1. What is Personal Information?

1.1. ‘Personal information’ is defined in the Act. Essentially, it means information from which your identity is reasonably apparent. This information may include information or an opinion about you (whether true or not) and may also include sensitive information.

1.2. ‘Sensitive information’ is any information about your racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional, or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information. We will not ask you to disclose sensitive information unless it is necessary for providing our services to you. However, if you elect to provide unsolicited sensitive information it may be captured and stored.

2. CLIENT INFORMATION

Client files are held in an electronic document management system or in a secure filing cabinet, which is accessible only to authorised employees or any authorised service provider in accordance with the practice's policies and procedures. The information on each file includes personal information such as name, date of birth, address, contact phone numbers, medical history, payment information and other personal information collected as part of providing the psychological service.

3. HOW CLIENTS’ PERSONAL INFORMATION IS COLLECTED

3.1. A client’s personal information is collected in a number of ways in the course of providing our service, including:

• Hardcopy and electronic forms

• Correspondence through telephone/virtual calls

• Correspondence via email/SMS

• If you contact us in person, through our website (Squarespace) or social media (such as LinkedIn, Instagram and Facebook)

• When the client interacts directly with Full Life Psychology employees, such as the receptionist

• When you apply for a position with us (for example, as an employee, a contractor or a volunteer) or a student placement

• From publicly available sources of information

• When other health practitioners provide personal information to Full Life Psychology via referrals, correspondence and medical reports.

3.2. When you provide your personal information to us, you are confirming that you agree for us to collect, use and disclose your personal information in accordance with this Policy.

However, you can update your privacy preferences at any time by contacting us on 07 5354 6112 or at admin@fulllifepsychology.com.au.

4. CONSEQUENCE OF NOT PROVIDING PERSONAL INFORMATION

If the client does not wish for their personal information to be collected in a way anticipated by this Privacy Policy, Full Life Psychology may not be in a position to provide the psychological service to the client. In some circumstances, clients may request to be anonymous or to use a pseudonym, unless it is impracticable for Full Life Psychology to deal with the client or if Full Life Psychology is required or authorised by law to deal with identified individuals.

5. PURPOSE OF HOLDING PERSONAL INFORMATION

A client’s personal information is gathered and used for the purpose of providing psychological services, which includes assessing, diagnosing and treating a client’s presenting issue. The personal information is retained in order to document what happens during sessions, and enables the psychologist to provide a relevant and informed psychological service.

6. DISCLOSURE OF PERSONAL INFORMATION

6.1. Clients’ personal information will remain confidential except when:

1. It is subpoenaed by a court, or disclosure is otherwise required or authorised by law;

2. Failure to disclose the information would in the reasonable belief of Full Life Psychology place a client or another person at serious risk to life, health or safety; or

3. The client’s prior approval has been obtained to:

a)  provide a written report to another agency or professional, e.g., a GP or a lawyer; or

b)  discuss the material with another person, e.g. a parent, employer, health provider, or third party funder; or

c)  disclose the information in another way; or

d)  disclose to another professional or agency (e.g. your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which your personal information was collected.

6.2. A client's personal information is not disclosed to overseas recipients, unless the client consents or such disclosure is otherwise required by law. Clients' personal information will not be used, sold, rented or disclosed for any other purpose.

6.3. In the event that unauthorised access, disclosure or loss of a client’s personal information occurs, Full Life Psychology will activate its data breach plan and use all reasonable endeavours to minimise any risk of consequential serious harm.

7. THIRD PARTY DISCLOSURE

7.1. Full Life Psychology uses third party providers for services such as payment processing, web hosting, web-based CRM, marketing and communication, IT support, data storage, backup and analysis.  Whilst all reasonable attempts have been made to ensure your personal information is stored on Australia-based servers, some of these parties may capture and store your personal information outside of Australia. These third-party providers include (but are not limited to) Facebook, Google, Halaxy, Instagram, MailChimp, and Medical Objects, and may not be subject to the Australian Privacy Act, but they will have their own privacy policies.

7.2. We will take all reasonable steps to ensure that third parties to whom we disclose your personal information have a compliant Privacy Policy and are committed to protecting your personal information at a standard at least equal to our commitment.

8. WEBSITE

8.1 Our website uses ‘cookies’ to help us improve the user experience, and to help us remember your preferences. You can refuse the use of cookies by selecting the appropriate settings on your browser. However, this may mean you will be unable to fully access our online services.

8.2 We may use Google analytics to monitor our website traffic data and to help us understand our website traffic and webpage usage. Google Analytics does not identify individual user information. You can choose to opt out of Google Analytics if you disable or refuse the cookie.

8.3 Our website may provide links to third party websites for your convenience and information. If you access those links, you will leave the Full Life Psychology website. Full Life Psychology does not control those sites or their privacy practices, which may differ from this Privacy Policy. Full Life Psychology does not endorse or make any representations about third party websites. Personal data you choose to provide to or that is collected by these third parties is not covered by this Privacy Policy. Please review the privacy policy of any organisation before submitting your personal information to it.

9. Storage and security of personal information

9.1. We take all reasonable steps to make sure your personal information is held securely and protected from loss, interference, unauthorised access or misuse. We generally store personal information in electronic databases. Some of these databases may be held on our behalf by third party data storage providers.

9.2. We use physical and technical processes to protect the confidentiality and security of information that we hold. We restrict access to information to staff who need to use the information and our databases and network servers have the appropriate security measures in place. We conduct regular access and security audits to ensure we follow our information and privacy procedures.

9.3. We only keep information for as long as we need it or are required to, and we destroy, return or de-identify thereafter.

9.4. We also follow the Office of the Australian Information Commissioner guidelines around handling any accidental or unauthorised disclosures of personal information (https://www.oaic.gov.au/).

9.5. Except to the extent that statutory liability cannot be excluded, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies any statutory consumer rights under any applicable law, including the Competition and Consumer Act 2010 (C’th).

9.6. When your Personal Information is no longer required for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be kept by us for a minimum of 7 years from your last interaction with us (e.g. appointment), in line with the Queensland Government Health Sector (Clinical Records) Retention and Disposal Schedule.

10. REQUESTS FOR ACCESS AND CORRECTION TO CLIENT INFORMATION

At any stage clients may request to see and correct the personal information about them kept on file. However, to protect your privacy and security, we will also take reasonable steps to verify your identity before granting access to your data. The psychologist may discuss the contents with you and/or give you a copy, subject to the exceptions in the Privacy Act 1988 (Cth). An administration fee may apply. If satisfied that personal information is inaccurate, out of date or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected. All requests by clients for access to or correction of personal information held about them should be lodged with Laura Scherman (Director, Full Life Psychology). These requests will be responded to in writing within 21 days and an appointment will be made if necessary for clarification purposes.

11. CONCERNS

If clients have a concern about the management of their personal information, they may contact Laura Scherman (Director, Full Life Psychology) on (07)5354 6112 or at admin@fulllifepsychology.com.au. Upon request they can obtain a copy of the Australian Privacy Principles, which describe their rights and how their personal information should be handled. Ultimately, if clients wish to lodge a formal complaint about the use of, disclosure of, or access to, their personal information, they may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us or by post to:

Office of the Australian Information Commissioner, GPO Box 5288, Sydney, NSW 2001.

12. CHANGES TO THIS POLICY

We may change this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by publication on our website. The revised version of this Privacy Policy will be effective at the time we post it.

Last updated: December 2023