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Privacy Policy

Head in the Clouds Co. ACN 654 298 441, (“we” “our” or “us”) recognises the importance of your privacy and respects your right to control how your personal information is collected and used.

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We are an APP Entity as defined in the Privacy Act 1988 (Cth) (the “Act”). This privacy policy is aligned with the Australian Privacy Principles as set out in the Act and describes the way that we may collect, hold and disclose personal information.

In this policy:

  • “Personal Information” means any information that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address, and phone number. 

  • “Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious belief or affiliation, philosophical belief, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.

We may update this Privacy Policy from time to time. The most current version will be located on our website, and is also available by contacting our Privacy Officer by email or at the address detailed below.

By engaging us to provide the services to you, you consent to the collection, use and disclosure of your personal and sensitive information as set out in this Privacy Policy. 

 

Types of personal and sensitive information collected 

The information that we collect may include any of the following: 

  • name, address(es) telephone number(s), email address(es) and other contact details; 

  • date of birth; 

  • occupation; 

  • your referring health professional or other referrer; 

  • details about your private health insurance, or your workers compensation claim details; 

  • medical information such as medical reports, referrals, medication, health history and other important health information provided by your referring health professional or collected during a consultation with one of our psychologists; 

  • payment information (such as credit card or bank details); and 

  • other personal or sensitive information required to provide psychological services. 

If you provide us personal or sensitive information of a third party (for example, if you are assisting a child to seek treatment) this information will be kept in accordance with this Privacy Policy. 

 

Use and Disclosure

Personal information collected by us will generally only be used and disclosed for the purpose it was collected.  This includes maintaining your account and contact details, providing you with our services, and processing payments. We may disclose your personal information to third parties or contractors who are integral to the provision of our services.

We may from time to time use personal information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act, including to effectuate or enforce a transaction, and/or procuring advice from legal and accounting firms, auditors and other consultants.

We may provide your health Information to other medical service providers, such as your general practitioner or specialist medical practitioners. We will only supply this information with your consent, or in circumstances where it is required for the delivery of health services, such as referral to another health service provider, billing and liaising with government offices regarding Medicare entitlements and payments, where it is necessary to prevent or lessen a serious threat to life, health or safety, or any other reason as permitted by law. 

 

How we collect personal information 

Generally, we collect personal and sensitive information directly from you, such as when: 

  • you provide us with personal details upon first consulting with us; 

  • one of our psychologists takes a history from you and observes you during a consultation; 

  • you call us on the telephone or via video conferencing with such information or send us an email, fax, note, letter or similar communication; 

  • you send information to us via our website; or 

  • a parent, guardian or carer provides such information to us on your behalf. 

We also collect personal and sensitive information about you when a health professional sends us a referral letter about you or your condition. 

If we collect personal or sensitive information about you from someone else in circumstances where you may not be aware that we have collected such information, where reasonably practicable we will notify you as soon as possible that the collection has occurred and the circumstances of that collection.

 

Why we collect, use and disclose personal information 

We will use the personal and sensitive information we collect as set out in this Privacy Policy. Primarily, that will be to assist our psychologists in consulting and treating you, and to allow us to bill you for our services. Outside of the terms of this Privacy Policy we will not use your personal or sensitive information without first seeking your consent, unless required or compelled to do so by law. 

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We will collect personal information for the following purposes: 

  • to establish and maintain your relationship with us; 

  • to facilitate the provision of psychological services; 

  • to facilitate payment for the services you receive, and to assist you to claim any applicable rebates for those services; 

  • to answer any inquiry you make; and

  • to communicate with you about our services and events.

We may also disclose your personal and sensitive information to third parties who work for or closely with our business to deliver the services you have requested. For example, some of our psychologists may be contractors rather than our direct employees. We will always ensure that these third parties are obliged to keep your personal and sensitive information confidential in the same way that we would. 

 

How we store and protect personal information 

We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access and modification or disclosure. As much as possible, we seek to collect and store the information gathered by the practice in electronic format on servers based in Australia. It is still necessary, however, to have some paper- based files and other records in our practice. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure. 

Additionally, we take reasonable steps to destroy or permanently de-identify personal and sensitive information when we no longer need it. 

Please note that the internet is not a secure method of transmitting information. We cannot and do not accept responsibility for the security of information you send to, or receive from us, over the internet, or for any unauthorised access or use of that information. 

 

Do we send personal information overseas? 

We may transfer your Personal Information (but not your Sensitive Information) to organisations in other countries. Recipients may include our related entities or employees, external service providers such as administration providers or information technology providers.  We only transfer information where we reasonably believe that the recipient is legally or contractually bound to principles that are substantially similar to the Australian Privacy Principles.

 

How you can access your personal information 

We will take reasonable steps to make sure that the personal and sensitive information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact us to update those details. 

At your request, we will provide you, within a reasonable period after your request, with a copy of any Personal and Sensitive Information that we hold about you, unless an exception under the Privacy Act 1988 applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information. We will require you to provide us with some proof of identity before we provide you with a copy of the Personal or Sensitive information we hold. If we believe that we are not able to provide you with access to Personal or Sensitive information, we will give you a notice of our reasons and advise you of the complaint mechanisms that exist under the Privacy Act 1988. 

We will promptly acknowledge and investigate any complaint about the way we manage Personal and sensitive Information. 

 

Changes to this policy

We may change this Privacy Policy from time to time. Any updated versions of this Privacy Policy will be posted on our website. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on our website, or where practical, by emailing clients.

How to contact us or make a complaint 

If you have any questions about this Privacy Policy, if you wish to update information we hold about you, or if you wish to make a complaint about our collection, use or disclosure of your personal and sensitive information under this Privacy Policy, please email us at info@headinthecloudsco.com.au

We will take reasonable steps to remedy any issues that you raise with us resulting from any failure to comply with our privacy obligations.

More information about Australia’s privacy laws and the Australian Privacy Principles is available from the Office of the Australian Information Commissioner at www.oaic.gov.au. If we cannot resolve any privacy issue that you raise with us, you can contact that Office by phone on 1300 363 992, online at http://www.oaic.gov.au/privacy/making-a-privacy-complaint or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001. 

© Head in the Clouds Co Pty Ltd. ACN 654 298 441

Level 3, 11-17 Buckingham Street, Surry Hills, Sydney NSW, 2010
info@headinthecloudsco.com.au | (02) 9136 2542

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