Sprout Psychology Melbourne Pty Ltd ABN 47 636 966 259 (“us”, “we”, or “our”) recognises the importance of your privacy and respects your right to control how your Personal Information is collected and used.

This Privacy Policy (“Privacy Policy”) outlines how we collect, use, manage, store and disclose your personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988, the Health Privacy Principles (HPPs), the Health Records Act 2001 (HRA), Health Records Regulations 2023 and other relevant privacy legislation (together, the “Legislation”).

Collection

The purpose for which we collect Personal Information is to provide you with the best healthcare service experience possible. Some provision of Personal Information is optional. However, if you do not provide us with certain types of Personal Information, we may not be able to provide our healthcare services to you.

To provide our healthcare services, we may collect Personal Information such as:
•    your name, sex, address and contact details, including your email address and telephone number;
•    your date of birth;
•    your business or company name;
•    nationality;
•    your reasons for contacting or additional information that you want to share with us;
•    images or footage of identifiable individuals;
•    medical history and current health information;
•    psychological history and assessment results;
•    family medical history;
•    Medicare and/or private health fund details; and
•    your payment and billing information, which we use to bill you for the healthcare services and to process your payments.

We collect this information directly from you, through triage, through completing our online form, creating a member account, intake forms, during consultations, or through referrals from other healthcare providers. We also collect this information via our employees, agents, and other third parties or through the deployment of third-party AI products and services which we use to assist us in recording, transcribing and summarising our triage process and psychology session with you.

We may also collect Personal Information from job applicants for recruitment purposes. Where this information is no longer needed, we will take reasonable steps to destroy or permanently de-identify it unless we are otherwise required by law.

We may at times collect Personal Information through visual and audio surveillance of various areas of our premises as permitted by relevant legislation and in accordance with our policies. We may also collect personal identifiers or information such as Medicare identifier, information directly and indirectly related to provision of healthcare services and details of conversations we have had with you or any other information relevant to us.

An identifier is a unique number assigned to an individual to identify them. Identifiers include Medicare Numbers and Tax File Numbers. We will not adopt, as our own, any of your identifiers or use or disclose an identifier which has been assigned to you by a government agency, unless permitted by law.

We automatically collect information that is often not personally identifiable, such as the website from which you came to our website (www.sprout-psychology.com.au) (Site), IP address, browser type and other information relating to the device through which you accessed the Site. We may combine this information with the Personal Information we have collected about you.

Access, Use and Disclosure

We will treat your Personal Information as strictly private and confidential. We will only use or disclose it for purposes directly related to your care and treatment, or in ways that you would reasonably expect that we may use it for your ongoing care and treatment. Your Personal Information is only accessible by our employees and contractors (such as our psychologists and administrative staff) on a strict-needs basis and on a strictly confidential basis.

Personal Information collected by us will generally only be used and disclosed for the purpose it was collected. This includes maintaining your contact details and clinical records, providing you with our healthcare services and processing payments and managing billing. We may disclose your Personal Information to third-party service providers who perform functions on our behalf (e.g. IT services, payment processing, accounting, call recordings) and to third-party AI service providers whom we engage to record, transcribe and summarise our triage process and our psychology sessions.

We may, from time to time, use Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act, including to effectuate or enforce a transaction, procuring advice from legal and accounting firms, auditors and other consultants. We may also disclose your Personal Information in circumstances where we are compelled by Australian legislation or a court of law to do so. We do not sell your Personal Information. We may aggregate the information you and others make available to us on a deidentified basis and share it with third parties for market analysis, research, marketing or other purposes such as to improve our healthcare services or to help our partners understand more about the users of our healthcare service and health issues. You can object to us using your information for these purposes.

We may use transcription technology to assist with efficiently managing inquiries during phone calls with our administrative staff. Your phone calls with admin may be recorded for quality and training purposes only. This information remains confidential and will not be used for any other purpose. In the event that we sell our business, or engage in a transfer, merger, restructure or change of control or other similar transactions, customer information (containing Personal Information) is generally one of the business assets that forms part of the transaction. Your Personal Information may be subject to such a transfer. In the unlikely event of insolvency, Personal Information may be transferred to a trustee or debtor in possession and then to a subsequent purchaser.

We may provide Personal Information to other healthcare service providers, such as your allied health professionals, general practitioner and specialist medical practitioners. We will only supply this information with your consent, or in circumstances where it is required for the delivery of healthcare services, such as referral to another healthcare service provider, billing and liaising with government offices regarding Medicare entitlements and payments, where it is necessary to prevent or lessen a serious threat to a patient’s life, health or safety, or other reason as permitted by law.

Telehealth Consultations

We offer telehealth consultations via secure video conferencing or phone platforms. While we use secure platforms to protect your privacy, there are still potential risks associated with telehealth, such as technical difficulties. You can ask your psychologist about these risks before your consultation.

Clinical Supervision

Psychologists may discuss client information with supervisors or during professional consultations. This information is typically de-identified to protect client confidentiality.

Your Access and Accuracy of Personal Information

You can access and/or correct information we hold about you at any time by contacting us at admin@sprout-psychology.com.au. We encourage you to contact us to keep your Personal Information accurate and up to date. We will respond to your request for Personal Information within a reasonable time. We may charge a reasonable administration fee to cover the costs of responding to your request, for example, where Personal Information is held in storage, subject to applicable laws and regulations. If required by law or where the information may relate to existing or anticipated legal proceedings, we may deny your request for access to your information. We will respond to your request, setting out the reasons for our refusal in writing.

Storage and Security

We will take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access and modification or disclosure. We use commercially reasonable physical, technical, and administrative measures to protect Personal Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our Site. We also implement secure electronic record-keeping systems, confidentiality agreements with all staff, regular data backups and restrict access to personal information based on role requirements. Despite taking appropriate measures to protect your Personal Information used and collected by us, please be aware that no data security measures can guarantee 100% security all the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk. If we no longer require the use of your Personal Information, we will take reasonable steps to destroy or permanently de-identify it unless we are otherwise required by law.

Personal Information may be stored electronically on our local server and by way of back up on a secure third-party data centre, located in Australia, or in physical storage at our practice or third-party secure storage facilities.

Anonymous Health Care

You may request to remain anonymous when you seek healthcare services from us. While we endeavour to comply with any request to use our healthcare services anonymously or using an alias, there may be circumstances in which it is unlawful or impracticable to do so. For instance, we cannot provide Medicare rebates or access to Veterans Affairs entitlements without properly identifying you. If you request to be seen anonymously, you will also not be able to access the Pharmaceutical Benefits Scheme in the event you require any medication.

Third-party websites

At times, our Site may contain links to other third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Marketing emails

We may send you direct marketing emails and information about healthcare services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) as you consented to upon registering for our healthcare services. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email (e.g. by clicking “Unsubscribe”). Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you email about your account, your account or any healthcare services you have requested or received from us, or for other customer healthcare service purposes. We do not provide your Personal Information to other organisations for the purposes of direct marketing.

Consent to international transfer

We may transfer your Personal Information to third parties located in other countries including our related entities or employees, external healthcare service providers such as administration providers or information technology providers such as cloud storage and data processing. We only transfer information where we reasonably believe that the recipient is legally or contractually bound to principles that are substantially similar to the Australian Privacy Principles.

Changes to this policy

We may change this Privacy Policy from time to time. Any updated versions of this Privacy Policy will be posted on our Site. Your continued use of any of our Site and healthcare services constitutes your acceptance and understanding of the Privacy Policy as in effect at the time of your use. This Policy is current as of 18/09/2024.

Complaints and Enquiries

If you have any questions or complaints regarding privacy, or if at any time you believe we may have wrongfully disclosed your Personal Information or breached our Privacy Policy, please contact us at (03) 9808 3518 or lodge your complaint in writing to:

The Director
369 Burwood Highway
Burwood VIC 3125

or via email at sharen@sprout-psychology.com.au

If you are not satisfied with our response, you are entitled to contact the Victorian Health Complaints Commissioner by phoning 1300 582 113, or the Office of the Australian Information Commissioner, by phoning 1300 363 992 or writing to the Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 1042.

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Last Updated 18/09/2024