In this Privacy Policy:

This Privacy Policy sets out the manner in which we collect, use, disclose and manage personal information. By using our websites or using our services, you are taken to have read, and agreed to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.

We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes.

Respecting information privacy

We value your privacy and we are committed to protecting the privacy and confidentiality of personal information.  In general terms, personal information is information or opinion, whether true or not, about a person whose identity is apparent, or can reasonably be ascertained, from the information or opinion (that is recorded in any form). This Privacy Policy supports our commitment to protecting your personal information.

In collecting and handling your personal information, we are bound by the Privacy Act 1988 (Cth) (“Privacy Act”), the Health Records Act 2001 (Vic) (“Health Records Act”) and other applicable privacy regulations.

What personal information do we collect?

We collect personal information about our clients and prospective clients in the course of delivering our services and programs (including, for example, consultations, counselling and workplace group sessions). The kinds of personal information we collect will vary depending on the context of the collection.

Examples of the types of personal information we collect include:

We do not ask for any personal information that is not reasonably necessary for, or directly related to, our functions or business activities.

What do we use personal information for?

We collect personal information:

Sensitive Information

We may collect your health-related information and other ‘sensitive information’ as defined under the Privacy Act.  We only collect your sensitive information after explaining how we will use that sensitive information and with your express consent, except in limited circumstances described below.

We may collect health information without consent where it is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety, and:

If we collect information without consent, we will take reasonable steps to de-identify that information before disclosing it to anyone else. Otherwise, we may use or disclose health information for research or statistical purposes relevant to public health or public safety when the Privacy Act permits the use or disclosure.

Collection of information on behalf of Custodian Organisations

Sometimes we collect personal information on behalf of Custodian Organisations, such as Justice Health, where the Custodian Organisation is the responsible custodian of the personal information.   In these cases the policies and procedures of the relevant Custodian Organisation will apply to the storage, handling and disclosure of that personal information.

How do we collect personal information?

Caraniche collects personal information through a variety of different methods including:

We will only collect your personal information from you directly, except where you have consented to collection of your personal information from someone else, or the information relates to a child or an adult who lacks capacity, in which case the relevant information may be collected from a parent or guardian.

We will only collect your sensitive information directly from you, unless it is not reasonable or practicable to do so – for example in an emergency where it may be necessary to collect health information from a guardian or relative.

Our disclosures to you when collecting your personal information

When we collect your personal information, we will take reasonable steps to inform you (as close as possible to the time we collect the information):

The matters above will generally be disclosed in our collection notices, privacy statements and consent forms.

Collection of personal information from third parties

In some cases, we collect personal information from third parties  – for example:

We collect personal information from third parties where it is reasonably necessary for, or directly related to, our functions or activities.

We will only collect sensitive information about you from a third party with your consent to the collection, unless an exception applies – including:

We may, with your consent, collect personal information from (or may disclose personal information to) agencies or organisations that are responsible for paying for the services or programs that we deliver to a client (Billing Agency).

Use and disclosure of personal information

We will only use or disclose personal information for the primary purpose for which we collected it and any secondary purpose contemplated by the context of collection, for example where:

In addition, we may use or disclose health information for research or statistical purposes relevant to public health or public safety in accordance with the Privacy Laws, for example, where:

We will not publish any of your personal information collected for research purposes unless you have provided consent. You will have the right to opt out of any research project at any time.

Storing and securing personal information

The security of the personal information that we collect is paramount.  We will take all reasonable steps to protect information from misuse and loss, and from unauthorised access, modification and disclosure. We apply appropriate physical, technical and protective data security practices to all personal information that we hold.

We will take all reasonable steps to destroy or permanently de-identify personal information if it is no longer required in accordance with Privacy Laws.

In accordance with the Health Records Act and the Australian Psychological Society (APS) Code of Ethics, client files are destroyed 7 years after the date of our last contact with the client (or such longer period as may be required by applicable law), expect that files relating to minors will generally be retained until the minor reaches the age of 25 or such longer period as may be required by law.

Where personal information is deemed to be a ‘public record’ then such information will be retained and disposed of as required under the Public Records Act 1973 (Vic).

Where we collect information on behalf of a Custodian Organisation, the security and storage of that information will be the responsibility of the Custodian Organisation.

De-identified information and anonymity

We may provide you with the option of not identifying who you are or using a pseudonym, but only where it is lawful and practicable to do so.  In the context of providing our services and programs, it will usually be impracticable to transact with an individual anonymously due to the type of information required from an individual e.g., contact details, medical history, referrals, etc.

From time to time we use certain de-identified information such as anonymous or statistical usage data, anonymized IP addresses, browser or platform types.

Access to and correction of personal information

We will take reasonable steps to ensure that all personal information that we collect and hold is accurate, up to date and not misleading, having regard to the purpose(s) for which the information is to be used.

You have the right to access, update and correct information that we hold about you.  Your requests to exercise these rights should be directed to our Privacy Officer at the contact details at the end of this Privacy Policy.  We will respond to a request for access within a reasonable period.

In most cases, we will be able to provide you with a summary of any personal information that we hold about you free of charge. However, in some circumstances, reasonable costs may be charged and we will explain the reasons for any charge that is applied.

For information about you held by a Custodian Organisation, any requests to access, update or correct this information must be directed to the relevant Custodian Organisation.

There are some situations where we cannot provide you access to your personal information, for example where:

Where we are not able to provide access to personal information or we are not willing to make a correction to personal information, we will notify you and provide our reasons.

Cookies

From time to time we may use cookies and measurement software and tools on our websites. We use and disclose the information collected through the use of cookies, measurement software and tools in accordance with this Privacy Policy. This includes using the information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our websites. If you do not want information collected through the use of cookies, measurement software and tools, you may be able to delete or reject Cookies or some of the measurement software features through your browser or the settings section of your mobile or tablet device. Disabling these features may cause some of the functions on our websites not to work properly.

Making a complaint

If you wish to complain about our handling of your personal information, you may lodge a complaint with our Privacy Officer.  We will investigate your complaint and provide a response within a reasonable period of time.

If you remain unhappy with the way we have handled your personal information or you are not satisfied with the way in which we have handled your complaint may lodge a complaint with:

Contact details and further information

Caraniche Privacy Officer

Address: Level 1, 260 Hoddle Street, Abbotsford VIC 3067
Phone: (03) 8417 0500

Email: feedback@caraniche.com.au

For further information and guidance on the Privacy Laws and the role of the Office of the Australian Information Commissioner see https://www.oaic.gov.au

For further information and guidance on the handling of health information specifically and the role of the Health Complaints Commissioner see https://www.hcc.vic.gov.au

For further information on the Australian Psychological Society Code of Ethics, see https://www.psychology.org.au/About-Us/What-we-do/ethics-and-practice-standards/APS-Code-of-Ethics