Privacy Policy

This document is the Privacy Policy of Inner Good Psychology Pty Ltd ACN 701 163 297 trading as Inner Good Psychology (“Inner Good Psychology”), also referred to as “we”, “our”, or “us” in this Privacy Policy.

This Privacy Policy relates to the collection and use of personal information that may be collected by or supplied to Inner Good Psychology. This Privacy Policy is in addition to any other terms and conditions applicable to the Inner Good Psychology. Inner Good Psychology reserves the right to modify or amend this Privacy Policy at any time, in our absolute discretion.

Inner Good Psychology may collect information from users of its website, clients of Inner Good Psychology, users of any application, booking or payment platform or portal utilised in connection with appointments with Inner Good Psychology.

Some information collected is information that may be capable of identifying an individual ("personal information"). This Privacy Policy, and the Australian Privacy Principles, regulates the way in which the Inner Good Psychology will deal with such personal information.

Purpose

Inner Good Psychology is committed to protecting your privacy and managing your personal information in accordance with:

· the Privacy Act 1988 (Cth);

· the Australian Privacy Principles (APPs);

· relevant health records legislation;

· Psychology Board of Australia requirements; and

· professional and ethical obligations applicable to registered psychologists.

This Privacy Policy explains how your personal information is collected, stored, used, disclosed, and protected.

Commitment to Privacy

Inner Good Psychology understands that psychological services involve the collection of sensitive and personal information.

We are committed to:

· maintaining confidentiality;

· protecting privacy;

· promoting informed choice;

· using information responsibly;

· storing information securely; and

· complying with legal and professional obligations.

Information We Collect

Personal information is collected only when knowingly and voluntarily submitted by you.

Our main purpose for collecting, using, holding and sharing your personal information is to provide you with psychology services. We also use it for directly related business activities, such as financial claims and payments, audits, and business processes.

Information collected may include:

Personal Information

· full name;

· date of birth;

· contact details;

· address;

· emergency contact details;

· Medicare details;

· referral information;

· funding information;

· payment information.

Health Information

· medical history;

· mental health history;

· medication information;

· assessment results;

· treatment plans;

· session notes;

· reports;

· correspondence.

Cultural Information

To support culturally safe practice, clients may choose to provide information relating to:

· Aboriginal and Torres Strait Islander identity;

· cultural background;

· language spoken;

· religious or spiritual beliefs;

· cultural practices relevant to treatment.

Providing this information is voluntary.

Accessibility Information

To support accessible services, clients may choose to provide information about:

· communication preferences;

· disability-related support needs;

· sensory preferences;

· accessibility requirements;

· support persons;

· alternative communication methods.

Providing this information is voluntary.

How Information Is Collected

Inner Good Psychology collects personal information that is reasonably necessary to provide and administer psychological services. We generally collect this information directly from you when you complete forms, attend appointments or communicate with us.

We may collect personal information directly from you through:

· intake forms;

· consent forms;

· during the course of appointments or providing services;

· telephone communication;

· email communication;

· referral letters;

· questionnaires;

· assessment tools;

· reports from other professionals;

We may also collect information when you use our website, submit an online enquiry, or communicate with us by telephone, email, SMS or social media. Where it is not practical or reasonable to collect information directly from you, we may collect it from other sources, including healthcare providers involved in your care. Where appropriate, information may also be collected from:

· parents or carers;

· legal guardians;

· referrers;

· medical practitioners;

· schools;

· support workers;

· other professionals,

We will collect information from these sources with your consent or where otherwise permitted or required by law.

Personal information collected in these ways may be stored as paper records, electronic records or audio recordings, as described in this Privacy Policy.

Why Information Is Collected

Personal information that you provide us is used only for the purpose for which it is submitted, unless we disclose other uses in this Privacy Policy or at the time of collection.

We will use the personal information we collect to:

· provide psychological services;

· understand presenting concerns;

· conduct assessments;

· develop treatment plans;

· communicate with you;

· administer appointments and billing;

· meet legal obligations;

· coordinate care where appropriate;

· maintain accurate health records.

Use of Technology

Inner Good Psychology uses secure technology systems to support the delivery and administration of psychological services. These systems may involve the collection, use, storage, processing and transmission of personal information, including sensitive and health information.

The technology used by Inner Good Psychology may include:

· Halaxy;

· Tyro Health;

· Xero;

· secure telehealth platforms;

· electronic health records;

· appropriate email and other communication systems;

· appointment scheduling and management systems;

· invoicing and payment processing systems;

· other software, applications and technology tools that support clinical documentation, delivery of psychology services and administrative functions.

Inner Good Psychology will endeavour to take reasonable steps to assess and manage the privacy and security risks associated with the technology it uses. However, Inner Good Psychology cannot guarantee the security of information transmitted or stored through third-party systems and is not responsible for the privacy or security practices of third-party providers beyond the extent of its control. Clients should refer to the relevant provider's privacy policy for further information about how that provider collects, uses, stores and otherwise handles information.

Where Inner Good Psychology engages third-party technology or service providers that may have access to, or process, client information, Inner Good Psychology will endeavour to take reasonable steps to select providers having regard to their privacy, confidentiality and information security practices.

In addition, the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information.

Where a technology provider is located overseas or information is stored or accessed outside Australia, Inner Good Psychology will take reasonable steps to ensure that any cross-border handling of personal information is undertaken in accordance with applicable privacy obligations.

Halaxy and Electronic Records

Inner Good Psychology uses Halaxy as its primary practice management system to assist with the administration and delivery of its services.

Halaxy may be used to:

· manage and schedule appointments;

· collect and store contact and identifying information;

· create, maintain and manage clinical and treatment records;

· manage correspondence and communication with you;

· process payments and manage billing information;

· generate and issue invoices and receipts;

· provide telehealth appointments by video or telephone;

· support communication and other administrative functions associated with providing psychological services.

Information collected or stored in Halaxy may include personal information and, where necessary for the provision and management of psychological services, sensitive information, including health information.

Halaxy is a third-party service provider. Inner Good Psychology will endeavour to take reasonable steps to ensure that information is handled in accordance with its privacy obligations and the terms of this Privacy Policy. However, your information will also be handled by Halaxy in accordance with Halaxy's own privacy policy and terms of use. Clients may review Halaxy's privacy information to understand how Halaxy collects, uses, stores and otherwise handles information. A copy of Halaxy's current privacy policy is available on the Halaxy website.

Inner Good Psychology may use third-party service providers and cloud-based systems to store, host, process or manage personal information, including sensitive information relating to psychological services. Depending on the provider and the services used, personal information may be stored or processed outside Australia or disclosed to recipients located overseas.

Where practicable, Inner Good Psychology will identify the countries in which overseas recipients are likely to be located.

Inner Good Psychology takes reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including when using overseas service providers. Where personal information is disclosed to an overseas recipient, Inner Good Psychology will take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, unless an applicable exception applies.

Where there is any inconsistency between this Privacy Policy and Halaxy's privacy policy, this Privacy Policy governs Inner Good Psychology's handling of client information, while Halaxy's privacy policy governs Halaxy's handling of information as a third-party service provider.

Audio Recordings

Inner Good Psychology will only make an audio recording of a consultation or other interaction with the client’s informed consent. Consent may apply to a particular recording or be provided on an ongoing basis for recordings made for an agreed purpose.

Audio recordings may be made and used where reasonably necessary to support:

clinical review and treatment;

· clinical supervision;

· quality assurance and service improvement;

· accurate and efficient preparation of clinical notes and records; and

· any other purposes that have been explained to the client and for which the client’s consent has been obtained.

Clients are not required to consent to audio recording in order to access psychological services. A client may decline to have a consultation recorded.

Where consent has been provided, a client may withdraw their consent to future recordings at any time. Withdrawal of consent will not affect the lawfulness of any recording or use that occurred before consent was withdrawn. Where appropriate and permitted by law, Inner Good Psychology will take reasonable steps to delete or dispose of recordings when they are no longer required for the purpose for which they were collected or where retention is no longer required by law or professional obligations.

Inner Good Psychology will endeavour to take all reasonable steps to protect recordings from unauthorised access, use, disclosure, alteration or loss.

Where a third-party technology provider is used to make, store, process or transcribe an audio recording, Inner Good Psychology will endeavour to take reasonable steps to ensure that the provider has appropriate privacy and security safeguards in place and that any use of the recording is consistent with the purpose for which it was collected and the client's consent.

AI-Assisted Note-Taking

Inner Good Psychology may use secure and appropriate technology to assist with clinical note-taking, documentation and other administrative aspects of providing psychological services.

Clients may decline the use of such technology or withdraw their consent at any time. Declining or withdrawing consent will not adversely affect a client’s access to, or quality of, psychological services.

Peer Consultation

Psychologists regularly engage in peer consultation and professional supervision to support ethical, competent and effective practice and to promote the best interests of clients.

Inner Good Psychology may discuss relevant aspects of a client’s circumstances, treatment or clinical presentation with another appropriately qualified psychologist or other professional for the purpose of professional consultation, supervision, case review or quality assurance.

Where reasonably practicable:

· identifying information will be removed or minimised;

· information will be de-identified to the extent possible;

· only information reasonably necessary for the consultation will be shared; and

· confidentiality will be maintained.

Any person involved in peer consultation or professional supervision will be expected to maintain the confidentiality of client information and comply with applicable professional and privacy obligations.

Disclosure of Information

Personal information, including sensitive or health information, may be disclosed where reasonably necessary and appropriate:

· with the client’s consent or as otherwise authorised by the client;

· to healthcare providers or other professionals involved in the client’s care, where appropriate and permitted;

· to a parent, guardian or other person with lawful authority to act on behalf of the client, where appropriate and permitted;

· to Medicare or other relevant government bodies for the purposes of processing claims, rebates or related requirements;

· to funding bodies or other organisations where disclosure is necessary for the provision, administration or funding of services, and where permitted;

· where disclosure is required or authorised by law or;

· in other circumstances permitted or required under applicable privacy laws and professional obligations.

Inner Good Psychology will only disclose information that is reasonably necessary for the relevant purpose and will take reasonable steps to ensure that information is disclosed only to appropriate recipients.

Limits to Confidentiality

Confidentiality is an important part of psychological care. However, there are circumstances in which information may need to be disclosed without your consent.

These may include situations involving:

· where there is a serious and foreseeable risk of harm to you or another person;

· where disclosure is required or authorised by law, including mandatory reporting obligations;

· where mandatory reporting obligations apply, including in relation to suspected child abuse or neglect where required by Queensland Law;

· where disclosure is required by a court order, subpoena or other legal process;

· where disclosure is necessary to protect the safety, health or wellbeing of a person; or

· where disclosure is otherwise permitted or required under applicable legislation.

Where appropriate and legally permitted, we will discuss the need for disclosure with you before information is disclosed. However, this may not always be possible or appropriate, including where doing so could increase a risk of harm or where disclosure is required by law.

Only information that is reasonably necessary for the relevant purpose will be disclosed where practicable.

Access to Records

We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date. If, at any time, you discover that information held about you is incorrect, you may contact us to have the information corrected.

Inner Good Psychology may request appropriate identification or additional information where reasonably necessary to protect client privacy and security of records.

In some circumstances, access may be refused or limited where permitted or required by law.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

Fees for Record Access

Reasonable fees may apply for costs associated with providing access to records, where permitted by applicable law. If a fee is applicable, the client will be informed of the fee before access is provided, where practicable.

Record Retention

Inner Good Psychology retains personal information and clinical records for the periods required by applicable Queensland and Australian legislation, professional standards and record-keeping requirements.

As a general guide:

Adult Clients

Clinical records are retained for a minimum of seven (7) years from the date of the client's last appointment, or for any longer period required by law or professional requirements.

Children and Young People

Where services are provided to a person under 18 years of age, clinical records will generally be retained until the person reaches 25 years of age, or for any longer period required by law or professional requirements.

Records may be retained for longer where reasonably necessary, including where required for legal, regulatory, professional or clinical purposes.

Audio Recording and AI File Retention

Where consent has been obtained Inner Good Psychology may use audio recording and AI-assisted technology to assist with transcription, clinical documentation and administrative processes and:

· audio recordings may be temporarily stored;

· audio recordings may be processed using an AI-assisted transcription or documentation tool;

· transcripts or draft documentation may be temporarily generated and stored; and

· information may be processed by third-party technology providers where necessary to provide the relevant service

Once the relevant documentation has been completed and verified, temporary audio recordings, transcripts and other AI-assisted processing files will be deleted, where practicable. Information may be retained for longer where required or permitted by law, or where reasonably necessary for clinical, legal, regulatory or professional purposes.

Clinical Records

Clinical notes, reports, correspondence and other documentation created in connection with a client's care form part of the client's health record.

Clinical records may be retained for the periods required by applicable privacy, health records and professional requirements, including the retention periods outlined in this Privacy Policy.

The deletion of an original audio recording or other temporary file does not result in the deletion of information that has been incorporated into the client's clinical record.

Website Information

When you use the Inner Good Psychology website, we may collect information that you provide directly to us, including information submitted through enquiry or contact forms.

We may also collect limited technical information about website use, such as IP address, browser type, device information and website activity, including through cookies or similar technologies, where applicable to assist us to measure or improve our website and to assist with the diagnosis of problems or support issues with our services. Cookies allow us to increase your security by storing your session ID and are a way of monitoring single user access. This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the site.

Information collected through the website may be used to:

· respond to enquiries;

· arrange or administer appointments;

· provide and administer services;

· communicate with clients;

· maintain and improve website functionality and security; and

· otherwise manage and operate the practice.

We will only collect and use personal information obtained through the website for purposes reasonably necessary for the operation of the practice or as otherwise permitted or required by law.

Where third-party services are used on the website, including appointment booking, payment, analytics, hosting or communication services, those providers may process information in accordance with their own privacy policies and the arrangements in place with Inner Good Psychology.

Where we provide links to websites outside of our web sites, as well as to third party websites, these linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that Web site and its privacy statement.

In the event we use social media to communicate with the public about Inner Good Psychology and if you communicate with us using such social media services, we may collect your personal information, but we only use it to help us to communicate with you and the public. We are not responsible for the privacy policies of social media services, and we advise you to examine the terms and conditions of using that social media platform and its privacy statement.

Data Security

Inner Good Psychology will endeavour to take all reasonable steps to protect personal information from:

· unauthorised access, use or disclosure;

· misuse;

· loss or theft; and

· unauthorised alteration or destruction.

While reasonable steps are taken to protect personal information, no method of electronic transmission, storage or processing can be guaranteed to be completely secure.

If Inner Good Psychology becomes aware of a data breach that is likely to result in serious harm to an affected individual, the practice will respond in accordance with applicable privacy laws, including the Notifiable Data Breaches scheme where applicable.

Complaints and Privacy Concerns

If you have a concern about the way Inner Good Psychology has collected, used, disclosed or handled your personal information, we encourage you to contact us in the first instance so that we can investigate and attempt to resolve the concern.

Email: admin@innergood.com.au

We will acknowledge and respond to privacy complaints within a reasonable period and in accordance with applicable privacy requirements.

If you are not satisfied with our response, or you would prefer to make a complaint externally, you may contact the relevant regulatory or complaints body, depending on the nature of your concern.

Australian Health Practitioner Regulation Agency (AHPRA)

AHPRA manages the registration of registered health practitioners and receives notifications and complaints about registered practitioners.

Website: www.ahpra.gov.au

Psychology Board of Australia

The Psychology Board of Australia regulates registered psychologists in Australia.

Website: www.psychologyboard.gov.au

Office of the Australian Information Commissioner (OAIC)

The OAIC handles privacy complaints relating to organisations covered by Australian privacy law, including the Australian Privacy Principles.

Website: www.oaic.gov.au

Office of the Health Ombudsman (Queensland)

The Office of the Health Ombudsman receives complaints and notifications about health services and health practitioners in Queensland.

Website: www.oho.qld.gov.au

Changes to This Privacy Policy

Inner Good Psychology may update this Privacy Policy from time to time.

The most recent version will be available upon request and may be published on the practice website.

Contact Details

Inner Good Psychology

Natasha Seawright
Registered Psychologist
AHPRA Registration Number: PSY0002475166
Provider Number: 6589682A

Email: admin@innergood.com.au
Phone: 0428 589 754
Website: www.innergood.com.au