Harmonics Psychology
Privacy Policy for Management of Personal Information
1.Commitment to Privacy
1.1 I, Dr Jackie Cesareo at Harmonics Psychology, am committed to safeguarding the privacy of my clients, staff and visitors of the Practice, as well as those who visit our website.
1.2 I respect your privacy and right to control how your personal information is collected and used. “Personal information” refers to any information that may identify you, or by which your identity might reasonably be determined.
1.2 My practice (Harmonics Psychology) adheres to the Australian Privacy Principles contained in the Privacy Act 1988 (cth).
1.3 This privacy policy for my practice provides you with information about how your personal information (including your mental health or clinical supervision information) is collected and used, and the circumstances in which I may share it with third parties. If I need to use your information for anything else, I will seek additional consent from you. In the event that unauthorised access, disclosure, or loss of your personal information occurs, I will endeavour to minimise the risk of consequential harm.
1.4 This Policy also applies to my website (www.harmonicspsychology.com.au,) which is operated by me, and to the products and services provided by me.
1.5 I am a sole practitioner and do not have an administrative assistant. I am the only person managing your file, bookings, and account. In the event of me becoming incapacitated to perform duties (e.g., due to death or illness), a senior clinical psychologist colleague will be legally granted access so that she can inform patients and carry out the necessary duties of the practice (such as closing files, writing to GPs, writing to Medicare, responding to subpoenas, and closing the practice).
2. Definitions in this Policy
2.1. “Personal Information” is categorised as information held by the Practice, 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.
2.2. “Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliation, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
3. Collection of Your Data
3.1. When you register as a patient or supervisee of Harmonics Psychology, you provide consent for me to access and use your personal information so that I can provide you with the best possible mental health care or clinical supervision.
3.2 Your personal information is gathered and used for the purpose of providing psychological services (which includes assessing, diagnosing, and treating your presenting issue), or providing clinical supervision. Personal information is retained in order to document what happens during sessions and to enable me to provide a relevant and informed psychological or supervision service. I also use it for related business activities, such as Medicare claims and payments, practice audits, and business processes. Therefore, it may be necessary for me to disclose your personal information to third parties or contractors who are integral to the provision of my services.
3.3 Harmonics Psychology will receive and store Personal Information and Sensitive Information (together, ‘your Data’) that you enter onto my website, provide to me directly or give to me in other forms including the Practice general information and consent form, and social history form.
3.4. Your Data may include your:
3.4.1. Contact details including name, date of birth, addresses, contact details (phone number and email address), emergency contact details;
3.4.2 Medical diagnosis of a mental health disorder as required for you to claim a Medicare rebate.
3.4.3 Medicare number for identification and claiming purposes
3.4.4. Payment and billing information, which we use to bill you for agreed services and to process your payments (including credit card details);
3.4.3. ‘Sensitive’ health information (both physical and mental health) including medical reports, medications, referrals;
3.4.4. Personal history and family history including health history, treatment history, social history, addictions history, family history and risk factors, information relating to injuries past or present, or whether you are pregnant;
3.4.5 ‘Sensitive’ clinical supervision information;
3.4.6 Health Fund Details;
3.4.7 Psychological assessments and session notes; and
3.4.8. Other information voluntarily provided by you when interacting with me.
Your Data is collected to ensure your safety and wellbeing, and that of other participants and facilitators at Harmonics Psychology, to send information, provide updates and process purchases of services provided by Dr Jackie Cesareo.
3.5. Sensitive Information, which includes the definition of your Data relating to your health, will not be collected unless you consent to the collection of that information.
3.6. Harmonics Psychology collects your Data from you in a variety of ways, when you initially contact me in person, by phone or electronically. This may include:
3.6.1. when you access my website, submit an enquiry form
3.6.2. when you interact with me electronically by email or by phone, including submitting practice information and consent forms and sms;
3.6.3. During the course of providing psychological or supervision services, I may collect further personal information during your assessment, treatment or supervision sessions; and
3.6.4. During the course of providing psychological or supervision services, I may collect further personal information from other sources. This may include your GP, psychiatrist, allied health professionals, hospitals, your health fund, and Medicare.
3.7. I may collect additional personal Data at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your contact or email preference, provide financial or credit card information, or communicate with Harmonics Psychology in any other way.
3.8. Harmonics Psychology may receive your Data from third parties. Those third parties may include your medical practitioners, hospitals, clinics, lawyers and/or family members. If I do, I will protect this information as set out in this Policy.
4. Use of Your Data
4.1.Personal Information (other than Sensitive Information) collected by Harmonics Psychology will only be used and disclosed for the purpose it was collected. This includes maintaining your account and contact details, providing you with psychological services (which include assessing, diagnosing and treating your presenting issue), providing clinical supervision and processing payments.
4.2 Personal information is retained in order to document what happens during sessions and to enable me to provide a relevant and informed psychological or supervision service. I also use it for related business activities, such as Medicare claims and payments, practice audits, and business processes. Therefore, it may be necessary for me to disclose your personal information to third parties or contractors who are integral to the provision of my services.
4.3. Harmonics Psychology may use Personal Information collected from you to provide you with information, updates, services or make you aware of new services available to you.
4.4. Harmonics Psychology may use your Personal Information to improve our services and better understand your needs.
4.5. Harmonics Psychology may contact you by a variety of measures including, but not limited to, telephone, email, text message or mail.
4.6. Harmonics Psychology may from time to time use your Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act. This includes to effectuate or enforce a transaction, or procure advice from legal and accounting firms, auditors and other consultants.
5. Disclosure of Your Data
5.1. Other than in the course of providing psychological services or as otherwise described in this policy, I will not share personal information to third parties without your consent.
5.2. Personal Information is only supplied to a third party when it is required for the delivery of our services. I share personal information with third parties who work with me for business purposes, such as information technology providers, insurers, accountants, auditors, professional advisers, and lawyers – these third parties are required to comply with APPs and this policy.
5.3. I may provide health information (Sensitive Information) to other medical service providers, such as your general practitioner or specialist medical practitioners. I 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 by law.
5.4. I will share your personal information under the following circumstances:
5.4.1. When it is required for the delivery of mental health services, information is provided to healthcare providers such as GPs, psychiatrists, other specialist medical practitioners, parents, employer, third-party funders such as Medicare and EAPs, and clinical supervisors of my work.
5.4.2. When it is required for the delivery of clinical supervision services, information is provided to third parties such as training institutions or associations (e.g., evaluation reports).
5.4.3. When I am required to write a report to another agency or professional, e.g., a GP or a lawyer.
5.4.4. When I am required to disclose to another professional or agency (e.g., your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which your personal information was collected.
5.4.5. When it is required or authorised by law (e.g., court subpoenas, warrants, legal proceedings or in response to a request from a law enforcement agency).
5.4.6. When it is necessary to lessen or prevent a serious threat to your life, health or safety; someone else’s life, health or safety; public health or safety; or it is impractical to obtain the patient’s consent.
5.4.7. To assist in locating a missing person.
5.4.8. To establish, exercise or defend an equitable claim.
5.4.9. For the purposes of confidential dispute resolution processes.
5.4.10. When there is a statutory requirement to share certain personal information (e.g., some diseases require mandatory notification).
5.5. Harmonics Psychology may use your Data to protect the copyright, trademarks, legal rights, property or safety of the Practice (www.harmonicspsychology.com.au), its clients or third parties.
5.6. I do not disclose your information in the following ways:
5.6.1. Sell or trade your personal information to any third party.
5.6.2. Upload any patient information to any shared eHealth services (e.g., My Health Record).
5.6.3. Other than in the course of providing psychological or supervision services or as otherwise described in this policy, I will not share personal information with any third party without your consent.
5.6.4. Share your personal information with anyone outside Australia without your consent unless such disclosure is otherwise required by law.
5.7. Information that I collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.
5.8. By providing me with your Data, you consent to the terms of this privacy policy and the types of disclosure covered by this policy. Where I disclose your Personal Information to third parties, I will request that the third party follow this policy regarding handling your personal information.
6. Security of Your Data
6.1. Harmonics Psychology is committed to ensuring that your Data is secure.
6.2. I will take reasonable steps to protect your Data from misuse, loss, unauthorised access and modification or disclosure.
6.3. I use commercially reasonable physical, technical and administrative measures to protect Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our website.
6.4. Harmonics Psychology handles all information digitally and is a paperless service. All information collected in sessions is stored electronically in pdf/jpg format in secure cloud-based storage (iCloud Drive) for the purposes of therapy.
6.5. Information that is collected administratively for the provision of your care at Harmonics Psychology (e.g., invoices, GP letters, NDIS reports, supervision reports) is stored using secure electronic platforms.
6.6 Secure electronic platforms are also used for processing (e.g., payments, Medicare claims and assessment questionnaires) and communication purposes (e.g., emails, efaxes and Telehealth).
6.7. I take reasonable steps to ensure the security and safety of the systems I use and the data I store. I use 3rd party systems and services to provide my services to you. These 3rd party systems have their own security and safety protocols in place, however I am not able to directly affect, influence or assess their protocols.
6.8. Despite taking appropriate measures to protect your Data used and collected by me, please be aware that no data security measures can guarantee 100% security all of the time. The transmission and exchange of information is carried out at your own risk.
6.9. I cannot guarantee the security of your Data that you transmit to me, or receive from me. Although I take measures to safeguard against unauthorised disclosures of your Data, I cannot assure you that your Data we collect will not be disclosed in a manner that is inconsistent with this privacy policy.
6.10. Digital communication methods such as email, SMS, and efax are not secure. There are inherent confidentiality risks. While safeguards are in place to ensure your privacy, digital communication always presents a risk of data privacy issues.
6.11. I do not have control over information I am obliged to share with others such as GPs, psychiatrists, and allied health practitioners. For example, a GP may forward my Medicare letters to another health professional, or upload them a shared electronic eHealth service such as My Health Record.
6.12. You are solely responsible for maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
6.13. If you receive communications from me 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.
7. Access to Your Data
7.1. I encourage you to contact me to keep your personal information up to date.
7.2. You have the right to request access to, and correction of, your personal information kept on file. You may request details of your Data that I hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). By law, I may discuss the contents with you and/or give you a copy, subject to the exceptions in the Privacy Act 1988 (cth).
7.3. If you would like a copy of your Data which we hold about you or believe that any of your Data I hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email me at reception@harmonicspsychology.com.au.
7.4 All requests for access to or correction of personal information held will be responded to in writing within a reasonable time frame, and an appointment will be made if necessary for clarification purposes. An administration fee may be payable for the provision of information.
7.5. I reserve the right to refuse to provide you with information that I hold about you, in certain circumstances set out in the Privacy Act. For example, if required by law or where the information may be related to existing or anticipated legal proceedings, I may deny you request, setting out reasons for the refusal in writing.
8. Website
8.1. When you visit the website of Dr Jackie Cesareo, Harmonics Psychology (www.harmonicspsychology.com.au) I may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.
8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
Cookies
8.3. When you interact with my website, I strive to make your experience easy and meaningful. I, or my 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. I may combine this data with the Personal Information I have collected from you. 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
8.4. At times, my website may contain links to other, third-party websites. Any access to and use of such linked websites is not governed by this 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.
9. Complaints about Privacy
9.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to: reception@harmonicspsychology.com.au
9.2. I take complaints and concerns regarding privacy seriously. Upon request you can obtain a copy of the Australian Privacy Principles, which describe your rights and how personal information should be handled. You should express to me any privacy concerns you may have in writing. I will respond shortly after receiving written notice of your complaint and attempt to resolve the issue. Please send details of your complaint to me at PO Box 90 Floreat WA 6014.
9.3. If you are not satisfied with my response, then you are entitled to lodge a formal complaint about the use of, disclosure of, or access to, your personal information. You may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at https://www.oaic.gov.au/privacy/privacy-complaints or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW, 2001.
10. Changes to Privacy Policy
10.1. This policy will be reviewed regularly to ensure it is in accordance with any regulatory changes that may occur. It will be altered if necessary. I may modify this policy at any time at my sole discretion, and all modifications will be effective immediately.
If, after reading this Policy you are at all unclear about any of the information provided, please contact Dr Jackie Cesareo prior to your appointment.