Protecting Your Information
Positive Wellbeing Psychology is committed to protecting the privacy of our clients and psychologists and psychiatrists, and takes the protection of personal and health information very seriously.
This policy outlines our approach to managing personal and health information, collected as part of provision of a service, enquiry about provision of service, or in accessing our website. Positive Wellbeing Psychology complies with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), and the Health Privacy Principles (HPPs) under the Health Records Act 2001 (Vic), when handling personal information.
Our Structure and Responsibility for Your Information
Positive Wellbeing Psychology (the 'Service Provider') provides administrative and practice support services to Independent Practitioners (psychologists and psychiatrists, referred throughout this document as 'Clinicians').
This means there are different responsibilities for your personal information:
- Positive Wellbeing Psychology is responsible for personal information collected for administrative and operational purposes (such as enquiries, bookings, billing, and practice systems).
- Clinicians retain ownership of, and professional and legal responsibility for, the clinical records they create and how that information is handled and stored.
- Positive Wellbeing Psychology manages administrative records and processes on behalf of the Clinicians engaging the Service Provider.
Collection and Management of Personal Information
We collect personal information in different ways depending on your interaction with us:
- Administrative information (collected by Positive Wellbeing Psychology): Includes your name, contact details, referral information, and appointment history. This is used to manage bookings, communication, and practice operations.
- Clinical information (collected by your clinician): Includes sensitive information such as your mental health history, medical background, and session notes. This is collected and used by your clinician as part of assessment and treatment.
This information is collected only with your consent and when necessary to provide our services.
Purpose of Collecting Personal Information
Your personal information is gathered and used for the purpose of supporting the provision of psychological and clinical services. Your Clinician collects and uses personal and health information for the purposes of assessment, diagnosis, and treatment of your presenting concerns. Positive Wellbeing Psychology also collects personal information for the purposes of administrative tasks, such as communication with you.
How Personal Information is Collected
Your personal information is collected in a number of ways during psychological or clinical consultation with your Clinician.
Information may be provided directly to Positive Wellbeing Psychology via online intake or enquiry forms, email correspondence, or when speaking with our reception team, for administrative and operational purposes. Personal information is also collected by your Clinician during consultations, including notes taken to document details relevant to assessment and treatment.
Personal information is usually collected directly from you. Oftentimes, information may be received from third parties (such as referring practitioners or family members), with your consent or where otherwise permitted by law.
Where personal information is collected indirectly:
- Positive Wellbeing Psychology will take reasonable steps to ensure you are made aware of the information provided and the circumstances of its collection, where this relates to administrative information; and
- Your Clinician is responsible for taking reasonable steps in relation to clinical information they collect.
Storage of Personal Information
Administrative information is stored within practice systems such as Halaxy, which is an Australian-based secure private practice software program commonly used in the healthcare industry. For more information regarding Halaxy please see the Halaxy Terms of Use and Halaxy Privacy Policy. The information on each file includes personal information such as your name, address, contact phone numbers, medical history, and other personal information collected as part of supporting the provision of the psychological and clinical service.
Email communications are managed through Zoho Mail, our secure email server platform.
Clinicians may choose to store their clinical notes in Halaxy, or may use hard-copy records or secure electronic systems (such as a password-protected personal device). If your Clinician prefers hard-copy notes, hard-copy client files are held in a secure filing cabinet which is accessible only to the Clinician. In all cases, Clinicians are required to ensure their notes are stored confidentially and in accordance with Australian privacy law and professional standards.
For the purposes of managing incoming enquiries, our reception team also uses internal databases which are securely stored (via encryption) online.
Health information is retained in accordance with legal and professional obligations, including minimum retention periods under Victorian law. This includes storing your records for a minimum of seven years (or until the age of 25 if under 18 years of age).
In some cases, Positive Wellbeing Psychology may share limited personal information with professional service providers (such as accountants, legal advisors, or IT consultants) for purposes such as billing, systems support, or compliance. All such providers are required to maintain confidentiality and comply with Australian privacy legislation.
International Partnerships
Some of our administrative services are conducted by international staff based in offshore locations. Positive Wellbeing Psychology takes reasonable steps to ensure that any overseas recipients handle personal information in accordance with Australian Privacy laws, including through confidentiality agreements, access controls, and secure systems. Any information that is subject to overseas handling is stored on Australian data servers. By engaging with our services, you consent to this disclosure where it is necessary to provide administrative support.
Data Security
We have stringent security protocols in place regarding data security. Our clinical system, Halaxy, and all back-end systems are protected with multi-factor authentication. Clinicians engaging the Service Provider are provided with guidelines regarding password and other data-security measures (such as anti-virus software etc.).
Disclosure of Personal Information
Personal information will remain confidential and will not be shared with other parties unless you request or consent to this (e.g. you request a written report for work/study or you wish to involve a loved one). Depending on which entity retains responsibility for your clinical record, they may be required or authorised to disclose information without consent in the following circumstances:
- If failure to disclose the information would, in the reasonable belief of your Clinician, place you or another person at serious risk to life, health or safety; or
- Information is subpoenaed by a court of law; or
- If your Clinician suspects that a child is at risk of neglect, abuse or harm, or if the Department of Human Services requires information relevant to a child under a protection order.
There also may be times where as part of the assessment and therapy process, it may be helpful for your Clinician to liaise with other people that are relevant to your therapy goals (e.g. your GP, specialist, etc.). Please note that if you intend to claim rebates from Medicare or another organisation then your Clinician must provide summary reports and be open to professional discussion regarding assessment and treatment progress.
For school-aged clients, it is assumed that parents have permission to act on behalf of their children in relation to attendance and administrative matters. Please advise your Clinician if there are particular concerns about a parent/guardian knowing about a child's attendance.
Clients under the age of 18 may have the right to make their own privacy decisions if they are assessed to have sufficient maturity and understanding. Where appropriate, your Clinician will consider the young person's capacity to consent to treatment and make decisions about how their personal information is handled.
Consequences of Not Providing Personal Information
If you do not wish for your personal information to be collected in a way anticipated by our Client Agreement or our Privacy Policy, your Clinician may not be in a position to provide a psychological or clinical service to you. You may request to be anonymous or to use a pseudonym, unless it is impracticable for your Clinician to deal with you or if your Clinician is required or authorised by law to deal with identified individuals. In most cases it will not be possible for you to be anonymous or to use a pseudonym.
Consent to Providing Information
By contacting us (via website enquiry, phone, or other written communication such as email), by completing a client consent form, or otherwise engaging in psychological or clinical services, you consent to your Clinician and Positive Wellbeing Psychology collecting, using, storing, and disclosing your information for the purposes specified in this Privacy Policy.
Requests for Access and Correction to Client Information
At any stage you may request to see and correct the personal information about you kept on file. Your Clinician may discuss the contents with you and/or give you a copy, subject to the exceptions in the Privacy Act 1988 (Cth). 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.
Requests for access to or correction of personal information should be directed to:
- Your clinician, for clinical information; or
- Positive Wellbeing Psychology, for administrative information (via info@positivewellbeingpsychology.com.au).
These requests will be responded to in writing within 10 days, and an appointment will be made if necessary for clarification purposes.
Our Website
Our website uses 'cookies' as part of our website analytics. Cookies are a form of technology used to track data using your browser's functionality. Cookies are small data files that websites place on computers or devices to enhance the functionality of the website, for example identifying if a person has visited our website before, and record details of the user's visit.
Most browsers have the option to enable notifications if you receive a cookie, or block cookies entirely if you wish.
Direct Communication and Newsletters
If you choose to subscribe via our website or when booking with us, we may occasionally send you newsletters or updates containing general mental health content, such as tips, articles, and wellbeing information. This mailing list is not used for communication about your appointments or to provide service reminders.
You can unsubscribe from these communications at any time by clicking the "unsubscribe" link at the bottom of the email, or by contacting us at info@positivewellbeingpsychology.com.au.
Social Media Use
Positive Wellbeing Psychology maintains public social media pages for sharing general wellbeing information. These platforms are not monitored for clinical communication. Please do not share personal or confidential information via social media. If you wish to contact us, please do so via phone or email.
Security Cameras (CCTV)
For the safety of our clients, Clinicians, and premises, we use closed-circuit security cameras at external entry points to the practice. These cameras record video footage and are used solely for security and safety purposes, such as responding to incidents or unlawful activity.
CCTV footage is securely stored, access is restricted, and recordings are retained for a limited period before being deleted, unless required for the investigation of an incident. Cameras do not operate within therapy rooms or other private internal areas.
Where CCTV footage is stored or processed using third-party systems, reasonable steps are taken to ensure compliance with the Australian Privacy Principles. Some data may be stored on servers located outside Australia.
Concerns
If you are dissatisfied with how your personal or health information has been collected, stored or disclosed, you can raise your concerns through our Complaints Handling Process – please indicate when you are making a privacy complaint so that it can be managed in accordance with applicable privacy laws.
We take all concerns seriously and will respond in accordance with our complaints process. Privacy-related concerns are managed with regard to the requirements of the Privacy Act 1988 (Cth) and the Health Records Act 2001 (Vic).
Upon request, you can also obtain a copy of the Australian Privacy Principles, which describe your rights and how your personal information should be handled.
If you are not satisfied with our response, you may lodge a formal complaint with the relevant external body:
- Office of the Australian Information Commissioner (OAIC) – http://www.oaic.gov.au | Phone: 1300 363 992
- Health Complaints Commissioner (Victoria) – http://www.hcc.vic.gov.au | Phone: 1300 582 113
Updates to the Privacy Policy
This Privacy Policy may be amended from time to time. Any changes will be effective when the updated policy is published on our website. Where changes are significant, we will take reasonable steps to notify you.
By continuing to engage with our services after updates are made available, you acknowledge the updated Privacy Policy. If you have any concerns about changes to this Privacy Policy, please contact us to discuss your options prior to continuing services.
Last Updated: 4th August 2026