Publication date: Version 1.3 Jun 2021
About this Policy
References to “Brisbane City Psychologists”, “BCP”, “we”, “us” and “our” are references to Bcpsyc Pty Ltd ATF Brisbane City Psychologists Services Trust ABN 79 409 261 282. References to “you” and “your” are references to any individual about whom we collect personal information. References to “psychologist” and “psychology practice” are references to any independent psychologist or psychology practice that bases or based their own independent psychology practice at Brisbane City Psychologists and whom we provide or provided services and facilities.
When used in this Policy, “personal information” has the meaning given in the Privacy Act. Generally, it means any information or an opinion that could be used to identify you. Sensitive information is personal information that includes information or an opinion about, for example, your health, criminal record, sexual orientation, religious or philosophical beliefs, racial or ethnic origin, and political opinions.
What personal information we collect about you
At all times, we try only to collect the personal information we need for the particular function or activity we are carrying out. When you enquire about services provided by psychologists, we may collect your full name, date of birth, email address, phone number, and other personal information, including sensitive information, to help us assess whether any psychologist or psychology practice based at Brisbane City Psychologists is an appropriate service for you and send you information or resources. We collect additional personal information about you, including sensitive information, when you book an appointment with a psychologist or psychology practice based at BCP and during the course of treatment with them, for example, your address, emergency contact person, government-related identifiers such as Medicare or DVA numbers, social and medical history. We may also collect your bank account details and details of third parties involved in the management or funding of your appointments, for the purposes of administering your appointments payment arrangements.
We may collect personal information about you if you are a healthcare professional or healthcare service provider who have referred a client to a psychologist or who are providing services to a client of a psychologist or psychology practice based at BCP, such as your name, medical speciality or position within the organisation your work for, your Medicare provider number if applicable, your contact details.
We may collect personal information about you if you interact with us on a commercial basis, for example, service providers and contractors to BCP, or as a member of the public. The kind of personal information we collect will depend on the capacity in which you are dealing with us. Generally, it would include your name, your contact details, details and information regarding our interactions and transactions with you and details such as professional registration numbers, insurance certificates, among others.
How we collect your personal information
How we hold your personal information
Brisbane City Psychologists collects and holds your personal information in electronic form. Most of the information collected is stored in the corresponding psychologist or psychology practice’s systems. We also hold some of your personal information securely on our servers and computer systems. Some information may be collected in paper-based documents which may be converted to electronic form and the original paper copy destroyed in a secure manner when we no longer need it. Any personal information retained in paper-based documents is stored in our secure archive facilities in Brisbane. We are legally required to hold clients’ personal information for a minimum of 7 years from the date of last entry in your record or if you are a minor until you attain or would have attained 25 years of age.
How we protect your personal information
Your personal information held by Brisbane City Psychologists is maintained in a secure environment, which can be accessed only by authorised personnel. We take reasonable steps to protect the security of the personal information we hold, by:
- ensuring physical security over our paper and electronic data stores, such as locks and security systems, is maintained and enhanced where possible
- maintaining security systems, for example, by using a firewall, using passcodes to control access to electronic devices, and using two-factor authentication when available to access electronic systems
- taking reasonable steps to destroy or de-identify your personal information once we no longer need it
- conducting regular privacy and data security audits to assess whether we have adequately complied with and implemented these measures.
However, no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully secure. Additionally, we are unable to ensure the security of personal information that is left with you or provided to you, for example, a paper-based report or email sent to you.
Why we collect your personal information
We collect your personal information to carry out functions or activities such as:
- providing services and facilities to a psychologist or psychology practice based at BCP
- assessing whether a psychologist or psychology practice is an appropriate service for you
- sending you communications via SMS or email to, for example, remind you about appointments with your psychologist, provide you with treatment resources and questionnaires and send you a copy of your invoices
- enabling you to receive the correct entitlements to benefits and funding for psychology services from third-party payers and to comply with their requirements
- responding to your enquiries, requests or feedback
- updating your records and keeping your information up to date.
If you have any concerns about the personal information we have asked you to provide please let us know.
Disclosure of your personal information
There are circumstances where we may be permitted or required by law to disclose your personal information to third parties. Common situations in which we may disclose your personal information to third parties are when:
- you have consented to the disclosure; or
- we reasonably believe that disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety; or
- you would reasonably expect your personal information to be disclosed and disclosure to that third party is for a purpose directly related to the primary purpose for which your personal information was collected (see Why we collect your personal information), for example, to the ambulance service, government agencies and other third-party payers administering subsidies and benefits to which you may be entitled such as Medicare and Department of Veterans Affairs; or
- it is required or authorised by or under Australian law or a court/tribunal order.
We engage external service providers to us for the purposes of providing services to your psychologist and managing our business, including software providers, payment systems operators, IT and data security service providers, website hosting service providers, our insurers, our professional advisors such as accountants, bookkeepers, and lawyers. Your personal information may be used and disclosed to them to facilitate these arrangements.
Your personal information will not be used, sold, rented, or disclosed for any other purpose. Where we have collected a government-related identifier, such as your Medicare or DVA number, we will only use or disclose that identifier as required or permitted by law.
Some of the information collected by BCP may be stored in systems that utilise data hosting facilities outside of Australia. Any overseas recipient of your information may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles. BCP will not be accountable under the Privacy Act for any breach by the overseas recipient and you may not be able to seek redress in the overseas jurisdiction. In addition, the overseas recipient may be subject to foreign laws that could compel the disclosure of personal information to a third party, such as an overseas authority.
During the novel Coronavirus outbreak, if you or one of our staff or any of the psychologists based at our practice have tested positive for COVID-19, we may be required to inform local health authorities that you have been in the practice. If required, we will only provide the minimum information necessary and required by the health authorities for contact tracing purposes. Please check the following In-person appointments at the practice during the Coronavirus outbreak Terms and Conditions for more information.
Collecting your personal information through our websites
Access to personal information and correction
You can ask for access or correction of your personal information, if you believe it to be inaccurate, in writing and we must respond within 30 days. We may ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible.
Access to your personal information may be declined in accordance with privacy laws, for example, where giving you access would put you or another person at risk of harm. In this circumstance, we must notify you in writing setting out the reasons. We do not provide copies of information records without a court subpoena if they contain sensitive information that may be harmful if read without a psychologist present to explain the information appropriately. Where a person requesting access to your personal information is an authorised representative of yours, such as a lawyer or guardian, we will ask the representative to provide evidence of their authority. We may also ask you to provide current and informed consent to us before releasing your personal information.
We take reasonable steps to ensure that the personal information we hold about you is accurate, up-to-date and complete. If you believe it to be incorrect or out of date you can ask that we correct it. If it is not possible for us to correct it, you can ask us to associate with it, for example, attach or link a statement that you believe the information is incorrect and why. If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
Concerns and complaints about your privacy
Notifiable data breaches scheme
In the event of any unauthorised access or unauthorised disclosure or loss of your personal information that is likely to result in serious harm to you or other individuals, we will investigate and notify you and the Office of the Australian Information Commissioner in accordance with the Privacy Act.
Queries, complaints, requests for access or correction should be made in writing and sent to:
Brisbane City Psychologists – Bcpsyc Pty Ltd ATF Brisbane City Psychologists Services Trust
Level 18, 141 Queen Street, Brisbane QLD 4000