OUR PRIVACY POLICY
Eloff & Andrew Pty Ltd atf Eloff & Andrews Unit Trust, trading as Eloff & Andrews Clinical Psychology, ABN 11 287 216 414 and its related entities recognise that the right to privacy of all persons is very important. This Privacy Policy sets out the key elements of how we comply with the Australian Privacy Principles, particularly in terms of the treatment of personal information that we collect and/or hold. Eloff & Andrews Clinical Psychology must comply with the Australian Privacy Act, and the Australian Privacy Principles, as amended from time to time.
ELOFF & ANDREWS CLINICAL PSYCHOLOGY PRIVACY POLICY
Eloff & Andrews Clinical Psychology has adopted a “holistic” privacy policy. Notwithstanding this, some parts of Eloff & Andrews Clinical Psychology’s operations, may develop specific Privacy Policies for their day-to-day operations. As stated previously, all Eloff & Andrews Clinical Psychology’s Privacy Policy documents must comply with the relevant legislation.
LEGISLATION
Privacy Act 1988 (Cth)
Privacy Amendment (Enhancing Privacy Protection) Act 2012
Notifiable Data Breaches (NDB) Scheme
Freedom of Information Act 1982 (FOI Act)
ACKNOWLEDGEMENT OF OUR PRIVACY POLICY
Our obligations under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 is to comply with the Australian Privacy Principle 1.4 which requires us to set out our policies on the management of personal information in a clearly expressed document which is free of charge to anyone who asks for it.
We respect your personal information and your right to privacy. This Privacy Policy describes the information that may be collected by us and how we protect your personal information.
Should there be, in any specific case, any inconsistency between this statement and the Act, this statement shall be interpreted, in respect of that case, to give effect to, and comply with the legislation.
JOB APPLICANTS AND EMPLOYEE RECORDS
Eloff & Andrews Clinical Psychology may collect personal information from job applicants for the primary purpose of interviewing, evaluating or employing job applicants.
Personal Information may include but not limited to resumes, superannuation, banking and educational details. Eloff & Andrews Clinical Psychology may also store information provided by job applicants who were unsuccessful for the purposes of future recruitment.
On occasion there may be a requirement to collect and store sensitive personal information from prospective employees or contractors such as criminal record searches. This data will be destroyed once it is no longer required or needed.
Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record held by the employing entity. As a result, this Privacy Policy does not apply to Eloff & Andrews Clinical Psychology’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between Eloff & Andrews Clinical Psychology and employee.
CHILDREN AND MINORS
All reasonable steps will be taken that personal information will not be collected by any person who is known by the organisation to be under the age of fifteen (15) without the consent of a parent or legal guardian.
Persons under age fifteen (15) may only provide personal information with the involvement and consent of a parent or legal guardian.
VULNERABLE COMMUNITY SEGMENTS
All reasonable steps will be taken to ensure sensitive personal information will not be collected from known vulnerable community segments without their express consent, or if they are unable to give consent, consent is obtained from a legal guardian.
THE KIND OF PERSONAL INFORMATION WE COLLECT AND HOLD
Generally speaking, the Personal Information we collect is used by us to operate Eloff & Andrews Clinical Psychology. The Personal Information we collect about you is mostly used for performing our professional services, billing, identification, authentication, and for contacting you if we need to. This information can include your name, gender, date of birth, country of birth, addresses, telephone numbers, email addresses, and credit and banking details.
Where reasonable and relevant, we collect any special categories of personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, criminal convictions, information about your health, and genetic and biometric data.
Personal information means information we hold about you from which your identity is either apparent or can be reasonably determined. We may collect non-personal information from you, such as browser type, operating system, and web pages visited to help us manage our web site.
Many of our services, consultations, and meetings are recorded via notes. On rare occasions videocalls may also be recorded. Any images of people attending and participating in our services and/or meetings, or other recordings, for example as above, will not be used or shown in part for promotional purposes, resource material and commercial activities.
We may, with consent, use email addresses to share news, tips, updates and special offers. People who receive these promotional emails can unsubscribe at any time.
We may use other data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of other data as “personal data” under applicable data protection laws. Where this is the case, we will process other data only for the same purposes as “personal data” under this Privacy Policy.
Other potential ways we may use your Personal Information:
To deliver customer service and assist you with any inquiries you may have.
To analyze trends, administer or optimise Eloff & Andrews Clinical Psychology, monitor usage or traffic patterns and gather demographic information about our user base as a whole.
To control unauthorised use or abuse of Eloff & Andrews Clinical Psychology resources—or otherwise detect, investigate or prevent activities that may violate our policies or be illegal.
We work with third-party services in Australia and the rest of the world (such as our web host, data backup and payment provider) that we allow access to Personal Information, and may use it on our behalf strictly for the purposes for which they are engaged. We minimise the amount of personal data that is utilised by these services, and we have ensured that these services process your data in accordance with the appropriate regulations.
HOW WE COLLECT AND HOLD PERSONAL INFORMATION
We directly collect Personal Information if you send an enquiry to us from our website, get in touch with us by chat, email, or phone. We may also collect some Personal Information if you engage with us through a mutual associate referral.
We use cookies and other internet technologies to manage our website, social media pages and certain online products and services. We do not use these technologies to collect or store personal information unless you have opted in to such a feature.
Our internet server logs the following information which is provided by your browser for statistical purposes only:
The type of browser and operating system you are using
Your Internet Service Provider and top level domain name
The address of any referring website; and
Your computer’s IP address.
All this information is used by Eloff & Andrews Clinical Psychology for aggregated statistical analyses or systems administration purposes only. No attempt will be made to identify users of their browsing activities, except where required by or under law.
COOKIES
A “cookie” is a packet of information that allows the Company server to identify and interact more effectively with your computer.
When you access our web site, we send you a temporary or “session cookie” that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s Internet browser type and your Internet Service Provider. Shortly after you end your interaction with our website, the cookie expires. This means it no longer exists on your computer and therefore cannot be used for further identification or access to your computer.
Without cookies certain personalised services cannot be provided to users of our website, accordingly you may not be able to take full advantage of all of the Company website features if cookies have been disabled.
LINKS TO OTHER SITES
The Eloff & Andrews Clinical Psychology website may contain links to other external sites. We are ultimately not responsible for the privacy practises or the content of such external websites. We encourage you to read and understand the privacy policies on those websites prior to providing any information to them.
THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We use personal information you provide only for purposes consistent with the reason you provided it, or for a directly related purpose. Generally, we will not use your personal information to market to you unless we have either your implied or express consent but in situations where it is impractical to obtain your prior consent, we will ensure you have an ability to opt out of such future communications.
We do not share your personal information with other organisations unless you give us your express consent, or where sharing is otherwise required or permitted by law, or where this is necessary on a basis to enable our contractors to perform specific functions.
Generally, Eloff & Andrews Clinical Psychology will collect personal information directly from you, and only to the extent necessary to provide a product or service, or to carry out our internal administrative operations.
We may collect personal information from you when:
You fill in an application form, or register for a service or event;
Acquire goods or services through our website;
Deal with us over the telephone;
E-mail us;
Ask us to contact you after visiting our website; or
Have contact with us in person.
You may also be able to transact with us anonymously or use a pseudonym where this is lawful and practicable. We will collect personal information from you by lawful and fair means and not in an unreasonably intrusive way.
We will use your personal information only for the particular purpose that you provided it, or for a directly related purpose. We may otherwise use your personal information where that other use is:
Required or permitted by law; or
With your express or implied consent.
PERSONAL INFORMATION WE COLLECT INDIRECTLY
We indirectly collect Personal Information when someone uses our services to record data about someone other than themselves.
This information can include names, genders, dates of birth, countries of birth, residential addresses, telephone numbers, email addresses, a person’s emergency contacts, health insurance numbers, and patient treatment notes and records. This can include sensitive information such as health records.
DIRECT MARKETING AND YOUR PRIVACY
We only conduct direct marketing utilising healthcare information with your direct consent. We will always give you a choice to opt out of receiving such information in the future.
From time to time we may use the non sensitive personal information we collect from you to advise you of, for example, conferences, events, products and/or services, which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. We will generally only do this with your consent, and we will always give you a choice to opt out of receiving such information in the future.
ELECTRONIC MARKETING
Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or implied consent. You may give us your express consent by, for example, ticking a box on an electronic or paper form where we seek your permission to send you electronic or other marketing information.
VIDEOS / PHOTOGRAPHS
Images of individuals in photographs or film are treated as personal information under the Privacy Act where the person’s identity is clear or can reasonably be worked out from that image. We uphold that all photographs and video footage of individuals will be used solely for Eloff & Andrews Clinical Psychology related purposes. In accordance with the Privacy Act, an individual’s consent will be sought if the photograph or video records sensitive information about the individual. Where practically possible, Eloff & Andrews Clinical Psychology will seek the consent of individuals in other cases. If you would like to have a video or still image removed from any material, please contact us using the contact details below.
YOUR PRIVACY PREFERENCES AND CHOICES
Every personalised marketing contact sent or made by Eloff & Andrews Clinical Psychology will include a means by which customers may opt out of receiving further marketing information. You may instruct us at any time to remove any previous consent you provided to receive marketing communications from us.
INFORMATION SHARING
We have a strict duty to maintain the privacy of all personal information we hold about you. However, certain exceptions do apply. For example, where disclosure of your personal information is:
Authorised or required by law, e.g. disclosure to various government departments and agencies such as the Australian Taxation Office, Centrelink, Child Support Agency or disclosure to courts under subpoena.
In the public interest, e.g. where a crime, fraud or misdemeanour is committed or suspected, and disclosure against the customer’s rights to confidentiality is justified.
With your consent, this may be implied or express, verbal or written.
USE OF THIRD PARTY SERVICE PROVIDERS
When we provide personal information to companies who perform services for us, such as specialist information technology companies or other contractors to the Company we require those companies to protect your personal information as diligently as we do.
UPDATING YOUR INFORMATION
It is inevitable that some personal information which we hold will become out of date. We will take reasonable steps to ensure that the personal information which we hold remains accurate and, if you advise us of a change of details, we will amend our records accordingly.
ACCESS TO YOUR PERSONAL INFORMATION
Eloff & Andrews Clinical Psychology will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type/s of information requested.
Eloff & Andrews Clinical Psychology will deal with your request to provide access to your personal information in a reasonable time of receipt of your request.
Eloff & Andrews Clinical Psychology will not charge you for lodging such a request but we may recover from you our reasonable costs incurred in supplying you with access to this information.
You can request access to the Personal Information you have provided to us, via email. This enables you to receive a copy of the data and to check that we are lawfully processing it.
If you think there’s a problem with the Personal Information we hold about you, you will either have the tools available to make these changes, or you can request a correction. This enables you to have any incomplete or inaccurate data we hold about you corrected (though we may need to verify the accuracy of the new data you provide to us).
If you want to request erasure of your Personal Information, we'll take all reasonable steps to do so unless we are required to keep it for legal reasons, which will be notified to you, if applicable, at the time of your request. As we only collect information that is required, it is likely that revoking your consent will limit the functionality of your service.
Should you require to move your data to another service, you may request the transfer of your data (including Personal Information) to you or to a third party. We will provide to you, or a third party that you have chosen, your data in a structured, commonly used, machine-readable format.
You may withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. This will be notified to you at the time of your request if applicable.
EXCEPTIONS
Your right to access your personal information is not absolute. In certain circumstances, the law permits us to refuse your request to provide you with access to your personal information, such as circumstances where:
Access would pose a serious threat to the life or health of any individual;
Access would have an unreasonable impact on the privacy of others;
The request is frivolous or vexatious;
The information relates to a commercially sensitive decision making process;
Access would be unlawful; or
Access may prejudice enforcement activities, a security function or commercial negotiations.
SECURITY
All reasonable steps will be taken to keep secure any personal information, which is held or transmitted. Security measures are taken to protect your information from misuse, interference and loss and from unauthorised access, modification or disclosure.
Where we have given you, or where you have chosen security codes (e.g. username, password, memorable word or PIN), which enable you to use any online service, you are responsible for keeping these security details confidential.
On an regular basis, Eloff & Andrews Clinical Psychology will perform a periodic technical and nontechnical evaluation that establishes the extent to which Eloff & Andrews Clinical Psychology or Eloff & Andrews Clinical Psychology’s business associate's security policies and procedures meet the security guidelines of the Office of Australian Information Commission for the Australian Privacy Principles.
The public internet is not a secure method of transmitting information. Accordingly, no responsibility is accepted for the security of information you send to or receive from us over the internet or for any unauthorised access or use of that information.
Should Eloff & Andrews Clinical Psychology discover a breach of data held, reasonable steps will be taken to notify those affected by the breach as soon as possible including how the breach occurred, possible effect and data affected, time of breach/es and remedies taken in accordance with Notifiable Data Breaches (NDB) scheme. To the extent permissible at law, in the event that there is a breach and indirectly collected information is at risk, we will follow the same protocol, however the affected Customers (rather than the individuals) will be notified instead.
DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS
If Eloff & Andrews Clinical Psychology transfers personal information to countries outside Australia, we will only do so in compliance with all applicable Australian data protection and privacy laws.
Eloff & Andrews Clinical Psychology will take reasonable steps to protect personal information no matter what country it is stored in or transferred to. We will have procedures and data transfer contracts as appropriate to help ensure this.
COMPLAIN ABOUT A BREACH OF THE AUSTRALIAN PRIVACY PRINCIPLES
Eloff & Andrews Clinical Psychology is committed to working to obtain a fair resolution of any complaint or concern about privacy.
To contact us with a compliment, complaint or a privacy question, you can write to us at: Unit 201/67 Regatta Boulevard, Birtinya QLD 4575, or call the Eloff & Andrews Clinical Psychology: (07) 5357 9108
Alternatively, If you are not satisfied with the response you receive from Eloff & Andrews Clinical Psychology you may contact the Office of the Australian Information Commissioner (OAIC) by:
Writing to GPO Box 5218, Sydney, NSW, 2001; or Calling 1300 363 992.
CHANGES TO THIS PRIVACY POLICY
This policy is current from November/2021. Eloff & Andrews Clinical Psychology may amend this Privacy Policy from time to time. We suggest that you visit our website regularly to keep up to date with any changes.