References to “Blue Healers Counselling”, “BHC”, “we”, “us” and “our” are references to Oliver de Nicolai trading as Blue Healers Counselling (ABN: 75 694 256 459). References to “you” and “your” are references to any individual about whom we collect personal information. References to “counsellor” are references to any counsellor that is employed by or sub-contracted to Blue Healers Counselling practice at Blue Healers Counselling that provide Counselling services.
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, racial or ethnic origin, and political opinions.
What personal information we collect about you
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 services provided by counsellors, 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 any counselling service provided by Blue Healers Counselling is 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 with a counsellor based at Blue Healers Counselling and during the course of treatment with them, for example, your address, emergency contact person, social and medical history. We may also collect your credit card 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 a counsellor based at Blue Healers Counselling, such as your name, medical speciality or position within the organisation your work for, and 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 Blue Healers Counselling, 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 us. 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.
How we collect your personal information
How we hold your personal information
Your personal information held by Blue Healers Counselling 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.
Why we collect your personal information
We collect your personal information to carry out functions or activities such as:
Providing services and facilities to a counsellor based at Blue Healers Counselling;
Assessing whether a counsellor at Blue Healers Counselling is an appropriate service for you;
Sending you communications via SMS or email to, for example, remind you about appointments with your counsellor, provide you with treatment resources and questionnaires and send you a copy of your invoices;
Responding to your enquiries, requests or feedback; and
Updating your records and keeping your information up to date.
If you have any concerns about the personal information we have asked you to provide please let us know.
Disclosure of your personal information
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 the ambulance service; or
It is required or authorised by or under Australian law or a court/tribunal order.
We engage external service providers to us for the purposes of providing services to your Counsellor and managing our business, including software providers, payment systems operators, IT and data security service providers, website hosting service providers, our insurers, our professional advisors such as accountants, bookkeepers and lawyers. Your personal information may be used and disclosed to them to facilitate these arrangements.
Your personal information will not be used, sold, rented or disclosed for any other purpose. Some of the information collected by Blue Healers Counselling may be stored in systems that utilise data hosting facilities outside of Australia. During the novel Coronavirus outbreak, if you or one of our counsellors based at our practice have tested positive for COVID-19, we may be required to inform local health authorities that you have been in the practice. If required, we will only provide the minimum information necessary and required by the health authorities for contact tracing purposes.
Collecting your personal information through our website.
Our website, www.bluehealerscounselling.com.au is hosted in Australia. Our website uses Google Analytics, a service that 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.
Access to personal information and correction
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. We do not provide copies of information records without a court subpoena if they contain sensitive information that may be harmful if read without a Counsellor 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.
Concerns and complaints about your privacy
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.