Privacy Policy at Inner Calm Clinical Psychology (ICCP)
This policy outlines how ICCP Pty Ltd handle personal information of their clients in accordance with the Australian Privacy principles.

Purpose of this policy

ICCP collects, works with and retains its clients’ personal information. This information is important in the optimal provision of psychological services. However, it is also important that the information is appropriately managed in accordance with law and ethical guidelines of the profession. This policy outlines how Inner Calm Clinical Psychology Pty Ltd handles clients’ personal information, in accordance with Australian Privacy Principles.

Relevant Laws and other Documents

The psychological services provided are bound by the legal requirements of the Commonwealth Privacy Act 1988, the Australian Privacy Principles 2014 and the Australian Psychological Society – Code of Ethics (2007)

What is personal information?

Personal information is any information which identifies you or could reasonably be used to identify you.

What personal information do we collect and why?

In order to provide optimal psychological services ICCP will collect information from clients or referrers. As a base, the following information will likely be collected:

- Your name, address and date of birth
- Your contact details
- Current and past medical information
- Your family medical history to the extent that it may inform current services
- Your and your family’s educational and occupational history
- Any legal proceedings that are occurring in the future or have in the past

In addition, as part of our psychological services, ICCP will collect the following personal information:

- Responses and results from psychological tests and questionnaires
- Responses and results as part of a neuropsychological assessment
- These responses may be in a ‘pencil-and-paper’ format, or via a computer
- Information pertaining to your session notes; treatment plan and your response to treatment

Video Recording
With prior discussion and specific informed signed consent obtained, ICCP will on occasion video record therapy sessions that are provided in person or via Telehealth. This is done as part of ongoing professional training and development and at times, as a therapy tool by the clinician. Access to the video recordings are accessed via a password protected link.

All of the above material is used to inform accurate assessment, diagnosis and treatment for ICCP clients. Not having this information may increase the risk that the assessment, diagnosis, and treatment plans subsequently arrived at or generated are sub-optimal.

For more information on Video Recording please refer to our Terms of Service.

Information provided by third parties

We will collect information from you where it is reasonable and practical to do so. We may also need to collect information from others who know you well (such as a parent) or from others involved in your care (such as your GP or other healthcare provider). Occasionally, and with informed consent, we may seek further information from a spouse/partner. We will always endeavour to keep you reliably informed of the information collected and the source of that information, and where appropriate will seek and obtain written informed consent to contact and retrieve that information.

Use and disclosure of personal information

ICCP will use and disclose personal information for the primary purpose of providing optimal psychological services. This will primarily take the form of a report prepared by the clinician and sent to the referrer or referring agent, plus others involved in the client’s care where applicable.

It is noted that in some circumstances psychologists are required by law to disclose personal information without the consent of the client. Specifically, psychologists may disclose personal information if a “permitted general situation” exists such as to “lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety”. This threat does not need to be imminent.

There may be occasions when ICCP discloses the personal information of a client where there is a serious threat to the life, health, or safety of an individual or the public, or on a rare occasion to assist in the location of a missing person.

Storage and security of personal information

Clinicians providing psychological services at ICCP will take reasonable steps to protect the personal information of clients from misuse, interference, or loss, and from unauthorised modification, access or disclosure.

Paper documents containing personal information listed above will be stored under lock. Electronic information containing personal information listed above will be stored and backed up securely, in accordance with the APS Code of Ethics (2007).

Can I access my personal information?

Clients have a right to access their personal information held by ICCP. Such requests need to be put in writing for security and recording purposes and to assist in finding the information for you.

ICCP may refuse the request for such information, or limit the information so provided, where it is legally entitled to do so. We will endeavour to provide reasons for refusal. For example, release of information may be denied or limited where such release may have an unreasonable impact on the privacy of others or is considered frivolous or vexatious.

Research and personal information

On occasion, ICCP will engage in research activities to improve the quality of the service we provide. In such cases, personal information of clients will be used. In this context, the information will not be released to third parties, but will be retained within ICCP for the sole purpose of quality evaluation and improvement of services.

In addition, ICCP may engage in academic or scientific research. In such cases clients will be asked to sign a consent form allowing the use of their personal information for the purposes of a specific research project. Such research will be required to have obtained the prior approval of a Human Research Ethics Committee within the Department of Health or the relevant University.

Anonymity and Pseudonymity

If desired by clients attending ICCP, and is practically and legally appropriate, the option is available to interact with ICCP using a pseudonym. This option is not available if doing so is impractical in terms of providing a psychological service or where the law or a court requires clients to identify themselves.

Psychologists duty of care

ICCP is guided by the Australian Psychological Society’s (APS’s) Code of Ethics (2007). Section A.4. of the Code relates to the appropriate collection of private information related to the provision of psychological services. Sections A.5. to A.7. of the Code relate to Confidentiality, the Release of Information to Clients, and the Collection of client information from associated parties. Section B.2. of the Code relates to appropriate record-keeping. The APS Code of Ethics (2007) can be obtained from ICCP, or from the APS website (www.psychology.org.au).

It is noted that under section A.5.2.(c) of the Code that psychologists disclose confidential information obtained in the course of their provision of psychological services, “if there is an immediate and specified risk of harm to an identifiable person or persons that can be averted only by disclosing information” (p.15).

Clients may also refer to the APS Charter for Clients of Psychologists https://psychology.org.au/getmedia/5fb479bb-4ab8-49f3-a9eb-1a76a3779ef4/aps-charter-for-clients.pdf

The Australian Health Practitioner Regulation Agency (AHPRA) is responsible for the registration of psychologists throughout Australia. Through AHPRA, and under National Law, there are requirements for registered health practitioners to make mandatory notifications to prevent the public from being placed at risk of harm. Revised guidelines took effect from 17th March 2014.

Transfer in certain circumstances

If there is a sale, merger, consolidation, change in control, transfer of substantial assets, reorganisation or liquidation of us then, subject always to the Ethical Guidelines of the Australian Psychological Society http://www.psychology.org.au/about/ethics/, 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.

Data breach plan

We follow the national requirements. See here:

https://www.oaic.gov.au/privacy/notifiable-data-breaches/


Complaints

Clients have a right to make a complaint about the handing of their personal information.

Complaints can be made to ICCP by email to [email protected] . We will endeavour to respond appropriately to reasonable complaints within 30 days of the receipt of the email.

Ultimately, if you wish to make a complaint about the use of, disclosure of, or access to your personal information, you may do so at:
The Office of the Australian Information Commissioner by phone on 1300 363 992 or online at http://www.oaic.gov.au/provacy/making-a-privacy-complaint or by post to:
Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001.

Other agencies to which clients may bring complaints are as follows:

Australian Health Practitioner Regulation Agency www.ahpra.gov.au
Australian Psychological Society www.psychology.org.au


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.innercalm.com.au Depending on the nature of the change, we may announce the change on the www.innercalm.com.au 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 [email protected]

For further information on your privacy rights go to: www.privacy.gov.au
For further information on the Health Records Act, go to:
https://www2.health.vic.gov.au/about/legislation/health-records-act http://www.health.vic.gov.au/hsc/downloads/hppextract.pdf