About this policy
Solution Psychology Pty Ltd, ABN: 35 632 714 802 (“us”, “we”, or “our”) recognises the importance of your privacy and respects your right to control how your personal information is collected and used.
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.
This Privacy Policy applies to our website, www.solutionpsychology.com.au (the “Site”) which is operated by us, and to the products and services provided by us to you (“Services”).
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 and any other information we may collect from you that may identify you.
“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.
Collection
To provide our services to you, we may collect Personal Information, such as your contact details, including your name, email address and contact phone number, your business or company name; your payment and billing information, which we use to bill you for the Services and to process your payments, including credit card details. We may also collect details of conversations we have had with you or any other information relevant to us.
We may also collect Sensitive Information about you, such as medical reports, referrals, medication, health history and other important health information where you consent, and such information is reasonably necessary to provide our Services to you.
We automatically collect through our Site and Services, information that is often not personally identifiable, such as the website from which visitors came to our Site, IP address, browser type and other information relating to the device through which they access the Site. We may combine this information with the Personal Information we have collected about clients.
We also collect Personal Information and Sensitive Information at the time you request us to provide Services to you. The collection of such information may be via our Site or via our employees, agents and other third parties or through the deployment of third party AI products and services which we use to assist us in recording, transcribing and analysing our psychology sessions with you.
You may elect not to provide us with some or all of the Personal Information or Sensitive Information we request from you, however we may not be able to provide our Services to you without such Personal Information or Sensitive Information.
For some Services, certain information is designated as mandatory (which is required to use the service) and some is optional (which you may choose not to provide, but your failure to provide that information may limit your use of the service). If you do not provide personal information to us that is designated as mandatory, we will be unable to provide you with that Service.
Use & 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 to you.
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 Act, including to effectuate or enforce a transaction, procuring advice from legal and accounting firms, auditors and other consultants.
We may also use and share aggregated, non-personally identifying information about you for market analysis, research, marketing or other purposes.
We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent.
We may provide Sensitive Information relating to your health to other medical service providers, such as your general practitioner or specialist medical practitioners and we may disclose your Sensitive Information to third party AI service providers whom we engage to record, transcribe and analyse our psychology sessions. 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 a patient’s life, health or safety, or other reason as permitted.
Access & Accuracy
We will take reasonable steps to ensure that your Personal Information which we may collect, use or disclose is accurate, complete and up-to-date. However, we rely on the accuracy of the personal information as entered by you or provided to us by third parties.
You can access and/or correct information we hold about you at any time by contacting us at info@solutionpsychology.com.au. We encourage you to contact us to keep your Personal Information up to date.
We will respond to your request for Personal Information within a reasonable time. We may charge a reasonable administration fee to cover the costs of responding to your request, for example, where Personal Information is held in storage.
If required by law or where the information may relate to existing or anticipated legal proceedings, we may deny your request for access to your information. We will respond to your request, setting out the reasons for our refusal in writing.
Storage & Security
We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access and modification or disclosure. 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.
Despite taking appropriate measure to protect personal information used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk.
If we no longer require the use of your personal information, we will take reasonable steps to destroy or permanently de-identify it.
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.
Before agreeing to host Personal Information to an entity or person located overseas and before we engage a third party AI service provider to assist us in the delivery of our Services, we take steps to ensure that the recipients of such information do not breach the APPs in relation to the information, by including relevant contractual provisions.
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or for legal purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You are solely responsible for the maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
Surveillance
At Solution Psychology we prioritize the safety and security of our employees and clients. To ensure a secure environment, we use surveillance cameras in public areas. Our Surveillance policy aims to provide transparency regarding the use, storage, and access to the recordings generated by these cameras, please click here to read our full policy to understand how we handle the collected information.
Privacy in online communications
The privacy of any form of communication via the internet or a mobile device is potentially vulnerable and limited by the security of the technology. Zoom or Teams (Microsoft Teams) is used for the provision of online services at Solution Psychology. Zoom nor Teams do not have access to identifiable health information and protect and encrypt all audio, video and screen sharing data in transit and at rest. For full details on Zoom security see https://zoom.us/security. For full details on Teams security and privacy see https://www.microsoft.com/en-au/trust-center Please be aware that email communication is not secure and should contain minimal personal information. You may be provided with suggestions to help you protect your own online privacy for our sessions. Please be aware that you are responsible for any costs incurred in relation to the provision of your own software, hardware and data usage associated with our telehealth service. Zoom and Teams are currently a free service and can be accessed by a modern browser without software download.
Solution Psychology will not make recordings of online sessions or use material from sessions for purposes other than delivering a Service to you. Your psychologist will seek your written consent if they wish to use material for other purposes (such as consultation with a supervisor or colleagues). We ask you to respect our privacy by agreeing not to make recordings of the sessions and not to use materials from the sessions for purposes other than therapy. If you wish to record sessions or use session material for other purposes, you must seek the consent of your psychologist to do so.
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 the breach relates to the My Health Records Act, we may disclose your personal information to the My Health Records System Operator under s 73A of that Act.
Identifiers
An identifier is a unique number assigned to an individual to identify them. Identifiers include Medicare Numbers and Tax File numbers. We will not adopt as our own any identifier of you or use or disclose an identifier of you which has been assigned by a government agency, unless permitted under the Act.
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.
Cookies, web beacons and analytics
When you interact with our Site, we strive to make your experience easy and meaningful. We, or our third-party service providers, may use cookies, web beacons (clear GIFs, web bugs) and similar technologies to track site visitor activity and collect site data. We may combine this data with the Personal Information we have collected from Customers. Examples of information that we may collect include technical information such as your computer’s IP address and your browser type, and information about your visit such as the products you viewed or searched for, the country you are in, what you clicked on and what links you visited to get to or from our site. If we identify you with this information, any use or disclosure of that information will be in accordance with this Privacy Policy.
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 we will process your opt-out requests as soon as reasonably practicable. 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.
Consent to international transfer
We may transfer your Personal Information to organisations in other countries that are recognised by the Office of the Australian Information Commissioner as having comparable privacy protections. Recipients may include our related entities or employees, external service providers such as administration providers or information technology providers such as cloud storage and data processing. 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.
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 Site – you should check periodically to review our current Privacy Policy, which is effective as of the effective date listed above. Your continued use of any of our Site and Services constitutes your acceptance and understanding of the Privacy Policy as in effect at the time of your use. 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 the Site, or where practical, by emailing Customers. This policy current as of 11 May 2024.
Complaints and Enquiries
If you have any questions or complaints regarding privacy, or if at any time you believe we may have wrongfully disclosed your Personal Information or breached our privacy policy, please contact us on (03) 9988 7760 or lodge your complaint in writing to:
Solution Psychology PTY LTD
Suite G03. One Dean
1-23 Dean Street
Moonee Ponds 3039
or via email at info@solutionpsychology.com.au
If you are not satisfied with our response you are entitled to contact the Office of the Australian Information Commissioner, by phoning 1300 363 992 or writing to the Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 1042.