Version 3 – 13 March 2019

Privacy Policy

1.       Introduction

Protecting your privacy

Your privacy and maintaining the confidentiality of your personal information is important.  We view it as an extension of our commitment to building a safe place for our clients that honours and respects them in full and that honours the trust they have placed in us over many years.

This Privacy Policy sets out how we care for your personal information, including the collection, storage, use and disclosure of your personal information, and how, if it is needed you can access and change your information, provide us with feedback, or possibly, make a complaint.

We treat our obligations under this Privacy Policy very seriously.  In addition, we comply with our obligations under various privacy legislation, including:

1. the Privacy Act 1988 (Cth) (and the Australian Privacy Principles under that Act);
2. health records legislation, including the Privacy and Data Protection Act 2014 (Vic), Health Records Act 2001 (Vic), Privacy and Personal Information Protection Act 1998 (NSW) and the Health Records and Information Privacy Act 2002 (NSW); and
3. marketing legislation, including the Spam Act 2003 (Cth).

2.       Collection of your personal information

2.1       What kinds of personal information do we collect?

The extent and type of personal information that we collect and hold about you will vary depending on whether you are an existing client, have attended one of our courses or presentations, made inquiries about our services or purchased one of our products, and the extent to which you might have used our services.

If you are currently or have in the past been a client of ours or attended one of our courses or presentations, then the personal information that we hold about you may include:

• your name, address, telephone and email address;
• your gender, date of birth and marital status;
• your billing details;
• in the event that you are or have been a client we will have on file (as part of our Code of Practice) confidential and secure session attendance notes;
• details of sessions, courses or presentations you have attended.

In general, we do not hold information about anyone who is not a client or has not attended one of our courses or presentations.  However, if you have previously contacted us to make an inquiry about our services or attending an event we could hold the information you gave us at that time.

In addition, where a client or someone attending one of our courses or presentations provides us with information about someone else, or where another person is designated to act on behalf of a client or someone attending an event of ours, we may hold that person’s information.

By voluntarily providing us with information about you, you are consenting to our use of it in accordance with this Privacy Policy, but only in accordance with this Privacy Policy.

2.2       Do we collect sensitive information?

For some of our services, we may be required to collect and hold sensitive information of yours.  For example, if you have had a counselling session with us, we would collect and hold information about you in client notes as part of our duty of care, our Code of Professional Practice, and for the purposes of ensuring continuity in our sessions.

2.3       How do we collect personal information?

We may collect personal information from you in a range of ways, including:

• when you book a session or register to attend one of our courses or presentations;
• when you contact us in person, by phone, via mail, email or online; and
• when we contact you through any means.

We will always try to collect your personal information directly from you.  However, there may be instances where we collect your information from other people or organisations. For example, if you are under the age of 18 and your parent or guardian is booking a session for you, we may collect information about you from them, although in such cases, we will only do so with the prior written consent of both parents or guardians.

If you have provided us with information about another person, then you need to tell that other person that you have done so, and that they have a right to access their information, and can refer to this Privacy Policy for information on how we will handle their personal information.

2.4       If you do not provide us with your personal information

If you do not provide us with the personal information we have asked you for, we may be unable to provide you with the services that you are requesting.

3.       Use and disclosure of your personal information

3.1       How do we use your personal information?

We will use your personal information only in accordance with this Privacy Policy.

If you give us your personal information for a certain reason, we may use the personal information in connection with the reason for which it was provided.  For instance, if you contact us by email, we will use the personal information you provide to answer your question or respond to your request.

Also, if you provide us your personal information in order to obtain access to our services, we will use your personal information to provide you with access to such services and to monitor your use of such services.  We may also use your personal information and other information collected through our services to help us improve the content and functionality of our site and services.

We may use this information to contact you in the future to tell you about services that we believe will be of interest to you. If at any time you do not wish to receive any future communications or to have your name deleted from our mailing lists, you can contact us at any time to let us know.

Our contact details are at the end of this policy.

In you accessing our services, we may use your information to:

• process a booking for a session;
• process your registration to attend one of our courses or presentations;
• process payments;
• contact you in relation to any relevant matter relating to you or our services to you;
• identify whether you may be interested in attending one of our courses or presentations;
• contact you to advise you of upcoming courses or presentations;
• conduct research and evaluation of our services;
• carry out internal functions, including administration, and accounting;
• monitor and evaluate our services;
• conduct client surveys;
• comply with laws and regulations.

3.2       Direct marketing and client communications

From time to time, we may contact you to provide you with information about other services offered by us that may be of interest to you or your friends and family.  This includes information about courses, presentations, audios or other services that relate to topics of interest that you may have previously indicated you would like to know about, such as, how to build, strengthen and evolve loving relationships or support your health and well-being at a deeper level. When we contact you it may be via mail, phone, email or SMS.

When you attend a session or take part in one of our courses or presentations, you consent to us using your personal information for direct marketing purposes (such as a bi-annual newsletter posted on our website), unless you withdraw your consent.

If you do not wish to receive marketing material from us, you can contact us at any time to let us know. Our contact details are at the end of this policy.

If you tell us that you do not want to receive marketing material, we will still contact you in relation to any on-going relationship that you are engaged in with us.  For example, we will still send you any payment requests and notices relevant to the services you receive from us.

3.3       Special workshops, courses and other programs

We are committed to delivering people a range of workshops, courses, audios and other programs which are designed to support people wanting to build harmonious loving relationships and support their well-being.

We may use the personal information (including health information) collected about clients to design and offer a range of workshops, courses and other programs that could benefit specific clients and to identify people who could potentially be interested in attending such events.

Some workshops, courses and other programs will be made generally available to all clients through our website, newsletters and other communications.  In other instances, an event may be tailored to meet the needs of specific clients who are likely to benefit from such an event, in which case, there may arise occasions where we contact clients to offer a specific program.

3.4       Who do we disclose your personal information to?

In order to allow us to provide our services to you or as part of our duty of care, we may be required to disclose your information to third parties.  This may include disclosure in the following circumstances:

any people or organisations engaged by us or acting on our behalf in relation to the delivery of our services, such as service provider or suppliers;
any one acting on your behalf, including trustees or legal representatives;
where disclosure is required by law, including compulsory notices from courts of law, tribunals or government agencies
where required by legislation, for instance mandatory reporting.
If (which is possible as we use a cloud-based server) we send your personal information outside of Australia, we will require that the recipient of the information comply with Australian privacy laws and our contractual obligations to maintain the security of the information. This is necessary as part of complying with obligations under the Australian Privacy Principles.

3.5       How do we store personal information and for how long?

We will take all reasonable care to ensure that your personal information is protected, remains confidential and is stored securely.  This includes our adopting a range of systems and communication security measures, as well as the secure storage of copies of any documents we hold recording information about you.

In addition, because your personal information is held confidentially, access to this information will be restricted to only people properly authorised to have access.  We keep your personal information only for as long as we need it to provide you with the services you requested from us and to comply with our legal obligations.

If we no longer need to store your personal information for any purpose, including legal purposes, we will take reasonable steps to destroy or de-identify your personal information in a secure manner.

4.       Counselling and bodywork clients and people attending workshops, etc

This section outlines how your information will be handled if you attend a counselling and or bodywork session, or a workshop or course that we offer.

 4.1      What information is collected if I attend a session or a workshop or course?

When you attend a counselling and or bodywork session with us or attend one of our workshops or courses, we will only collect your personal information for the purposes of offering our services to you, and to ensure that our services are provided to you in accordance with our policies and procedures, duty of care and Code of Conduct.

When you attend a counselling and or bodywork session with us or take part in one of our workshops or courses or use any of our related services, the information that we may collect includes:

• your name, address, telephone number and email contact details;
• your gender and date of birth;
• health information, which includes the treatments you have had or are planning to have, health conditions or ailments that you have suffered or may be at risk of suffering, and any other information that is relevant to your health and well-being;
• name and contact details of any person authorised to act on your behalf when speaking with us (known as a Health Partner or Personal Representative);
• details of any correspondence and resources that we have sent you, such as brochures, information sheets or videos;
• details of any conversations we have had with you; and
• records of our interactions with you, including (but not limited to) client session notes.

4.2       How will my information be used or disclosed?

When you attend a counselling and or bodywork session with us or take part in one of our programs or related services, we may use your personal information for the purposes of offering and providing services to you.

We may use your personal information to:

• contact you to advise you about upcoming programs;
• conduct customer satisfaction surveys and to otherwise evaluate our services;
• conduct marketing, research and statistical analysis;
• comply with any laws or regulations, including mandatory reporting legislation.

In addition, we may use de-identified information to conduct data analytics and to identify clients who might be interested in attending one of our tailored programs.

In the course of providing services to you we may disclose your personal information:

• to any person authorised to act on your behalf (including a Health Partner or Personal Representative);
• where required, to a regulatory authority over any part of our business or affairs; and
• where we are required or permitted by law to do so, including where we reasonably believe that disclosure is necessary to lessen or prevent a serious and imminent threat to life, health or safety of you or of another person.

5.         Accessing and correcting your personal information

5.1       Can I access my personal information?

You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request.  We will endeavour to meet your request for access within a reasonable time and in the manner requested by you.  However in some circumstances, we may be unable to give you access to information, such as where:

• we no longer hold or use the information;
• providing access would have an unreasonable impact on the privacy of others;
• the request is frivolous or vexatious;
  the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
• providing access would be unlawful;
• denying access is required by law;
• providing access would be likely to prejudice the prevention, detection,
• investigation and prosecution of possible unlawful activity;
• where access would pose a threat to the life or health of any individual.

If we are unable to give you access to the information you have requested, we will give you written reasons explaining why we are unable.

If you have any concerns about the refusal, please see section 7.1 for further information.

5.2       Correcting your personal information

To enable us to provide you with the best service that we can, it is important that the personal information we hold about you is accurate.  We will take reasonable steps to ensure your information is accurate, complete and up-to-date at the time of collecting, using or disclosing it.

However, you should also notify us when your details change.

If you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us. We will take reasonable steps to amend your records.

6.       Your privacy online

6.1       Online data collection and use

When you access our website, we collect certain anonymous technical information about user activities on the website.  This information which is collected using various technologies cannot be used specifically to identify you.  The information collected may include information such as the type of browser that you use to access our website and the pages that you have visited.

We may store such information ourselves or such information might be included in databases owned and maintained by our service providers.  We may use this this information and pool it with other information to track, for example, the total number of users of our online services, the number of visitors to each page of our website, the domain names of visitors’ Internet service providers, and how our users use and interact with our website and online services.

6.2       Cookies and analytics

In operating our website and online services, we may use a technology called “cookies.”  A cookie is a piece of information that the computer that hosts our services gives to your browser when you access our services.  Cookies in themselves do not identify the individual user, just the computer used.

Using cookies helps provide additional functionality to our website and helps us analyze usage of our services more accurately. For instance, setting a cookie on your browser allows you to access our services without needing to enter a password more than once during a visit to our site.  It will also allow us to determine which pages are of most interest for people visiting our site.  In all cases in which we use cookies, we will not collect personal information except with your permission.

On most web browsers, you will find a “help” section on the toolbar.  Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.  If you decide not to display cookies, then you may not be able to gain access to all the content and facilities of this website.  Accordingly, we recommend you leave cookies displayed.

7.       Contacting us

7.1       Your feedback

If you have any questions, feedback or concerns about this policy or how your information is handled by us, or you require further information relating to privacy and our work and the services that we offer, you can contact us at any time.

If you are not happy with our response, you are able to seek advice from the Office of the Australian Information Commissioner by calling 1300 363 992 from within Australia. If calling from outside Australia +61 2 92849749.