PrivacyPolicy

PRIVACY POLICY & HEALTH INFORMATION MANAGEMENT

Last updated: August 2026

This Privacy Policy explains how Renate Best (ABN 81 353 728 689) collects, uses, stores, protects and discloses personal and health information in providing psychological services, professional supervision and consultation.

The practice is committed to protecting your privacy and handling your personal and health information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Notifiable Data Breaches (NDB) scheme, applicable health records and privacy legislation, and the Psychology Board of Australia's Code of Conduct for psychologists.

1. Personal and Health Information Collected

To provide safe and effective psychological services, supervision and consultation, the practice may collect information that is reasonably necessary for the service being provided.

Depending on the nature of the service, this may include:

  • your name, date of birth and contact details;

  • relevant demographic and background information;

  • information provided through online booking and intake forms;

  • information about your psychological, medical and psychosocial history;

  • information relevant to assessment, treatment, formulation and ongoing care;

  • information contained in referral letters, Mental Health Treatment Plans or other documents provided by you or, where appropriately authorised, another health professional;

  • clinical notes and records of consultations;

  • information about other health professionals involved in your care;

  • Medicare or private health insurance information where relevant;

  • billing and payment information; and

  • information necessary to manage appointments and the administration of the practice.

Only information that is reasonably necessary for the provision and administration of the relevant service will be collected.

2. Anonymity and Pseudonymity

You may have the right to deal with an organisation anonymously or by using a pseudonym in some circumstances.

Due to the nature of psychological services, professional obligations, record-keeping requirements and, where applicable, Medicare requirements, it is generally not practicable for psychological services provided by this practice to be delivered anonymously or under a pseudonym.

3. How Information Is Collected

Information is generally collected directly from you through

  • secure online booking and intake systems;

  • information you provide before or during consultations;

  • email or other approved practice communications;

  • payment and administrative processes; and

  • documents you provide to the practice.

Where appropriate and with your consent, or where otherwise permitted or required by law, information may also be collected from third parties involved in your care, such as your General Practitioner or another treating health professional.

Before collecting personal or health information, you will be provided with information about how that information will be collected, recorded, stored and used.

Where information is requested from an associated person or another health professional, the nature and purpose of the information being sought will be explained and appropriate consent will be obtained where required.

4. Informed Consent and Information Handling

Before psychological services commence, you will be provided with information about the nature of the service, relevant benefits and risks, fees and other material matters necessary for you to make an informed decision about whether to proceed.

You may ask questions about the service and your information at any time.

You may withdraw your consent to particular uses or disclosures of your information where consent is the basis for that use or disclosure. Withdrawal of consent may have implications for the provision of services, and these will be discussed with you where relevant.

Consent will be revisited where there is a significant change to the service or another aspect of the professional relationship.

5. Purpose of Collection, Use and Disclosure

Your personal and health information may be collected, used and disclosed as reasonably necessary for:

  • providing psychological assessment, treatment and support;

  • clinical assessment, formulation and treatment planning;

  • monitoring and reviewing your care;

  • providing professional supervision and consultation;

  • maintaining appropriate clinical and professional governance;

  • coordinating care with other health professionals where authorised or required;

  • managing appointments and practice administration;

  • processing payments and accounts;

  • processing Medicare or private health insurance claims where applicable;

  • complying with professional, legal and regulatory obligations;

  • responding to lawful requests for information; and

  • managing situations involving significant risk to your safety or the safety of another person.

Information may be disclosed, where appropriate and with your consent where required, to:

  • your referring General Practitioner or other treating health professionals;

  • Medicare or Services Australia where required for Medicare rebate processing;

  • private health insurers where relevant and authorised;

  • professional supervisors or consultants for supervision, consultation and clinical governance purposes;

  • secure third-party providers that support practice operations, such as practice management, booking, payment, information technology and communications services; and

  • other persons or organisations where disclosure is authorised or required by law.

Information will only be disclosed to the extent reasonably necessary for the relevant purpose.

6. Professional Supervision and Consultation

As part of maintaining safe, ethical and effective professional practice, clinical matters may be discussed with a professional supervisor or appropriate consultant for supervision, consultation or clinical governance purposes.

Before disclosing, transmitting, sharing, reproducing or posting your personal information or images for supervision or consultation, your psychologist will obtain your written informed consent, including where information is intended to be de-identified, unless disclosure is otherwise authorised or required by law.

Identifying information will be minimised wherever practicable, and information will be handled confidentially.

7. Confidentiality and Its Limits

Your personal and health information is treated as confidential.

Information will not ordinarily be disclosed to another person without your consent. However, there are circumstances in which information may be disclosed without your consent, including where:

  • disclosure is required or authorised by law;

  • disclosure is necessary to comply with a subpoena, court order or other lawful requirement;

  • disclosure is permitted or required under applicable mandatory reporting obligations;

  • disclosure is reasonably necessary to respond to a serious risk to your safety or the safety of another person; or

  • disclosure is necessary to facilitate emergency medical or other emergency assistance.

The limits of confidentiality will be discussed with you as part of the informed consent process and whenever relevant circumstances arise.

8. Telehealth and Privacy

Psychological services provided by this practice are delivered by telehealth using secure telehealth technology.

Reasonable steps are taken to provide consultations in a private and secure environment and to protect the confidentiality of telehealth communications.

You are encouraged to:

  • participate in consultations from a private location where possible;

  • use a private and secure internet connection where practicable;

  • use headphones where appropriate to reduce the likelihood of others hearing the consultation; and

  • take reasonable steps to prevent other people from accessing your device or consultation.

For privacy and professional reasons, sessions must not be audio- or video-recorded by either party without prior discussion and agreement.

The practice does not routinely audio- or video-record psychological consultations.

Telehealth may not be appropriate for every person or every situation. If another form or level of care is considered more appropriate to your circumstances, this will be discussed with you and, where appropriate, referral or alternative support may be recommended.

9. Electronic Communication

The practice uses electronic systems to support booking, administration, communication and the delivery of services.

Electronic communication may carry privacy and security risks despite reasonable safeguards. Sensitive clinical information should therefore be communicated through the secure systems provided by the practice wherever practicable.

Email and SMS are primarily used for administrative communication and are not appropriate for urgent psychological or emergency assistance.

The practice will not ordinarily provide clinical advice or manage emergencies through email, text message or other routine administrative communication channels.

10. Storage and Security of Information

Clinical and administrative records are maintained using secure electronic systems, including Halaxy as the practice's practice-management and clinical record system, together with third-party service providers used to support the practice.

Halaxy may be used for functions including appointment management, online intake, clinical records, clinical notes, billing, payment administration and other practice-management functions relevant to your care.

Reasonable steps are taken to protect personal and health information from:

  • misuse;

  • interference;

  • loss;

  • unauthorised access;

  • unauthorised modification; and

  • unauthorised disclosure.

The practice does not ordinarily retain permanent paper-based clinical records on-site.

Access to client information is limited to circumstances in which access is required for the provision or administration of services, professional obligations, or where access is otherwise authorised or required by law.

11. Third-Party Service Providers

The practice uses secure third-party providers to support booking, practice management, clinical record keeping, payment processing, electronic communications, telehealth and other administrative functions.

These providers may process personal information on behalf of the practice.

The practice takes reasonable steps to select and use service providers with appropriate privacy and security arrangements and to ensure that personal information is handled consistently with applicable privacy obligations.

Third-party providers and their technology arrangements may change from time to time as the practice develops and maintains its systems.

12. Cross-Border Data Storage and Processing

Some third-party service providers used by the practice may store or process personal information outside Australia.

Where personal information is disclosed to an overseas recipient, the practice will take reasonable steps to ensure that the information is handled in accordance with applicable Australian privacy obligations and any relevant contractual or other safeguards.

The location and processing arrangements of third-party technology providers may change from time to time.

Where practicable, information about relevant overseas data handling arrangements will be reflected in this Privacy Policy or otherwise made available to you.

13. Access to and Correction of Information

You have rights to request access to personal and health information held about you, subject to any applicable legal exceptions.

You may also request that information be corrected if you believe it is inaccurate, incomplete, out of date or misleading.

You may request access to or correction of your information by contacting the practice. Requests may be made in writing or through another appropriate communication method agreed with the practice.

Requests will be considered and managed in accordance with applicable privacy legislation, professional obligations and any lawful exceptions to access.

Where appropriate, reasonable steps will be taken to facilitate the transfer or management of your information to another practitioner, with your consent and in accordance with applicable legal requirements.

14. Data Retention

Client records are retained in accordance with applicable legal, professional and regulatory requirements.

Consistent with the Psychology Board of Australia's Code of Conduct for psychologists:

  • adult client records are retained for at least seven (7) years from the date of the last entry in the record; and

  • where the client was under 18 years of age when the last entry was made, records are retained until after the client's 25th birthday, or for any longer period required by applicable legislation.

After the applicable retention period, records will be securely destroyed or de-identified where appropriate and permitted.

15. Data Breaches

The practice takes reasonable steps to prevent unauthorised access to, loss of or disclosure of personal information.

If a suspected data breach occurs, appropriate steps will be taken to contain and assess the incident and to reduce any potential harm.

Where an eligible data breach occurs that is likely to result in serious harm and the requirements of the Notifiable Data Breaches scheme are met, the practice will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law.

Information about a notifiable data breach will include, where required, details about the nature of the breach, the types of information involved and steps affected individuals can take in response.

16. Complaints and Privacy Concerns

If you have a concern about how your personal or health information has been collected, used, stored or disclosed, please contact the practice in the first instance.

The practice will consider and respond to privacy concerns in accordance with applicable privacy legislation and professional obligations.

If you are not satisfied with the response, or wish to make a complaint directly to the privacy regulator, you may contact the Office of the Australian Information Commissioner (OAIC).

Information about making a privacy complaint is available at:

Office of the Australian Information Commissioner – Privacy complaints

17. Continuity of Care and Practice Closure

Reasonable arrangements will be made to support continuity of care if the practice becomes temporarily unavailable, relocates, closes or if the therapeutic relationship needs to end.

Where appropriate, this may include helping clients identify alternative practitioners and, with the client's consent, facilitating the transfer of relevant information.

Client records will be managed, transferred or retained in accordance with applicable legal, privacy and professional requirements.

18. International Clients and Services

Where services are provided to clients located outside Australia, additional legal, regulatory, privacy or professional requirements may apply depending on the client's location.

Before commencing services with an international client, the practice may consider whether the service can appropriately and lawfully be provided to a person in that jurisdiction.

International wellbeing support services are distinct from Australian Medicare-funded psychological services and do not constitute emergency or crisis care.

19. Updates to This Policy

This Privacy Policy may be updated from time to time to reflect changes in legislation, professional standards, technology, third-party service providers or practice procedures.

The most current version will be available on the practice website.

Privacy Policy last updated: August 2026