Privacy Policy for Open Perspectives Psychology
1. Introduction
We are committed to protecting the privacy and confidentiality of your personal information. This Privacy Policy explains how we collect, use, and protect your data in line with Australian privacy regulations, the Australian Psychological Society (APS) guidelines, the Australian Health Practitioner Regulation Agency (AHPRA) standards, and relevant competency standards.
2. Types of Personal Information We Collect
We collect and store the following types of personal information for the purpose of providing psychological services:
- Personal Details: Name, contact information, date of birth, etc.
- Health Information: Psychological assessments, session notes, treatment plans, and progress reports.
- Video Recordings: If you explicitly consent to recording during sessions for supervision or training, these will be stored and handled as per your consent.
3. How We Use Your Information
Your information is used solely for the purpose of providing psychological care, including:
- Conducting assessments and therapy sessions.
- Communicating with you about appointments, treatment plans, and progress.
- Sharing information with your consent, as described in our consent form.
4. Data Retention
We retain your information for a period of 7 years after the completion of treatment, as required by the Privacy Act 1988 (Cth) and informed by APS and AHPRA guidelines. For clients from Indigenous communities, a longer retention period may apply. Once the retention period has ended, your data will be securely deleted from our systems.
- Contingency Access: In case of my incapacitation, arrangements for a nominated psychologist peer to access client records will be made, with your prior consent.
5. Data Sharing and Disclosure
We will share your information only with your consent or in the following circumstances:
- Referrals: Information shared with other health professionals or referrers as part of your treatment, with your explicit consent.
- Serious Risk of Harm: If there is an immediate risk of harm to you or others, we may disclose your information to appropriate third parties.
- Legal Requests: If required by law, such as in the case of a subpoena, we will disclose information as necessary.
6. Data Security
We use compliant services like Google Workspace and Zanda (see Third-Party Services, below) to store your data securely. We implement the following measures:
- Encryption: All client data is encrypted in transit and at rest using industry-standard encryption protocols.
- Access Control: Only I, and my supervisor with your consent for video-recorded sessions, have access to your information. Contingency access arrangements are in place if needed.
- Regular Updates: I ensure that my devices and software are regularly updated to protect against security vulnerabilities.
- Physical Security: Paper records, if used, are shredded within one week.
7. Data Breaches
In the unlikely event of a data breach, we will follow the Notifiable Data Breaches Scheme. This includes notifying you and the relevant authorities within 30 days of discovering the breach, in accordance with Australian privacy laws.
8. Third-Party Services
Our practice utilises several third-party platforms to manage, store, and process client data. Below is an overview of these services and their compliance with Australian privacy standards:
- Zanda (Practice Management Software): A certified platform that complies with the Australian Privacy Principles (APPs) for storing client records and managing practice operations.
- Google Workspace (Productivity and Communication Tools): Google Workspace, which complies with Australian privacy standards, provides email, document storage, and communication tools. For further details, refer to the Google Cloud whitepaper on security and privacy.
- Psychometric Assessment Platforms: We use the following third-party platforms to administer psychometric assessments and track client outcomes. These platforms comply with relevant privacy standards, including the Australian Privacy Principles (APPs), except where noted:
- NovoPsych/NovoNote: An Australian-based platform for psychometric assessments (NovoPsych) and note/document writing (NovoNote), fully compliant with APPs. We do not currently use the audio transcription feature of NovoNote and would seek client consent before doing so.
- PAA/MHS Assessment Centre+ (MAC+): An Australian-based platform for administering various psychometric assessments, aligned with APPs.
- Gottman Connect: A platform for administering relationship assessments developed by The Gottman Institute. While Gottman Connect complies with U.S. regulations such as HIPAA, it does not explicitly confirm compliance with Australian privacy laws. We recommend clients review Gottman Connect's privacy policy for further information.
- Healthlink - for secure receipt of documents from referrers such as GPs and psychiatrists, fully compliant with APPs.
- GoFax - integrated with Zanda for secure transmission of documents (e.g. to referrers), fully compliant with APPs.
9. Your Rights
You have the right to:
- Access: Request a copy of the information we hold about you.
- Correction: Request corrections to any inaccurate or incomplete data.
- Withdrawal of Consent: You can withdraw your consent for data collection or sharing at any time, except where required by law.
10. Data Retention for Indigenous Clients
In recognition of the historical impact of the Stolen Generations and the trauma caused by the loss of information about family histories, it has been suggested by cultural sensitivity guidelines and ethical practices (e.g., APS, AHPRA) that records for Indigenous clients be retained for a period of 10 years or longer. We invite Indigenous clients to express their preference regarding the retention of their personal data, and we will respect their wishes in line with our commitment to cultural sensitivity and client autonomy.
11. Contact Us
If you have any questions about this policy, or if you would like to access or correct your information, please contact us at:
admin@openperspectives.com.au