe.com/au/privacy.

4. Why do we collect, use, and disclose your personal health information?

We may use your information to:

  1. Provide the Counselling Services from our practice.
  2. Provide the Practitioner Support Services to other Practitioners, including where personal health information or de-identified information is used.
  3. Administrative purposes in running our practice.
  4. Our billing purposes include compliance with health fund requirements.
  5. Follow-up calls, appointment reminders/recall notices via SMS, letter or email for treatment, result actions, and preventative healthcare.
  6. Disclose to others involved in your health care, including treating doctors and specialists outside this practice (“Health Practitioner“), when you complete a ‘release of information’ form authorising disclosure of your personal health information to that Health Practitioner.
  7. Implement accreditation and quality assurance activities to improve individual and community health care and practice management.
  8. Comply with legal-related disclosure as required by a court of law.
  9. Conduct or participate in research only where de-identified information is used.
  10. Allow Practitioners to participate in medical training/teaching using only de-identified information.
  11. Comply with any legislative or regulatory requirements, e.g. notifiable diseases.
  12. When treatment for your medical condition by a Health Practitioner outside this practice becomes urgent, with your consent implied or expressed.
  13. Distribute ad hoc newsletters via email to share generic health-related information.
  14. For our service providers, agents, and contractors (only on a need-to-know basis) to help us provide our services to you.
  15. Specific third parties authorised by you to receive information held by us.
  16. Other persons, including government agencies, regulatory bodies, and law enforcement agencies, as required or authorised by law.
  17. Comply with applicable laws and other regulatory, accounting, reporting or professional obligations.
  18. Process and respond to your requests, enquiries, or complaints.

We may also use your information to perform analytics (on a de-identified basis) to:

  1. improve our products and services;
  2. market our services to you;
  3. identify and develop new products and services you may be interested in;
  4. conduct, monitor and analyse our business and internal operations;
  5. send you updates, publications, marketing, and new product or service offerings (however, if you do not want to receive marketing emails from us, you can opt out at any time using the contact details below).

5. To whom do we disclose your personal information?

We cannot share your personal health information with any Health Practitioner unless required by law, or it is necessary to prevent a serious threat to life, health or safety, or you consent to the disclosure of the data to an identified Health Practitioner. In this case, the Health Practitioner would contact you to ask permission to see your health information (as per item 4 (f) above).

6. We may also disclose your information to:

  1. Any person you nominate explicitly to share your health information;
  2. Any person who is your parent or guardian for health information purposes;
  3. Specific third parties you authorise to receive information held by us; and
  4. From time to time, our service providers, agents and contractors (on a need-to-know basis only) help provide our services to you.

Some vendors or other parties may receive or store your information overseas. For example, we may disclose your email address or additional contact information to providers of marketing database services, which may store the data in an overseas jurisdiction. Family Connection Counselling does not host or store your personal information outside Australia.

7. How do we store and keep your information secure?

We will hold your personal information in electronic form, encrypted and stored in a cloud-based facility, with practice management software using infrastructure located in Australia (“Data Storage“), which has been classified as appropriate for storage of data up to the “protected” security level.

If you wish to access your records with us, you can send your request by post to PO Box 515, South Fremantle, WA 6162, or by email to info@familyconnection.net.au and provide proof of identity to Family Connection Counselling. We may charge a fee to cover the administrative costs of providing your medical records.

We use various physical and electronic security measures to secure your personal information from misuse, interference, loss, or unauthorised use or disclosure. For example, we restrict physical access to our offices, employ firewalls and secure databases, password protect our IT systems, frequently update our anti-virus software, and conduct regular audits and data integrity checks. Our employees, providers, agents and contractors are also bound to keep your personal information secure and treat it as confidential.

We will protect your health information by taking such security safeguards as are reasonable against loss, unauthorised access, use, modification or disclosure, and against all other misuses. However, we cannot guarantee the security of your personal information in the Data Storage, including your health information. The Internet is not a secure environment. If you use the Internet to send us any information, including from your email address, please be aware that it will be posted at your own risk.

8. Accessing or correcting your personal information

You have rights under the Privacy Act to:

  1. request access to the personal information we hold about you;
  2. ask us to update or correct any information that is inaccurate, misleading, incomplete or outdated; and
  3. opt-out of receiving direct marketing communications from us.

You can also ask us to remove any information irrelevant to the purposes specified in item 4 above.

You can do any of these things by contacting our Support Team using the contact details below.

If you request access to your personal information or ask us to correct or update information about you, as noted in item 7 above, we may need to verify your identity. Sometimes, we may have a valid reason to deny your request to access or correct your information. If we do this, we will tell you why.

9. Making a complaint

If you think we have breached the Privacy Act, or you wish to complain about how we have handled your personal information, you can contact us using the details below. Please include your name, email address, or telephone number and clearly describe your complaint.

Family Connection Counselling’s Support Team will investigate any complaint, and we will communicate the outcome of that investigation to you. (Please allow at least 14 days for us to do so).

Suppose you are not satisfied with the outcome of our internal investigation. In that case, you may complain to the Office of the Australian Information Commissioner (OAIC) at enquiries@oaic.gov.au or 1300 363 992. More information is available on the OAIC’s website at https://www.oaic.gov.au/.

10. Contact us

If you would like more information concerning how we handle your information or our approach to privacy or to exercise any of your rights outlined above, please contact:

Family Connection Counselling Privacy Policy version 2.0, 16 February 2024.