12 POINTS PSYCHOLOGY ABN 83 622 983 742 (“we”, “our”, “us” or “12 Points”), complies with the Privacy Act 1988 (Cth) (“Privacy Act”) and the applicable Privacy Principles in the Privacy Act when handling personal information, together with the Health Records Act 2001 (Vic) (“Health Records Act”) and the applicable Health Privacy Principles in the Health Records Act when handling personal information which is health information (“Health Information”).

This Privacy Policy applies to our website, www.12pointspsychology.com (“Website”, or "Site") which is operated by us, and to the products and services provided by us.

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, memberships 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 recognise the importance of your privacy and take the protection of your personal information seriously.

Collection

We and our practitioners (psychologists and counsellors) collect personal information for the purposes of arranging appointments and delivering counselling services, as well as communicating with you. We may collect information through our client consent forms, via the 12 Points website, or in the course of our practitioners undertaking counselling services in consultation and treatment of clients.

We collect personal information from clients when they register an enquiry via phone, email or our online client form, book an appointment, attend our practice, access our Website and/or at any other time from time-to-time in the course of our practitioners providing counselling services.

We collect personal information from third party service providers when they are engaged to supply services to us (such as, but not limited to, practitioners), provide information to us or invoice us for the provision of services.

The kind of personal information we may collect will depend on who you are (e.g. a client or third party service provider) and the nature of your interaction with us, and may include your full name, address, email address, date of birth, Medicare details, billing information, general appointment information and other personal information. If you do not provide us with all the information we request, our practitioners may not be able to deliver the counselling services.

Our practitioners may also collect your personal information in the manner and for the purposes contemplated above.

Some personal information we or our practitioners collect may include Health Information. We collect Health Information from clients when they attend our clinics for the purposes of arranging appointments and obtaining counselling services. Our practitioners collect Health Information in order to provide the counselling services. How your Health Information is dealt with is outlined in greater detail below.

Health Information

We and our practitioners comply with the Health Privacy Principles and the Ethical Guidelines of the Australian Psychological Society  in the collection, use and disclosure of all Health Information and to ensure that all Health Information is kept strictly confidential.

We and/or our practitioners may collect your Health Information when you attend our practice and/or at any other time from time-to-time in the course of arranging the provision of counselling services.

Our practitioners also collect your Health Information:

• as necessary for the provision of counselling services, including recording personal information and Health Information which is relevant to your current situation for the purposes of assessment and diagnosis in your client notes,
• only as necessary for the provision of counselling services, or as otherwise in accordance with your consent, or as may be required by law including Court order;
• only from our clients (or from someone authorised by them) (including a caregiver, if applicable);
• with care, taking all steps as may be reasonably necessary to ensure your information remains confidential and that any persons it is disclosed it to in accordance with this Privacy Policy are also required to keep it confidential in accordance with the duty of care to you and in accordance with the Ethical Guidelines of the Australian Psychological Society. 
• with accuracy, on the basis that you may at any time request a copy of the Health Information that we or our psychologists hold by emailing us at 12points.psychology@gmail.com (subject always to applicable law) and where our records are found to be inaccurate, we will rectify any inaccuracies on the basis of the further information you provide.

Consent and usage

By engaging us or registering your details on our Website or by email or telephone, and/or using the Website, or completing a client consent form, or otherwise engaging our counselling services, you consent to us and our practitioners collecting, using and disclosing your personal information (including Health Information) for the purposes specified in this Privacy Policy.

Personal information collected by us will generally only be used and disclosed for the purpose it was collected. We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent.

We may use any personal information collected (excluding Health Information) to provide our counselling services, operate the Website, respond to feedback and complaints, communicate with third party service providers or if needed to enforce our Consent Form with you. If you are a third party service provider, we will use your personal information to communicate with you including to accept your offer to provide services, correspond with you in relation to the provision of services and to pay your invoices.

Data security and quality

We will take reasonable steps to protect the personal information we collect and hold from misuse, loss and interference and from unauthorised access and modification, and to make sure it is accurate, complete and up-to-date when we collect, use or disclose it.

We use commercially reasonable physical, technical and administrative measures to protect Personal Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our Site. Personal information may be stored electronically through third party data centres, which may be located overseas, or in physical storage at our premises or third-party secure storage facilities.

To assist us, please ensure you provide us with your correct details, and let us know if you believe the information we have about you is inaccurate, incomplete, out of date or misleading (and we will take reasonable steps to correct the information). We may take steps to destroy or permanently de-identify information when it is no longer needed for any purpose for which it may be used or disclosed. We may retain and use de-identified information.

Data Breach Notification Scheme

If we have reason to suspect a data breach has occurred, we will undertake an assessment in accordance with the Notifiable Data Breach Scheme.  If we determine there has been an eligible data breach, we will notify you as soon as reasonably practicable.

Cookies

Our Website may use “cookies”; technology to store data on your computer using the functionality of your browser. Many websites do this because cookies allow the website publisher to do useful things like find out whether the computer has visited the site before.

You can modify your browser to prevent cookie use – but if you do this our service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of behaviour of visitors to the Website.

In the course of serving advertisements to the Website (if any), third-party advertisers or ad servers may place or recognise a unique cookie on your browser. The use of cookies by such third party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.

Access, corrections and complaints

You can request, and we will provide you with access to, any personal information we hold about you (including any Health Information) (subject to any applicable legal exceptions). Please also let us know if you have any concerns or complaints about the way we are handling your personal information so we can address them. Requests should be submitted by email to 12points.psychology@gmail.com. Where our records are found to be inaccurate, we will promptly rectify any inaccuracies on the basis of the further information you provide.

Transfer in certain circumstances

If there is a sale, merger, consolidation, change in control, transfer of substantial assets, re-organisation or liquidation of us then, subject always to the Ethical Guidelines of the Australian Psychological Society  we may transfer, sell or assign personal information (other than Health Information) collected to one or more relevant third parties. Subject always to your consent, we may also transfer any Health Information we hold about you to your psychologist in the event your psychologist leaves our practice.

Third-party websites

At times, our Site may contain links to other, third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Marketing emails

We may send you direct marketing emails and information about products and services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth) as you consented to upon registering for our Services.  If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you email about your account, your account or any Services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing.

If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.

Career Applications

Employment applications and resumes collected by us are safely and securely stored and only used for the purposes for which they were collected.

Changes to this Privacy Policy

This Privacy Policy forms part of the agreement between you and us (either in your capacity as a client or a third party service provider). We may, from time to time, amend this Privacy Policy, in whole or part, in our sole discretion. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on www.12pointspsychology.com. Depending on the nature of the change, we may announce the change on the www.12pointspsychology.com home page or by email (if we have your email address). However, in any event, by continuing to use the Website and/or our service following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as amended from time to time, in whole or part, you must terminate your use of the Website and inform us immediately prior to any further receipt of our counselling services.

Contact us

If you have any questions about this Privacy Policy, or if you wish to request access to your personal information, correct or update you details or raise any privacy concerns you may have, please contact us at 12points.psychology@gmail.com

For further information on your privacy rights go to: https://www.oaic.gov.au/privacy

For further information on the Health Records Act, go to:

https://www.health.vic.gov.au/legislation/health-records-act

https://www.legislation.vic.gov.au/in-force/acts/health-records-act-2001/046