Privacy policy for the handling of personal information

1.     Purpose

This document describes the privacy policy of HAY Clinical Psychology Pty Ltd for the management of your personal information. The psychological service provided is bound by the legal requirements of the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) and the Health Records Act 2001 (Vic), adhering to the Australian Privacy Principles (APPs) and Health Privacy Principles (HPPs) in our handling of personal information. This Privacy Policy outlines how HAY Clinical Psychology (“we”, “our”, or “us”) collect, use, disclose, and protect your information.

2.     Collection of Personal Information

As part of providing a psychological service, HAY Clinical Psychology will need to collect and record personal and health information that is relevant to your current situation. This includes:

·       Personal details such as your name, address and contact phone numbers. Other demographic information, such as date of birth, gender and occupation. Emergency contact numbers.

·       Billing and insurance information such as Medicare details and payment details are also collected.

·       GP and other treating clinician details (if applicable)

·       Information about your Medical and Mental Health history, including medications, developmental history, social and family history, presenting concerns, reported experiences and risk and safety details.

·       A record of what happens during sessions, any psychological tests you complete, and any correspondence made between you and the practice, which may include personal information such as names, address and contact phone numbers.

·       Information received from others, such as your GP, or other healthcare providers.

·       Information provided by you or anyone else relating to your personal or health circumstances.

The personal and health information is retained to document what happens during sessions and enables the psychologist to provide a relevant and informed psychological service. This information and record keeping is a necessary part of the services provided and guides treatment. Billing information is collected to administer your account, process payments, issue invoices and receipts, where relevant, manage Medicare or private health insurance claims.

3.     How your personal information is collected

There are a number of ways your personal information is collected, including when:

•          You provide information directly to your psychologist in your session and in writing such as letters, phone email or SMS.

•          Other health practitioners, such as your GP, provide personal information to HAY Clinical Psychology, through referrals, correspondence and medical reports.

•          We may receive personal information from other individuals or sources, such as lawyers, or family members.

If you have concerns that the information recorded is not correct, please discuss your concerns with HAY Clinical Psychology.

4.     Confidentiality of information and Limits to confidentiality

Personal information gathered by your psychologist will remain confidential except for certain circumstances. In most cases, any sharing of information will only occur with your consent.

There are times when your psychologist may release your information without obtaining your consent such as:

•          When a court requires information by issuing a subpoena, or providing information is otherwise required or authorised by law.

•          When it is required because the psychologist must make a mandatory report on a concern.

•          When the psychologist discloses information because they believe you or someone else is at risk of serious harm.

5.     When Information May be Shared

We may disclose relevant personal or health information to individuals or organisations where you have provided your consent for us to do so. If an external agency requests information about you and indicates that have obtained your consent, the practice may require you to also provide consent directly to us before your information is released.

Where you have been referred under a Mental Health Treatment plan, Medicare regulations state that your referring GP or medical practitioner must receive regular updates from your psychologist to inform about engagement, presenting concerns, treatment, progress and relevant recommendations. If you do not consent to the sharing of information with your referring medical practitioner, please discuss with HAY Clinical Psychology. Declining the sharing of information with your GP or psychiatrist may also affect your ability to claim Medicare rebates. Sometimes, we may also need to contact Medicare.  

Psychologists are required to consult and receive supervision from colleagues and clinical supervisors from time to time. If your information is shared in this context, all care is taken to deidentify your information in such a way that you remain anonymous.

6.     Consequence of not providing personal information

Psychologists are required to keep clear and accurate client records as part of their professional obligations. If you do not wish for your personal information to be collected, we may not be able to provide the psychological service to you. Please discuss any concerns you have with HAY Clinical Psychology.

7.     Data security and Storage

HAY Clinical Psychology takes reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification, or disclosure. Your information is stored securely and accessed only by your psychologist and the authorised staff or providers of the practice, as required, in accordance with the practice’s policies and procedures. 

Client information is predominantly stored in Zanda Health, a secure electronic practice management system that adheres to Australian Privacy laws and is IOS27001 certified. All entries are dated, attributable to the psychologist, and completed as soon as practicable. Adult records are retained for at least 7 years from last contact, in accordance with the Victorian Health Records Act 2001. Secure digital destruction processes in Zanda Health are followed once retention periods expire.

8.     Artificial Intelligence

HAY Clinical Psychology may utilise artificial intelligence (AI)-assisted tools such as NovoNote (by NovoPsych), to assist with clinical documentation and administrative tasks. AI-generated content is reviewed by your psychologist to ensure accuracy and appropriateness before being incorporated into your clinical record. AI tools do not replace clinical judgement or decision-making. 

Where AI technology is used, reasonable steps are taken to protect your personal information and ensure it is handled in accordance with applicable privacy obligations. Your consent will be obtained before using AI-assisted tools. You have a right to decline the use of AI and withdraw your consent at any time.

Where applicable, information regarding the use of these systems and associated privacy considerations is outlined separately in “HAY Clinical Psychology: Use of Artificial Intelligence (AI) Policy” (available upon request).

9.     Third-party Platforms

HAY Clinical Psychology uses trusted third-party service providers to support the delivery and administration of psychological services, including practice management, telehealth, clinical documentation, secure email communication, payment processing and psychometric platforms. These providers may store or process personal information on behalf of this practice, including through infrastructure located overseas, and have their own privacy policies. Reasonable steps are taken to select providers that maintain appropriate privacy and security measures consistent with applicable Australian privacy obligations.

Where appropriate, the practice uses NovoPsych, a secure clinical assessment platform, to administer and score validated psychological questionnaires and outcome measures. Information collected through NovoPsych forms part of your clinical record and is managed in accordance with applicable privacy laws and this Privacy Policy.

10.  Accessing your personal information

You have the right to access and correct your personal information held by HAY Clinical Psychology. Your psychologist may discuss the contents with you and/or give you a copy, subject to the exceptions in the Privacy Act 1988 (Cth).  If your psychologist is satisfied that your personal information is inaccurate, out of date or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected.

There may be some exceptions that impact your ability to access the information, which are outlined in the relevant legislation. 

If you would like to access or correct your information, please discuss it with us or you can request in writing. All written requests for access to information will be responded to in writing within 30 calendar days and an appointment will be made if necessary for clarification purposes. In some cases, there may also be an associated fee.

11.  Data breach policy

In the event that any unauthorised access, disclosure or loss of your personal information occurs HAY Clinical Psychology will activate its data breach plan and take all reasonable steps to minimise any risk of consequential serious harm.

 12.     Duty of Care

During your engagement with HAY Clinical Psychology, information shared through sessions or other communications may at times raise concerns about your safety and wellbeing, or the safety and wellbeing of another person. Where concerns arise, a duty of care may require reasonable steps to be taken to support safety and wellbeing, which may include discussing concerns with you, developing a safety plan, contacting an emergency contact where appropriate, or sharing relevant information with appropriate individuals or services, such as healthcare provider, crisis support services, or emergency services. We will communicate openly with you and let you know if our concerns reach a level where external support needs to be involved. This may occur when we reasonably believe that withholding this information would place you or someone else at serious risk of harm to life, health, or safety.

13.     Website

www.hayclinpsychology.com.au

This website may use cookies and similar technologies to improve website functionality, understand how visitors use the website, and support the delivery of website content. Cookies generally do not identify you personally. Most web browsers allow you to modify the use of cookies through your browser settings. Please note that disabling cookies may affect the functionality and performance of some features of this website. By using our website, you consent to the use of cookies in accordance with this Privacy Policy.

Our website may use Google Analytics to help us understand how visitors use the website and to improve its functionality and user experience. Google Analytics collects aggregated and de-identified usage information and does not identify you personally. 

Personal information collected through the website contact form is used for the purpose of responding to enquiries and facilitating initial contact with the practice. Individuals are asked not to include sensitive personal or health information when submitting an enquiry via the website.

14.     Complaints

If you have a concern about the management of your personal information or the services provided, please discuss this with HAY Clinical Psychology upon first instance.

Ultimately, if you wish to lodge a formal complaint about the use of, disclosure of, or access to, your personal information, you may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992 or Online at https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us

You can also lodge a formal complaint with Australian Health Practitioner Regulation Agency (AHPRA) https://www.ahpra.gov.au

15.     Policy Review

This Privacy Policy is reviewed periodically and may be updated from time to time to reflect changes in our practices, services, technology, legal obligations, or relevant privacy requirements. We reserve the right to amend this Privacy Policy, in whole or in part, where necessary. Any changes will take effect when the updated Privacy Policy is published on the practice’s website. We encourage you to review this Privacy Policy periodically to remain informed about how your information is collected, used, and protected.