The Glow Centre takes the privacy of its clients very seriously and maintains security and confidentiality of all personal information consistent with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth). The procedures for the collection and management of personal information are clear and upheld by all staff, contractors and students.

​

Client information

​

1. Client files are held in secure filing cabinets, located in a lockable office; and on the secure practice management software system, Halaxy. Filing cabinets and Halaxy are accessible only to authorised employees, contractors and students. The information on each file includes personal information such as name, address, contact phone numbers, medical history, payment information, and other personal information collected as part of providing the psychological service.

2. Halaxy’s Privacy Policy can be read on their website: https://www.halaxy.com/article/privacy

3. Employees, contractors and students are bound by The Glow Centre’s Accessing Client Records Policy, which prevents them from accessing client records for any clients they are not directly involved in the care of.

4. All staff, contractors and students are bound by signed Confidentiality Agreements, and/or their own health practitioner guidelines and ethics that prevent the unauthorised disclosure of client information.

5. Clients’ entry and exit from The Glow Centre’s premises is recorded via CCTV using the security system, Ring. Monitoring of The Glow Centre’s foyer and reception area are conducted for security purposes. No surveillance or recording of consulting rooms, bathrooms or the kitchen is conducted. Video information collected by Ring is collected using encryption. Videos are stored securely in the cloud, can only be viewed by authorised users (the Director and Operations Manager of The Glow Centre), can only be accessed with two-step verification, and are permanently deleted from Ring servers after 60 days.

6. Ring’s Privacy Policy can be read on their website: https://en-uk.ring.com/pages/privacy

 

How clients’ personal information is collected

​

7. A client’s personal information is collected in a number of ways during treatment at The Glow Centre, including when the client provides information directly to the practice or their clinician using hardcopy forms, online forms, correspondence via email, correspondence via SMS; when attending The Glow Centre in person; when interacting directly with The Glow Centre employees, contractors or students; and when other health practitioners or stakeholders provide personal information to The Glow Centre via referrals, correspondence, and medical reports.

8. Telehealth sessions are not recorded by The Glow Centre or the Halaxy telehealth platform.

 

Consequence of not providing personal information

​

9. If the client does not wish for their personal information to be collected in a way anticipated by this Privacy Policy, The Glow Centre may not be in a position to provide services to the client. In some circumstances, clients may request to be anonymous or to use a pseudonym, unless it is impracticable for The Glow Centre to deal with the client or if The Glow Centre is required or authorised by law to deal with identified individuals.

 

Purpose of holding personal information

​

10. A client’s personal information is gathered and used for the purpose of providing psychological and social work services, which includes assessing, diagnosing and treating a client’s presenting issue. The personal information is retained in order to document what happens during sessions, and enables clinicians to provide a relevant and informed clinical service.

 

Disclosure of personal information

​

11. Clients’ personal information will remain confidential except when:

11.1 It is subpoenaed by a court, or disclosure is otherwise required or authorised by law;

11.2 Failure to disclose the information would in the reasonable belief of the clinician place a client or another person at serious risk to life, health or safety; or

11.3 The client’s prior approval has been obtained using The Glow Centre Authorisation to Request and Release Clinical Information (ARRCI) form:

11.3.1 Provide a written report to another agency or professional, eg a GP; or

11.3.2 Discuss the material with another person, eg a parent, employer, health provider, or third party funder; or

11.3.3 Disclose the information in another way; or

11.3.4 Disclose to another professional or agency (eg GP) and disclosure of the personal information to that third party is for a purpose which is directly related to the primary purpose for which the personal information was collected.

12. All of the above information related to the disclosure of personal information will be shared with clients in their initial online intake form and at their first session with their clinician.  

13. Clients’ personal information will not be used, sold, rented or disclosed for any other purpose.

14. In the event that unauthorised access, disclosure or loss of a client’s personal information occurs, The Glow Centre will activate its Data Breach Policy and use all reasonable endeavours to minimise any risk of consequential serious harm.

​

Requests for access and correction to client information

 

15. At any stage clients may request to see and correct the personal information about them kept on file. The clinician may discuss the contents with them and/or give them 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. All requests by clients for access to or correction of personal information held about them should be lodged with the Operations Manager. These requests will be responded to in writing within 14 days and an appointment will be made if necessary for clarification purposes.

 

Concerns

​

16. If clients have a concern about the management of their personal information, they may inform the Operations Manager. Upon request they can obtain a copy of the Australian Privacy Principles, which describe their rights and how their personal information should be handled. Ultimately, if clients wish to lodge a formal complaint about the use of, disclosure of, or access to, their personal information, they may do so with the Office of the Australian Information Commissioner by:

1. Phone on 1300 363 992

2. Online at http://www.oaic.gov.au/privacy/making-a-privacy-complaint

3. Post – OAIC, GPO Box 5218, Sydney NSW 2001.