Privacy Policy

Introduction.

CIRCA Sleep Psychology Practice is committed to protecting your privacy and complying with the Privacy Act 1988 and the Australian Privacy Principles (APPs). This policy outlines what type of information is collected and how we collect, use, disclose, and safeguard your personal information.

Types of information collected.

We collect various types of information.

Client Service Record Information:

Name, date of birth, addresses, contact numbers, emergency contacts, email address and other contact details;
Health information contained in your digital health record including medicare number, healthcare identified and health fund details where relevant (if you participate and only with your consent);
Financial payment details (such as your credit card number);
Other information disclosed by you, if relevant when providing our services directly to you (such as your relationships with other persons, employment information and qualifications, gender, race, sexuality or religion); and

Confidential Client Record Information:

Details of other health service providers involved in your care and copies of any referral letters and/or reports/results from those parties;
Medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors;
In addition, in the provision of psychological services Circa Sleep Psychology will likely collect the following personal information:
- Treatment plans, psychological assessments, referral sources.
- Responses and results from psychological tests and questionnaires.
- Responses and results reasonably obtained as part of a neuropsychological assessment.
- Information pertaining to your session notes; treatment plan and your response to treatment.

Collection Methods.

We are committed to using lawful and fair means to collect personal information and collecting it from others only when it is unreasonable or impracticable to obtain certain information from our clients directly.

A client's personal information is collected in a number of ways:

During psychological therapy with Circa Sleep Psychology, including when the client provides information directly to a clinician using hardcopy or electronic forms, correspondence including via email and when the client interacts directly with CIRCA Sleep Psychology employees; and

From a client’s responsible person, such as parents and guardians; and
From other health service providers who provide personal information to Circa Sleep Psychology, via referrals, correspondence and medical reports.

We will always endeavour to keep you reliably informed of the information collected and the source of that information, and will seek and obtain written informed consent to contact and retrieve that information.

USE AND DISCLOSURE OF INFORMATION

It is necessary for Circa Sleep Psychology to collect, hold, and use information to provide our service, including for the following purposes to:

Communicate with clients;
Conduct psychological services including assessment and diagnosis;
Communicate with other relevant healthcare providers (with the client’s written consent);

Communicate with other parties such as schoolteachers to obtain clinical information (with the client’s written consent);
Liaise with Medicare, your health fund or government department;
When it is necessary to lessen or prevent a serious threat to your life, health, or safety or public health or safety;
To handle a complaint or respond to anticipated or existing legal action; and
As required by the Commonwealth Privacy Act 1988

Our privacy practices are in keeping with the Commonwealth Privacy Act 1988, and in our practice of confidentiality we also strive to conform to the ethical principles of the APS Code of Ethics.

We will seek your written consent to communicate with third parties. We may share confidential information in the following circumstances:

with the consent of the relevant client or a person with legal authority to act on behalf of the client;
where there is a legal obligation to do so (e.g., a subpoena is issued, or when a mandatory report must be made about a child at risk of harm);
if there is an immediate and specified risk of harm to an identifiable person or persons that can be averted only by disclosing information; or
when consulting colleagues, or in the course of supervision or professional training, provided the psychologist conceals the identity of clients and associated parties involved; or obtains the client’s consent, and gives prior notice to the recipients of the information that they are required to preserve the client’s privacy, and obtains an undertaking from the recipients of the information that they will preserve the client’s privacy.

In line with the Privacy Act and APS Code of Ethics, client information is retained for a minimum of 7 years after the client’s last contact with our service, or if the client is under 18, until they turn 25.

Your personal information is not likely to be sent overseas, except in the case that overseas data storage facilities are used by providers such as Google. In each case, data is stored in encrypted form and cannot be accessed or viewed by those affiliated with each provider except under rare legal circumstances.

Storage and Security.

Circa Sleep Psychology collects and stores your personal information electronically. We securely store this information on servers and computer systems. In some cases, personal information may be collected on paper, which is then converted to an electronic format, and the original paper documents are securely destroyed.

All Circa Sleep Psychology clinicians will take reasonable steps to protect the personal information of clients from misuse, interference, or loss, and from unauthorized modification, access, or disclosure. This will be done in accordance with the APS Code of Ethics (2007) and other relevant ethical guidelines, legal obligations, and privacy laws, including the Privacy Act 1988 and the Australian Privacy Principles.

If a data breach occurs involving personal information and the breach is likely to cause harm, we will notify that affected client as soon as possible after the occurrence.

Access and Correction.

You have the right to:

Access: Clients can request details of personal information we hold about them, as permitted by the Privacy Act 1988 (Cth) (the Act). In some cases, we may refuse to provide access, as allowed under the Act. Otherwise, we will provide access if it is reasonable and practicable to do so. We generally provide this information free of charge, but if your request requires significant effort or expense, we may ask for a reasonable fee.
Correction: If you believe that any information we hold about you is inaccurate, outdated, incomplete, irrelevant, or misleading, please contact us using the details below. We rely on clients to inform us when their personal information changes. We will correct any inaccurate or outdated information and notify relevant third parties of the correction, unless doing so is impracticable or unlawful.
Deletion: If you wish for us to delete personal information we hold about you, or stop collecting information for a specific purpose, please contact us. However, please note that we may be required by law to retain certain information (such as healthcare records) for a prescribed period. Even if we agree to delete your information, some residual data may remain in backups or deletion logs.

We will respond to requests for access, correction, or deletion of information within a reasonable timeframe.

Requests can be made in writing to hello@circasleep.com.au, and we will respond as soon as practicable.

Complaints.

Clients have a right to make a complaint about the handing of their personal information.

Complaints can be made to Circa Sleep Psychology by email (hello@circaleep.com.au). We will endeavour to respond appropriately to reasonable complaints within 30 days of the receipt of the email.

Ultimately, if you wish to make a complaint about the use of, disclosure of, or access to your personal information, you may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at http://www.oaic.gov.au/provacy/making-a-privacy-complaint or by post to: office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001.

Other agencies to which clients may bring complaints are as follows:

Australian Health Practitioner Regulation Agency (ahpra.gov.au)
Australian Psychological Society (psychology.org.au)

Changes to the policy.

We may update or modify this Privacy Policy at any time and at our discretion. Any changes will be effective immediately upon posting the updated Privacy Policy on our website. We encourage you to check back periodically to stay informed of the current version.

Contact.

Queries, complaints, requests for access or correction should be made in writing and sent to: hello@circasleep.com.au

Last updated September, 2024.