Privacy Policy

PRIVACY COLLECTION NOTICE

This Privacy Collection Notice describes how SWN Co Pty Ltd t/a Nurtured Thoughts Psychology ABN 41 653 561 810 we, us or our collects and handles your personal information when you make an enquiry with us.

We collect personal information from you so that we can respond to your enquiry and for related purposes set out in our Privacy Policy, available on our website or on request.

We may disclose this personal information to third parties, including our personnel, related entities, service providers, contractors, professional advisers, healthcare providers and any third parties engaged by us and acting on our behalf, and as otherwise set out in our Privacy Policy.

We store personal information in Australia. Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information outside Australia.

If you do not provide your personal information to us, it may affect our ability to do business with you or provide services to you.

Please see our Privacy Policy for more information about how we collect, store, use and disclose your personal information, including health information, details about overseas disclosure, access, correction, how you can make a privacy-related complaint and our complaint-handling process.

If you have questions about our privacy practices, please contact us by email at:

admin@nurturedthoughts.com.au

By providing your personal information to us, you agree to the collection, use, storage and disclosure of that information as described in this Privacy Collection Notice and our Privacy Policy.

PRIVACY POLICY

SWN Co Pty Ltd t/a Nurtured Thoughts Psychology ABN 41 653 561 810 we, us or our is committed to protecting your privacy.

This Privacy Policy explains how we collect, use, disclose, store and protect your personal information. It applies to all personal information we handle, whether collected through our website, by phone, by email, through online forms, through telehealth, in person, or through other means in relation to the business we carry on as Nurtured Thoughts Psychology.

Quick overview

We collect information you provide to us and information we gather when we interact with you.

We use this information to provide our services, manage your care, communicate with you, operate our business and meet legal and professional obligations.

We protect your information using secure systems, access controls and privacy processes.

You have rights regarding your personal information and health information, including access and correction rights.

You may contact us if you have a privacy concern or complaint.

Patient health information and Protected Health Information

As an Australian healthcare provider, we handle patient health information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable Australian health, privacy, professional and record-keeping obligations.

For the purposes of this Privacy Policy, Protected Health Information or PHI means patient health information, sensitive information and clinical records that identify, or could reasonably identify, a patient and relate to their health, healthcare, treatment, prescriptions, payment for healthcare or related healthcare services.

In this Privacy Policy, references to health information include patient health information, sensitive information, clinical records and, where relevant, Protected Health Information or PHI.

Health information may include information about your:

health, symptoms, diagnoses, medications, treatment, referrals, medical history, mental health history, prescriptions, Medicare details, private health insurance details, pathology or radiology results, correspondence from other healthcare providers, appointment history, clinical notes, care plans and records created as part of your care.

We treat health information as confidential medical information and handle it with additional care.

Information we collect

We may collect the following types of personal information.

Basic identifying and contact details

Name
Address
Email address
Phone number
Age and date of birth
Next of kin or emergency contact details
Parent, guardian or carer details, where relevant

Professional details

Professional role or occupation
Employer details, where relevant
Professional registrations, licences or qualifications, where relevant

Service-related information

Services you have enquired about or received
Appointment history
Payment and transaction details for services you have purchased from us
Your preferences for our services
Your marketing preferences
Feedback and survey responses

Digital information

IP address and general location information derived from your IP address
Search and browsing behaviour
Website usage patterns
Cookie preferences
Interactions with our website, emails, advertisements or online services

Professional information for job applicants and workers

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Background checks, where required or permitted by law
Professional memberships, where relevant

Sensitive information and health information

We handle sensitive information with extra care and protection. We only collect sensitive information with your consent or where legally permitted.

This may include:

Health information
Medicare number
Private health insurance details
Individual or family medical history
Mental health history
Treatment reports
Clinical notes
Referring doctor or healthcare provider correspondence
Care plan information, including mental health treatment plans, eating disorder care plans or chronic disease management plans
Symptoms, health concerns, medications, treatment preferences and treatment records
Pathology or radiology records
Prescription information
Real-time prescription monitoring information, where relevant and permitted
Parent, guardian or carer details, where relevant to assessment or treatment
Any other personal information requested by us or provided by you or a third party for healthcare purposes

We may also collect other sensitive information where relevant and lawful, including:

Racial or ethnic origin, where relevant to providing culturally appropriate care
Religious beliefs, where relevant to your care or preferences
Criminal record checks, where required for employment or contractor screening
Professional memberships, where relevant to employment or contractor assessment

How we collect personal information

We may collect personal information:

directly from you when you interact with us, contact us, complete forms, book appointments, attend consultations, use our website or communicate with our team;
automatically when you visit our website, use our technologies, interact with our online services or engage with our digital communications;
from third parties, including referring doctors, other healthcare professionals, pharmacies, pathology providers, radiology providers, hospitals, government services, service providers, business partners, public sources, government organisations and people or organisations authorised by you.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information to run our business and provide our services.

Business operations

To manage our relationship with you as a patient, client, supplier, contractor or worker
To process and deliver our services
To handle enquiries, support requests and communications
To maintain accurate records for billing and administration
To verify your identity when required or permitted by law

Healthcare and clinical services

To assess your health concerns and clinical needs
To provide consultations, assessments, treatment, referrals and follow-up care
To document your care in your clinical record
To communicate with you about appointments, results, treatment plans, referrals and follow-up
To provide prescriptions where medically indicated
To support continuity of care
To communicate with other healthcare providers involved in your care
To manage clinical risk and patient safety

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle enquiries made through our website or platforms
To manage your participation in surveys, feedback sessions or events

Service improvement

To conduct analytics and market research
To improve our business operations and services
To develop and enhance our systems, applications and platforms
To understand how our services are used
To support quality assurance, clinical governance, training and risk management

Marketing and promotions

To send you promotional information about our services and events
To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions and special offers
To provide additional benefits to our patients
You can opt out of marketing communications at any time.

Employment purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment and contractor records
To comply with workplace and professional obligations

Legal and compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business and clinical records
To fulfil regulatory requirements or reporting obligations
To protect our legal rights and interests
To respond to complaints, incidents, legal claims, subpoenas, regulator requests or lawful requests
To comply with health, privacy, professional, insurance and record-keeping obligations

How we use and disclose patient health information

We collect, use and disclose patient health information for the purpose of providing healthcare and related services.

This may include:

assessing your health concerns and clinical needs;
providing consultations, assessments, treatment, prescriptions where medically indicated, referrals and follow-up care;
documenting your care in your clinical record;
communicating with you about appointments, results, treatment plans, referrals and follow-up;
communicating with your treating clinicians, regular GP, specialists, pharmacies, pathology providers, radiology providers, hospitals, emergency services or other healthcare providers involved in your care;
managing billing, Medicare, private health insurance, payment processing and administrative support;
supporting quality assurance, clinical governance, audit, risk management, training and service improvement;
complying with legal, regulatory, professional, insurance, reporting and record-keeping obligations;
responding to complaints, incidents, legal claims, subpoenas, court orders, regulator requests or other lawful requests;
protecting your safety or the safety of others, including in an emergency or where required or authorised by law.

We will only use or disclose your health information for the purpose for which it was collected, a directly related purpose you would reasonably expect, with your consent, or where required or authorised by Australian law.

We do not sell patient health information.

Our disclosures of personal information to third parties

We may disclose personal information to the following parties where reasonably necessary for the purposes described in this Privacy Policy.

Service providers

Administrative support providers
IT service providers
Clinical software providers
Data storage providers
Web hosting and server providers
Payment processors
Marketing and advertising providers
Analytics providers
Communication platform providers
AI, transcription or documentation support providers, where used lawfully and with appropriate safeguards

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers
Accountants
Business advisers

Business partners and contractors

Our existing or potential agents
Our business partners or contractors
Contracted clinicians and administrative personnel
Other parties involved in delivering or supporting our services

Healthcare providers and healthcare-related bodies

Referring medical professionals
Medical professionals that we refer you to, with your authorisation or where otherwise permitted by law
Your regular GP, specialists or treating healthcare providers
Pharmacies
Pathology providers
Radiology providers
Hospitals
Emergency services when necessary
Prescription delivery services, where relevant
Government-based monitoring services, where required or permitted by law

Corporate transactions

If we merge with or are acquired by another company, restructure, or sell all or part of our business or assets:
your information may be disclosed to our advisers;
your information may be disclosed to potential purchasers and their advisers;
your information may be included in transferred business assets, subject to applicable privacy obligations.

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities
Law enforcement officers
Government agencies
Professional bodies
Other parties where required or permitted by law

Other parties

Third parties you have authorised
A parent, guardian, carer or substitute decision-maker, where relevant and lawful
Any other party as required or permitted by law

Overseas disclosure

Storage and access

We store your personal information in Australia. However, your information may be accessed from or transferred to locations outside Australia, including the Philippines and the United States, in circumstances such as:

when our service providers are located overseas;
when we work with overseas business partners;
when using cloud-based services, software platforms or data storage solutions.

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law.

This may include:

only sending what is necessary;
requiring recipients to protect your information through contractual agreements;
requiring recipients to comply with privacy standards in applicable law or comparable safeguards;
monitoring how recipients handle your information where appropriate.

Your rights regarding your health information

You have rights in relation to the personal information and health information we hold about you.

Access to your health information

You may request access to the personal information and health information we hold about you, including your clinical records.
You can request access by contacting us using the details below.
We may ask you to verify your identity before we release any information. We will respond to your request within a reasonable time.
Access may be provided by allowing you to inspect records, providing a copy of records, giving you a written summary, or another appropriate method.
We may charge a reasonable administrative fee for providing access where permitted by law.
In limited circumstances, we may refuse access where permitted or required by law, such as where access would pose a serious threat to health or safety, unreasonably affect another person’s privacy, breach legal privilege, or otherwise be unlawful.
If we refuse access, we will explain the reason where it is lawful and reasonable to do so.

Copies of your records

You may request a copy of your health information or clinical records.

Requests should be made in writing to the clinic and should clearly identify the information requested.

Before providing copies, we may need to verify your identity and confirm whether the records should be released directly to you, to another healthcare provider, or to another authorised person.

Correction or amendment of your health information

You may ask us to correct or amend personal information or health information we hold about you if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

If we agree the information should be corrected, we will take reasonable steps to update the information.

If we do not agree to the requested correction, we will explain why and, where appropriate, allow you to add a statement to your record noting that you requested the correction.

Withdrawal of consent and communication preferences

Where we rely on your consent to use or disclose your information, you may withdraw that consent by contacting us.

Withdrawal of consent may affect our ability to provide some services.

You may also update your communication preferences or opt out of marketing communications at any time.

How to exercise your rights

To request access to your information, request a copy of your records, ask for a correction, update your preferences or raise a privacy concern, please contact us:

Email: admin@nurturedthoughts.com.au
Phone: (07) 3056 0921
Post: 4 Rakeevan Road, Graceville, QLD 4075

Please include your full name, date of birth, contact details, the nature of your request, and enough information for us to identify the relevant records.

We may ask for further information to verify your identity before actioning your request.

Privacy complaints

If you have a concern or complaint about how we have handled your personal information or health information, please contact us first so that we can investigate and respond.

Privacy Officer
Email: admin@nurturedthoughts.com.au
Phone: (07) 3056 0921
Post: 4 Rakeevan Road, Graceville, QLD 4075

When making a complaint, please include your full name, contact details, a clear description of your concern, any relevant dates, and any supporting information.

We will acknowledge and investigate privacy complaints within a reasonable time.

We may contact you for further information and may need to verify your identity before discussing details of your health information.

We will provide a written response explaining the outcome of our review and any steps we propose to take.

If you are not satisfied with our response, or if we do not respond within the required timeframe, you may contact the Office of the Australian Information Commissioner.

Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Phone: 1300 363 992

Our legal duties to protect health information

We are legally required to take reasonable steps to protect personal information and health information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

We are also required to handle health information in accordance with applicable Australian privacy, healthcare, professional, clinical and record-keeping obligations.

We maintain administrative, technical and physical safeguards designed to protect patient health information.

These include:

secure clinical and administrative systems;
access controls;
staff confidentiality obligations;
staff training;
secure document handling;
secure disposal processes;
reasonable steps to ensure third-party service providers protect information they handle on our behalf;
incident response processes;
data breach assessment and notification processes.

Access to patient health information is limited to authorised clinicians, staff, contractors and service providers who require access for clinical care, administrative support, legal compliance, technology support or other legitimate business purposes.

We will notify affected individuals and regulators of eligible data breaches where required by Australian law.

Protecting your information

We use multiple layers of security to protect your information.

Technical safeguards

Secure systems for data storage and transmission
Security monitoring
System access controls
Password and authentication controls
Data backup and recovery processes where applicable

Operational security

Staff training on security and privacy
Strict access controls based on job requirements
Confidentiality obligations for staff and contractors
Privacy and security procedures
Incident response processes

Physical security

Secure premises with controlled access
Secure storage of physical documents where used
Secure disposal of physical documents
Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms, such as comments or reviews, can be accessed and used by others.

We cannot control or protect information that you make publicly available.

How long we keep your information

We keep personal information and health information for as long as reasonably necessary for the purposes for which it was collected, including providing healthcare, continuity of care, legal compliance, professional obligations, insurance, audit and risk-management purposes.

Patient clinical records are generally retained for at least 7 years from the date of the patient’s last contact with the practice.

For patients who were under 18 years of age at the time of care, records are generally retained until the patient reaches at least 25 years of age.

Records may be retained for longer where required or permitted by law, or where clinically, legally, professionally or operationally appropriate.

When information is no longer required, we take reasonable steps to securely destroy or de-identify it.

Cookies and analytics

What we use

We use cookies, tracking pixels and similar technologies on our website and in our emails to improve your experience and our services.

Cookies are small text files stored on your device.

They help us remember your preferences, enable certain website functions and make your interactions with our website more efficient.

Tracking pixels

Tracking pixels are tiny, invisible images in web pages and emails.

They help us understand how you interact with our content, measure email engagement and deliver more relevant content.

How we use these technologies

Essential functions

To remember your login status
To maintain your session security
To store your preferences
To enable core website features

Analytics and performance

To understand how our website is used
To measure page views and traffic
To analyse user navigation patterns
To identify areas for improvement

Personalisation

To remember your preferences
To tailor content to your interests
To improve your browsing experience
To provide relevant recommendations

Your control

You can manage these technologies by:

adjusting your browser settings to block or delete cookies;
using privacy-focused browser extensions;
configuring your email client to block images;
using our cookie preference settings, where available.
Blocking all cookies may affect website functionality and your user experience.

Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity.

You can opt out of Google’s advertising features through your Google account settings, browser add-ons or your device’s privacy settings.

Google provides tools and options to control how your data is used for advertising purposes. You can learn more through Google’s privacy resources.

Meta advertising tools

We use Meta’s advertising tools, such as Meta Pixel, to understand how our ads perform and to show you more relevant advertisements on Meta platforms such as Facebook and Instagram when you visit our website or app.

You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

Artificial Intelligence technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties.

We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

transcribe consultations, with your consent;
support clinical documentation;
summarise notes, where appropriate and with relevant safeguards;
conduct analysis and data processing;
improve and optimise our services and operations;
automate routine tasks and communications.

Data protection and security

When we work with third-party AI providers, we take reasonable steps to ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain the rights outlined in this Privacy Policy.

When using AI with your personal information, we commit to the following.

Transparency and control

We will inform you when AI is used in a way that may significantly affect you.

We maintain human oversight and review of significant AI-generated outputs or decisions.

Our staff are trained to understand AI limitations and verify outputs before relying on them.

We implement processes to verify the accuracy of AI-generated outputs.

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information.

We regularly test and monitor AI outputs for accuracy and reliability where appropriate.

Risk mitigation

We assess and document risks associated with using AI to process personal information where appropriate.

We implement reasonable measures to address those risks.

We monitor AI performance and review its impact where appropriate.

Amendments

We may update this Privacy Policy at any time by posting the revised version on our website.

We recommend that you review our website regularly to stay current with any policy changes.