Brisbane Counselling Centre Pty Ltd ACN 010 871 020 (BCC, we, us or our) takes your privacy seriously and is committed to protecting your privacy under the Privacy Act and other relevant laws including Public Records Act 2002 (Qld) and Healthcare Identifiers Act 2010 (Cth). This Privacy Policy describes how we collect and treat your Personal Information.

By accessing or visiting our website and/or using our services (whether the service is completed by you or not), you agree to be bound by this Privacy Policy. We may amend this Privacy Policy from time to time. We will notify you of important changes, highlight them at the top of this Privacy Policy, and provide a prominent link to those changes for a reasonable length of time following the changes. You consent to the amended Privacy Policy by continuing to use our services.

Who we are

We offer services and facilities to psychologists who provide psychology and counselling services to their patients at our premises.

If you have any questions about our use of your Personal Information or have any concerns about our compliance with the Australian Privacy Principles, please contact:

Natascha Madden, Director

Brisbane Counselling Centre

Level 7, 87 Wickham Terrace Brisbane QLD 4000 Australia

Tel: (07) 3831 4452

Fax: (07) 3831 4457

Personal Information collection and usage

This Privacy Policy relates to all information supplied by you to us including:

• Contact information: your name, position, role, company or organisation, telephone number email, postal address emergency contact details;
• Your communications: information provided in communications with us including when you book (or enquire about booking) an appointment with a psychologist;
• Business information: data identifying you in relation to commercial dealings we have with you or the business you represent;
• Information from public sources: for example, from LinkedIn and similar professional networks, directories or internet publications;
• Financial information: we may obtain your bank account details (or third party payer) for example when taking payment for an appointment with a psychologist (whether that appointment has occurred or not and including late or cancellation fees);
• Medical information: we may collect information about your health and medical history for the purpose of providing this information to your treating psychologist and to process payment and rebates, for example through Tyro HealthPoint (Private Health Insurance claims) and Medicare;
• Social media: posts, likes, tweets and other interactions with our social media presence;
• Technical information: when you access our website and our technology services being IP address, time zone setting, browser plug-in types and versions, operating system you are using, device type, hardware model, MAC address, unique identifiers and mobile network information;
• Online data: when you access our website, app and our technology services, information about your visit including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and other similar information and whether you click on particular links or open our emails.  

We may receive Personal Information directly from you, the company or organisation you represent, or screening providers who assist us with our legal obligations. This information may be exchanged over the phone, by email, SMS, in person, in any other form of written communication or through our online enquiry form on our website. We may also obtain Personal Information about you from a healthcare professional such as your treating GP or specialist doctor.

If you send us an email containing Personal Information, we will use reasonable endeavours to ensure the confidentiality of that information. Our internet host may monitor emails for maintenance and fault detection purposes. We may also monitor emails so as to ensure that we are complying with our legal obligations. We may forward emails to related service providers and other third parties where the email contains feedback or complaints. Email is not a secure method of communication. If you are concerned about sending your Personal Information to us by email we suggest that you consider contacting us in person, by writing or by telephone.

We do not collect Personal Information about your online activities across third party websites or online services.

In addition to the information you provide to us, any information supplied by you to a psychologist will not be made available to other psychologists, staff or interested parties without firstly obtaining your written consent (unless required by law).

If you do not wish to provide Personal Information to us, then you do not have to do so, however it may affect your use of the website and/or any products and services offered on it.

How we use your Personal Information

We use your Personal Information for the following purposes:

• to provide to and enable the psychologists who use our services and facilities to provide psychology and/or counselling services to patients;
• to assist in making an assessment as to which psychologist might be the most appropriate for you;
• to communicate with you including for example sending appointment reminders and confirmations, emailing you your invoice or bill, or reminding you that your mental health treatment plan requires updating;
• receiving or responding to feedback, enquiries or concerns you may have;
• to monitor our website and our other technology services, to ensure they are used appropriately and working as intended, including as tracking outages, unauthorised use, or troubleshooting issues that you report to us;
• protecting our information and technology platforms from hacks, or identifying and addressing malware and other security threats;
• compliance with law, including auditing and reporting requirements. We reserve the right to obtain further information from you to comply with the law if required;
• to pursue the legitimate business interests listed in the “Legitimate Interests” section of this policy below.

If there is a change of control in our business or a sale or transfer of business assets, you consent to us transferring (to the extent permissible at law) our user databases, together with any of your Personal Information and non-personal information contained in those databases to the new purchaser.

Why we use your Personal Information

We will process your Personal Information for a number of reasons including:

• with your consent: for example you share details for particular purposes;
• to comply with law;
• processing is necessary for our legitimate business interests or those of a third party, provided this does not override any interests or rights that you have as an individual.

Our legitimate interests include looking after your health and wellbeing, monitoring how users access our website, understanding and responding to feedback and enquiries, and providing the appropriate facilities and services to enable the phycologists to service their patients.

Why we use Sensitive Information

We will only use Sensitive Information if:

• it is not otherwise permitted under this Privacy Policy, but we have your express and informed consent for the particular processing;
• we need to protect your vital interests or those of another person for example, in medical emergencies;
• you have manifestly made the data public for example, where you have published it on social media;
• this is necessary to deal with legal claims for example, involving court proceedings;
• this is necessary for substantial public interest for example, to prevent or detect unlawful acts; or
• as permitted by applicable law.

Who we share your Personal Information with

There are instances where we can disclose your Personal Information where it is permitted or required by law. We share your information with others as follows:

• Shared service centres: that we or third parties operate including for IT services, marketing, risk management and office support services;
• Financial institutions: for payment processing;
• Law enforcement bodies and our regulators: or authorities in accordance with law or good practice;
• Appropriate parties in the event of emergencies: in particular to protect health and safety of you and others;
• Healthcare professionals: including hospitals and your treating GP for example in connection with a mental health treatment plan;
• Family or representative: any person, family member, representatives or other organisations that you have consented or where we are required, permitted, authorised or otherwise directed to by law;
• Advertising networks and analytics service providers: to support and display ads on our website, apps and other social media tools;
• Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation;
• Independent contractors: including website designers, mailing and courier services, printers and distributors of direct marketing material and external advisors such as auditors, lawyers and debt collectors

How we store your Personal Information

We may keep your Personal Information in physical and electronic form (or a combination). We will store and process your information securely using good practice physical, technical and administrative security measures. However, exchanging information by the internet is not completely secure. Although we will take reasonable measures to protect your Personal Information, we cannot guarantee the security of information you transmit, so any transmission is at your own risk.

Where your Personal Information is also kept by a psychologist, how they treat your information is dealt with under their own privacy policy. We encourage you to read their privacy policy.

How long we store your Personal Information for

We retain the data we collect for different periods of time depending on what it is and how we use it.  We generally keep your information as needed to provide our services to the psychologists, or as requested by the psychologists, comply with legal, accounting or regulatory requirements or to deal with claims. We also have a legal requirement to store your information for at least seven years from the time you had last contact with a psychologist, or if you are a minor, until you turn 25 years of age.

Once we no longer need to hold your Personal Information, we will destroy it (either by shredding physical documents or permanently deleting electronic information from our server, subject to any back-up records).

How you can correct your Personal Information

If you believe that any Personal Information that we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us  in writing. It is your responsibility to advise us of any changes to your Personal Information (for example change of residential address, email address or phone number). We will respond within a reasonable time where practicable and will endeavour to correct any personal information. You may request we provide you with, or delete, your Personal Information. Any written request by you cannot be unreasonably withheld by us and we will be responded to within a reasonable period (and no more than 30 days after your request).

Access to your personal information

Please contact us if you would like to access the Personal Information that we hold about you. We will generally provide you with access to your Personal Information within a reasonable period (and no more than 30 days after your request). Depending on the amount of information requested, we may charge an access fee to cover the cost of retrieving the information and supplying it to you.

Access to Personal Information may be refused in a number of circumstances, such as where the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, we will explain why in writing. Similarly, in some limited circumstances we may not make requested corrections to Personal Information, in which case we will provide you with written reasons for this decision.

If you have any concerns about the way your Personal Information is stored, disclosed or otherwise managed, or believe that a breach of your privacy has occurred, please contact us in writing. We will respond to your concerns as soon as reasonably practicable (and no more than 30 days after your request). If you are for whatever reason not satisfied with the response or resolution of your concerns or complaint, you can contact the Office of the Australian Information Commissioner.

Cookies and Google Analytics

Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes and which allow us to provide you with customised services. We use cookies and Google Analytics on our online services.

Google Analytics collects and processes data by using the website’s cookies to analyse the use of the website including, for example, how long users spend on each webpage and collect other ‘Online data’ described above. This information is used mainly for the optimisation of the website to enhance the user experience, and to allow us to better deliver our services. The data collected by Google is transmitted to a server in the United States (or other countries outside of Australia).

You can review how Google uses data by clicking on the following link: https://policies.google.com/technologies/partner-sites

Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to refuse cookies. However, if you do so, you may not be able to take full advantage of our website.

Use of Commonwealth government identifiers

We will not use Commonwealth government identifiers (Identifiers) (for example, Medicare numbers) as our own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Act.

Where we will hold your information

We may store your data in different parts of the world, and your information may be transferred out of Australia, including to the United States. Data protection laws vary by country.  We will take steps to protect your information in line with locally applicable data protection requirements

Links to third party websites

Our website, email updates and other communications may, from time to time, contain links to and from the websites of others. The Personal Information that you provide through these websites is not subject to this Privacy Policy and the treatment of your Personal Information by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

Definitions

In this Privacy Policy, the following terms have the meaning given to them below unless the context requires otherwise:

• Personal Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not or in a material form or not;
• Privacy Act: means the Privacy Act 1988 (Cth);
• Privacy Policy: means this privacy policy as amended from time to time made available on our website;
• Sensitive Information: has the meaning given to it in the Privacy Act, which includes information or an opinion about an individual’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation or criminal record; and
• You/Your: means the individual who we collect the Personal Information from and about.

 

Last update: Aug 2023