Privacy Policy for Management of Personal Information1

This document describes the Glynn Mind Clinic (GMC) privacy policy for the management of clients or patients’ personal information. GMC is bound by the legal requirements of the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (PR Act) and the Australian Psychological Society Code of Ethics.

  1. Client information
    1. Client files are held in a secure practice management software which is accessible only to authorised employees. The information on each file includes personal information such as name, address, contact phone numbers, medical history, and other personal information collected as part of providing the psychological service.
  2. How clients or patients’ personal information is collected
    1. A client’s personal information is collected in a number of ways during psychological consultation with GMC, including when the client provides information directly to GMC using hardcopy forms, correspondence via email, website registration/online bookings, when the client interacts directly with GMC employees such as the receptionist, and when other health practitioners provide personal information to GMC, via referrals, correspondence and medical reports.
  3. Consequence of not providing personal information
    1. If the client does not wish for their personal information to be collected in a way contemplated by this Privacy Policy, GMC may not be in a position to provide the psychological service to the client. In some circumstances, clients or patients may request to be anonymous or to use a pseudonym, unless it is impracticable for GMC to deal with the client or if GMC is required or authorised by law to deal with identified individuals.
  4. Purpose of holding personal information
    1. A client’s personal information is gathered and used for the purpose of providing psychological services, which includes assessing, diagnosing and treating a client’s presenting issue. The personal information is retained in order to document what happens during sessions and enables the psychologist to provide a relevant and informed psychological service.
  5. Disclosure of personal information
    1. Clients or patients’ personal information will remain confidential except where:
      1. it is subpoenaed by a court, or disclosure is otherwise required or authorised by law; or
      2. failure to disclose the information would, in the reasonable belief of the GMC, place a client or another person at serious risk to life, health or safety; or
      3. the client’s prior approval has been obtained to:
        1. provide a written report to another agency or professional, e.g., a GP or a lawyer; or
        2. discuss the material with another person, e.g. a parent, employer, health provider, or third party funder; or
        3. disclose the information in another way or for another purpose; or
        4. disclose to another professional or agency (e.g. your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which the personal information was collected.
      4. A client’s personal information is not disclosed to overseas recipients unless the client consents or such disclosure is otherwise required by law. Client’s or patients’ personal information will not be used, sold, rented or disclosed for any other purpose.
      5. In the event that unauthorised access, disclosure or loss of a client’s personal information occurs GMC will activate its data breach plan and use all reasonable endeavours to minimise any risk of consequential serious harm.
  6. Requests for access and correction to client information
    1. At any stage clients or patients may request to see and correct the personal information about them kept on file. The psychologist may discuss the contents with them and/or give them a copy, subject to the exceptions in the PR Act.
    2. If satisfied that personal information is inaccurate, out of date or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected.
    3. All requests by clients or patients for access to or correction of personal information held about them should be lodged with our practice manager: [email protected]. These requests will be responded to in writing within 14 days, and an appointment will be made if necessary, for clarification purposes.
  7. Concerns
    1. If clients or patients have a concern about the management of their personal information, they may inform our practice manager: [email protected]
    2. Upon request they can obtain a copy of the Australian Privacy Principles, which describe their rights and how their personal information should be handled.
    3. Ultimately, if clients or patients wish to lodge a formal complaint about the use of, disclosure of, or access to, their personal information, they may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992, online via the OAIC website here or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001.
1. Adopted from the APS Privacy Policy Template.