Privacy Policy

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Blue Harbour Counselling is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other relevant state laws about the management of personal information. This Privacy Policy applies to the personal information I handle about clients and prospective clients of my counselling practice that uses or has used my services and facilities, visitors to my website www.blueharbourcounselling.au users of services I provide and members of the public. This Privacy Policy should be read together with my Terms & Conditions. By accessing my website or using my services, you agree to be bound by the terms of this Privacy Policy.

Definitions

References to “Blue Harbour Counselling”, “I”, “me” and “my” are references to Patricia Mallon trading as Blue Harbour Counselling (ABN: 43 660 469 725). References to “you” and “your” are references to any individual about who I collect personal information. References to “counsellor” are references to me as counsellor at Blue Harbour Counselling providing counselling services.

Personal Information

When used in this Policy, “personal information” has the meaning given in the Privacy Act. Generally, it means any information or an opinion that could be used to identify you. Sensitive information is personal information that includes information or an opinion about, for example, your health, criminal record, sexual orientation, religious or philosophical beliefs, racial or ethnic origin, and political opinions.

What personal information I collect about you

At all times, I try only to collect the personal information I need for the particular function or activity I am carrying out. When you enquire about my counselling services, I may collect your full name, date of birth, email address, phone number, and other personal information, including sensitive information, to help me assess whether any counselling service provided by me is an appropriate service for you and send you information or resources. I collect additional personal information about you, including sensitive information, when you book an appointment with me and during the course of counselling sessions with me, for example, your address, emergency contact person, social and medical history. 

I will not collect your credit card details and details of third parties involved in the management or funding of your appointments, for the purposes of administering your appointments payment arrangements.

I may collect personal information about you if you are a healthcare professional or healthcare service provider who have referred a client to me, such as your name, medical speciality or position within the organisation your work for, and your contact details.

I may collect personal information about you if you interact with me on a commercial basis, or as a member of the public. The kind of personal information I collect will depend on the capacity in which you are dealing with me. Generally, it would include your name, your contact details, details and information regarding our interactions and transactions with you and details such as professional registration numbers, insurance certificates, among others.

How I collect your personal information

I will, where practicable, collect information directly from you. I collect your personal information mainly when you deal with me over the phone, have contact with me in person, give or send me a letter or document or when you interact with me online via my website (such as www.blueharbourcounselling.au), email, SMS, and social media channels (please note that social media channels will handle your personal information for their own purposes and have their own Privacy Policy). I may also collect personal information about you, including sensitive information, indirectly from other sources such as your GP or other healthcare professionals, government agencies administering your entitlements and benefits, a carer, a legal professional or a person responsible for your healthcare decisions. If you want to share information that includes another person’s information in which that person will be identifiable, you must seek permission from the individual and let them know about our Privacy Policy.

How I hold your personal information

Your personal information held by me is maintained in a secure environment, which can be accessed only by me. I take reasonable steps to protect the security of the personal information I hold, by:

· ensuring physical security over my paper and electronic data stores, such as locks and security systems, is maintained and enhanced where possible

· maintaining security systems, for example, by using a firewall, and using passcodes to control access to electronic devices, to access electronic systems taking reasonable steps to destroy or de-identify your personal information once I no longer need it conducting regular privacy and data security audits to assess whether I have adequately complied with and implemented these measures.

However, no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully secure. Additionally, I am unable to ensure the security of personal information that is left with you or provided to you, for example, a paper-based report or email sent to you.

Why I collect your personal information

I collect your personal information to carry out functions or activities such as:

· Providing services and facilities to me as a counsellor;

· Assessing whether I can provide an appropriate service for you;

· Sending you communications via SMS or email to, for example, remind you about appointments with me, provide you with treatment resources and questionnaires and send you a copy of your invoices;

· Responding to your enquiries, requests or feedback; and

· Updating your records and keeping your information up to date.

If you have any concerns about the personal information I have asked you to provide please let me know.

Disclosure of your personal information

There are circumstances where I may be permitted or required by law to disclose your personal information to third parties. Common situations in which I may disclose your personal information to third parties are when:

· You have consented to the disclosure; or

· I reasonably believe that disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, including yours or to public health or safety; or

· You would reasonably expect your personal information to be disclosed and disclosure to that third party is for a purpose directly related to the primary purpose for which your personal information was collected (see Why we collect your personal information), for example, to the ambulance service; or

· It is required or authorised by or under Australian law or a court/tribunal order.

I engage external service providers to us for the purposes of providing services to me as your Counsellor and managing my business, including software providers, payment systems operators, IT and data security service providers, website hosting service providers, my insurers, and my professional advisors such as accountants and lawyers. Your personal information may be used and disclosed to them to facilitate these arrangements.

Your personal information will not be used, sold, rented or disclosed for any other purpose. Some of the information collected by me may be stored in systems that utilise data hosting facilities outside of Australia. 

Collecting your personal information through my website

My website, www.blueharbourcounselling.au uses Google Analytics, a service that transmits website traffic data to Google servers in the United States and possibly other locations outside of Australia. Google Analytics does not identify individual users or associate individual IP addresses with any other data held by Google.

I use reports provided by Google Analytics to help me understand website traffic and patterns of usage by users on my website, to help me improve my website and its content. By using my website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy https://policies.google.com/privacy. You can opt out of Google Analytics if you disable or refuse cookies, disable JavaScript, or use the opt-out service provided by Google.

My website may contain links to third-party websites and links to my social media profiles such as Facebook, Instagram, Pinterest, Linkedin and YouTube. I am not responsible for the content or privacy practices employed by websites that are linked from my website. You can access their Privacy Policy on their respective websites.

Access to personal information and correction

You can ask for access or correction of your personal information, if you believe it to be inaccurate, in writing and I must respond within 30 days. I may ask you to verify your identity before I give you access to your information or correct it, and I will try to make the process as simple as possible.

Access to your personal information may be declined in accordance with privacy laws, for example, where giving you access would put you or another person at risk of harm. In this circumstance, I must notify you in writing setting out the reasons. I do not provide copies of information records without a court subpoena if they contain sensitive information that may be harmful if read without a Counsellor present to explain the information appropriately. Where a person requesting access to your personal information is an authorised representative of yours, such as a lawyer or guardian, I will ask the representative to provide evidence of their authority. I may also ask you to provide current and informed consent to me before releasing your personal information.

I take reasonable steps to ensure that the personal information I hold about you is accurate, up-to-date and complete. If you believe it to be incorrect or out of date you can ask that I correct it. If it is not possible for me to correct it, you can ask me to associate with it, for example, attach or link a statement that you believe the information is incorrect and why. If I make a correction and I have disclosed the incorrect information to others, you can ask me to tell them about the correction. I must do so unless there is a valid reason not to.

Concerns and complaints about your privacy

You may contact me at any time if you have any questions or concerns about this Privacy Policy or how your personal information has been handled. If you have a complaint about how I have handled your personal information, please contact me in writing. I will tell you promptly that I have received your complaint and then investigate and respond to the complaint within 30 days. I will determine what (if any) steps I should take to resolve the complaint. If you are not satisfied with my response, you may lodge a complaint with the Office of the Australian Information Commissioner. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

In the event of any unauthorised access or unauthorised disclosure or loss of your personal information that is likely to result in serious harm to you or other individuals, I will investigate and notify you and the Office of the Australian Information Commissioner in accordance with the Privacy Act.

Changes to this Privacy Policy

I will update this Privacy Policy when my information handling practices change. Any information I hold about you will be governed by my current Privacy Policy. I recommend that you periodically review this Privacy Policy for any changes. 

Date updated: 04.10.2022