When used in this Policy, “personal information” has the meaning given in the Privacy Act. Generally, it means any information or an opinion that could be used to identify you. “Sensitive information” is personal information that includes information or an opinion about, for example, your health, criminal record, sexual orientation, religious or philosophical beliefs, and racial or ethnic origin.

At all times, we try only to collect the personal information we need for the particular function or activity we are carrying out. When you enquire about our services, we may collect your full name, date of birth, email address, phone number, and other personal information, including sensitive information, to help us assess whether we are an appropriate service for you and send you information or resources. We collect additional personal information about you, including sensitive information, when you book an appointment and during the course of treatment, for example, your address, emergency contact person, government-related identifiers such as Medicare or DVA numbers, social and medical history. We may also collect your bank account details and details of third parties involved in the management or funding of your appointments, for the purposes of administering your appointments payment arrangements.

We may collect personal information about you if you are a healthcare professional or healthcare service provider who have referred a client to us or who are providing services to a client of ours, such as your name, medical speciality or position within the organisation your work for, your Medicare provider number if applicable, your contact details.

We may collect personal information about you if you interact with us on a commercial basis, for example, service providers and contractors to Mind Health, or as a member of the public. The kind of personal information we collect will depend on the capacity in which you are dealing with Mind Health. Generally, it would include your name, your contact details, details and information regarding our interactions and transactions with you and details such as professional registration numbers, insurance certificates, among others.

Mind Health will, where practicable, collect information directly from you. We collect your personal information mainly when you deal with us over the phone, have contact with us in person, give or send us a letter or document or when you interact with us online via our website (such as www.mindhealth.com.au), email, SMS, and social media channels (please note that social media channels will handle your personal information for their own purposes and have their own Privacy Policy). We may also collect personal information about you, including sensitive information, indirectly from other sources such as your GP or other healthcare professionals, government agencies administering your entitlements and benefits, a carer, a legal professional or a person responsible for your healthcare decisions. If you want to share information that includes another person’s information in which that person will be identifiable, you must seek permission from the individual and let them know about our Privacy Policy.

Mind Health collects and holds your personal information in electronic form. We hold your personal information securely on servers and computer systems. Some information may be collected in paper-based documents which may be converted to electronic form and the original paper copy destroyed in a secure manner when we no longer need it. Personal information retained in paper-based documents is stored in our secure archive facilities in Sydney, NSW. We are legally required to hold clients’ personal information for a minimum of 7 years from the date of last entry in your record or if you are a minor until you attain or would have attained 25 years of age.

Your personal information is maintained in a secure environment, which can be accessed only by authorised personnel. We take reasonable steps to protect the security of the personal information we hold, by:

• ensuring physical security over our paper and electronic data stores, such as locks and security systems, is maintained and enhanced where possible
• maintaining security systems, for example, by using a firewall, using passcodes to control access to electronic devices, and using two-factor authentication when available to access electronic systems
• taking reasonable steps to destroy or de-identify your personal information once we no longer need it
• conducting regular privacy and data security audits to assess whether we have adequately complied with and implemented these measures.

However, no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully secure. Additionally, we are unable to ensure the security of personal information that is left with you or provided to you, for example, a paper-based report or email sent to you.

We collect your personal information to carry out functions or activities such as:

• assessing whether we are an appropriate service for you
• providing you with psychological services such as assessing, diagnosing, and treating psychological issues or preparing reports
• sending you communications via SMS or email to, for example, remind you about your future appointments, provide you with treatment resources and questionnaires and send you a copy of your invoices
• enabling you to receive the correct entitlements to benefits and funding for our services from third-party payers and to comply with their requirements
• responding to your enquiries, requests or feedback
• updating our records and keeping your information up to date.

Providing accurate and complete information is important for the safety, quality and effectiveness of the services we provide. If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you with the services you are seeking. If you have any concerns about the personal information we have asked you to provide please let us know.

There are circumstances where we may be permitted or required by law to disclose your personal information to third parties. Common situations in which we may disclose your personal information to third parties are when:

• you have consented to the disclosure; or
• we reasonably believe that disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety; or
• you would reasonably expect your personal information to be disclosed and disclosure to that third party is for a purpose directly related to the primary purpose for which your personal information was collected (see Why we collect your personal information), for example, to a GP or medical specialist involved in your care, a hospital for higher levels of care, the ambulance service, government agencies and other third-party payers administering subsidies and benefits to which you may be entitled such as Medicare and Department of Veterans Affairs; or
• it is required or authorised by or under an Australian law or a court/tribunal order.

If you are attending or have attended couples counselling sessions and we receive a subpoena or legal request for the information we hold about the person you attended with, the information released may contain information about both, the person you attended with and you.

We may use and disclose some of your personal information to Mind Health’ staff for a range of administrative, management and operational purposes, for example, to manage your appointments, administer billing and rebates. We may also use and disclose your personal information to psychologists at our practice, other than your treating psychologist, to provide you with psychological services if, for example, your treating psychologist is unavailable or away for an extended period.

We may use and disclose personal information to trusted third parties we engage to perform functions on our behalf, for example, to provide professional services, software services, IT and data security services. Your personal information will not be used, sold, rented or disclosed for any other purpose. Where we have collected a government related identifier, such as your Medicare or DVA number, we will not adopt that identifier as our own identifier and we will only use or disclose that identifier as required or permitted by law.

Some of the information collected by Mind Health may be stored in systems that utilise data hosting facilities outside of Australia.

Our website, www.mindhealth.com.au, is hosted in Australia. Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States and possibly other locations outside of Australia. Google Analytics does not identify individual users or associate individual IP addresses with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and patterns of usage by users on our website, to help us improve our website and its content. By using our website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy https://policies.google.com/privacy. You can opt-out of Google Analytics if you disable or refuse cookies, disable JavaScript, or use the opt-out service provided by Google.

Our website may contain links to third-party websites and links to YouTube and Vimeo videos. Mind Health is not responsible for the content or privacy practices employed by websites that are linked from our website. You can access their Privacy Policy on their respective websites.

You can ask for access or correction of your personal information, if you believe it to be inaccurate, in writing and we must respond within 30 days. We may ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible.

Access to your personal information may be declined in accordance with privacy laws, for example, where giving you access would put you or another person at risk of harm. In this circumstance, we must notify you in writing setting out the reasons. If you are a client, access to personal information may only be provided to you by arranging an appointment to discuss the information with the psychologist responsible for your file. These appointments are billed at the current private sessional rates and payable by you at the time of the appointment. We do not provide copies of any file information without a court subpoena as clinical records contain sensitive information relevant to your treatment and may be harmful if read without a psychologist present to explain the information appropriately. Where a person requesting access to your personal information is an authorised representative of yours, such as a lawyer or guardian, we will ask the representative to provide evidence of their authority. We may also ask you to provide current and informed consent to us before releasing your personal information. 

We take reasonable steps to ensure that the personal information we hold about you is accurate, up-to-date and complete. If you believe it to be incorrect or out of date you can ask that we correct it. If it is not possible for us to correct it, you can ask us to associate with it, for example, attach or link a statement that you believe the information is incorrect and why. If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.

You may contact Mind Health at any time if you have any questions or concerns about our Privacy Policy or how your personal information has been handled. If you have a complaint about how we have handled your personal information, please contact us in writing. We will tell you promptly that we have received your complaint and then investigate and respond to the complaint within 30 days. We will determine what (if any) steps we should take to resolve the complaint. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

In the event of any unauthorised access or unauthorised disclosure or loss of your personal information that is likely to result in serious harm to you or other individuals, we will investigate and notify you and the Office of the Australian Information Commissioner in accordance with the Privacy Act.

We will update our Privacy Policy when our information handling practices change. Any information we hold about you will be governed by our current Privacy Policy. We recommend that you periodically review our Privacy Policy for any changes. The current version of our Privacy Policy is available at www.mindhealth.com.au/privacy.  

Queries, complaints, requests for access or correction should be made in writing and sent to:

By post:
Privacy Officer
Mind Health Associates P/L
Suite 1, Level 3, 20 Wentworth Street, PARRAMATTA NSW 2150

By email:
info@mindhealth.com.au