Soteria Consulting Pty. Ltd.
PRIVACY POLICY

Soteria Consulting Pty. Ltd. ABN 24100778005 in its own right (“we”, “our” or “us”), complies with the Privacy Act 1988 (Cth) (“Privacy Act”) and the applicable Privacy Principles in the Privacy Act when handling personal information, together with the Health Records Act 2001 (Vic) (“Health Records Act”) and the applicable Health Privacy Principles in the Health Records Act when handling personal information which is health information (“Health Information”).
We take the protection of your personal information seriously. Personal information includes any information or opinion, whether true or not, about a person who is identified or whose identity can reasonably be established.

Collection:
We and our psychologists collect personal information for the purposes of arranging appointments and delivering counselling services as well as communicating with you. We may collect information through our client intake and consent forms, or in the course of our psychologists undertaking counselling services in consultation and treatment of clients.
We collect personal information:
• from clients– when they register an enquiry, book an appointment, attend our practice, access our Website, subscribe to our newsletter, and/or at any other time from time-to-time in the course of our psychologists providing counselling services;
• from third party service providers – when they are engaged to supply services to us (such as but not limited to psychologists), provide information to us or invoice us for the provision of services;
• when we receive enquiries through the Website and when the Website is otherwise accessed or used;
• when we receive enquiries via email or telephone.

The kind of personal information we may collect will depend on who you are (e.g. a client or third party service provider) and the nature of your interaction with us, and may include your full name, address, email address, date of birth, Medicare details, billing information, general appointment information and other personal information. If you do not provide us with all the information we request, our psychologists may not be able to deliver the counselling services.
Our psychologists may also collect your personal information in the manner and for the purposes contemplated above.
Some personal information we or our psychologists collect may include Health Information. We collect Health Information from clients when they attend our clinics for the purposes of arranging appointments and obtaining counselling services. Our psychologists collect Health Information in order to provide the counselling services. How your Health Information is dealt with is outlined in greater detail below.
The Health Information we collect enables us to arrange for the provision of counselling services and for the safe, appropriate and accurate provision of counselling services by our psychologists, to assess the needs of clients in the provision of counselling services and for us to generally assist in optimising the quality of our service.

Consent:
By engaging us or registering your details on our Website or by email or telephone, and/or using the Website or completing a client consent form or otherwise engaging our counselling services, you consent to us and our psychologists collecting, using and disclosing your personal information (including Health Information) for the purposes specified in this Privacy Policy.

Use:
We may use any personal information collected (excluding Health Information) to provide our counselling services, operate the Website, sign you up to our newsletter, respond to feedback and complaints, communicate with third party service providers or if needed to enforce our Client agreement (Client Consent Form) with you. If you are a third party service provider, we will use your personal information to communicate with you including to accept your offer to provide services, correspond with you in relation to the provision of services and to pay your invoices.

Health Information
We and our psychologists comply with the Health Privacy Principles and the Ethical Guidelines of the Australian Psychological Society http://www.psychology.org.au/about/ethics in the collection, use and disclosure of all Health Information and to ensure that all Health Information is kept strictly confidential.
We and/or our psychologists may collect your Health Information when you attend our practice and/or at any other time from time-to-time in the course of arranging the provision of counselling services.
Our psychologists also collect your Health Information:
• as necessary for the provision of counselling services, including recording personal information and Health Information which is relevant to your current situation for the purposes of assessment and diagnosis in your client notes,
• only as necessary for the provision of counselling services, or as otherwise in accordance with your consent, or as may be required by law including Court order;
• only from our clients (or from someone authorised by them) (including a caregiver if you have one);
• with care, taking all steps as may be reasonably necessary to ensure your information remains confidential and that any persons it is disclosed it to in accordance with this Privacy Policy are also required to keep it confidential in accordance with the duty of care to you and in accordance with the Ethical Guidelines of the Australian Psychological Society http://www.psychology.org.au/about/ethics/
• with accuracy, on the basis that you may at any time request a copy of the Health Information that we or our psychologists hold by emailing us at info@soteriaconsulting.com (subject always to applicable law) and where our records are found to be inaccurate, we will rectify any inaccuracies on the basis of the further information you provide. A fee may be charged.

Disclosure and sharing:
We will only disclose personal information to additional third parties with your consent in accordance with this Privacy Policy or if permitted or authorised to do so by law.
Data security and quality:
We will take reasonable steps to protect the personal information we collect and hold from misuse, loss and interference and from unauthorised access and modification, and to make sure it is accurate, complete and up-to-date when we collect, use or disclose it.
To assist us, please ensure you provide us with your correct details, and let us know if you believe the information we have about you is inaccurate, incomplete, out of date or misleading (and we will take reasonable steps to correct the information). We may take steps to destroy or permanently de-identify information when it is no longer needed for any purpose for which it may be used or disclosed. We may retain and use de-identified information.
Our Website: www.soteriaconsulting.com

Cookies:
Our Website may use “cookies”; technology to store data on your computer using the functionality of your browser. Many websites do this because cookies allow the website publisher to do useful things like find out whether the computer has visited the site before.
You can modify your browser to prevent cookie use – but if you do this our service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of behaviour of visitors to the Website.
In the course of serving advertisements to the Website (if any), third-party advertisers or ad servers may place or recognise a unique cookie on your browser. The use of cookies by such third party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.
Access, correction and complaints:
You can request, and we will provide you with access to, any personal information we hold about you (including any Health Information) (subject to any applicable legal exceptions). Please also let us know if you have any concerns or complaints about the way we are handling your personal information so we can address them. Requests should be submitted by email to info@soteriaconsulting.com. Where our records are found to be inaccurate, we will promptly rectify any inaccuracies on the basis of the further information you provide.

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.

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.soteriaconsulting.com. Depending on the nature of the change, we may announce the change on the www.soteriaconsulting.com 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 info@soteriaconsulting.com

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