Privacy Policy

1. Introduction

  • Your Practitioner and Provider have adopted this Policy in accordance with the privacy law.
  • This Policy outlines how Provider deals with Personal Information, which it collects in conjunction with the Services.
  • Provider may also collect information about Individuals who do not use the Services.
  • Capitalised words in this Policy are defined terms. Defined terms are explained at the end of this Policy.

2. Collecting information directly from people

Provider collects Personal Information directly when an Individual:

  • contacts Provider by telephone, fax, email or another from of communication;
  • gives Provider his or her information in person on a paper or electronic form, including a client intake and claiming form;
  • sends the Provider a message through SMS or a third party app;
  • registers or subscribes for an account;

Provider also collects Personal Information directly when:

  • Provider’s server and analytics service may log details about website visits; and
  • Provider’s website places a cookie on an Individual’s device or store Individuals’ I.P. addresses.

3. Collecting information from third parties

  • Provider collects Personal Information about Individuals from third parties when:
  • third parties give Provider access to files containing Personal Information;
  • psychologists manage records about an Individual using the Services;
  • Provider is given written or verbal information from a teacher, a medical practitioner or health practitioner, EAP provider or other referral source; and
  • parents and guardians provide information about their children or children in their care.  

4. Types of Information that Provider collects and holds

Using processes described in this Policy, Provider collects the following categories of Personal Information about Individuals:

  • (Content) whatever Personal Information is included in content Individuals share using Provider’s Services;
  • (Identity Information) name, signature, date of birth, nationality, license & registration details, Medicare details, private health insurance, member details, bank account and credit/debit card details, family details, employment details, educational information, usernames;
  • (Contact Information) email address, social media profiles, telephone & fax number, third-party usernames, residential, Provider and postal addresses;
  • (Internet Data) webpage views, IP address, referring web site addresses, location, browser type, operating system, domain name, access times and other data typically collected by analytics services like Google Analytics;

5. Sensitive Information

Privacy law categorise certain types of Personal Information as “sensitive information”, including:

  • information or an opinion (that is also Personal Information) about an Individual’s:
    • racial or ethnic origin;
    • political opinions;
    • religious beliefs or affiliations;
    • philosophical beliefs;
    • criminal record; and/or
    • sexual orientation or practices;
  • health information about an Individual, including:
    • any information or opinion about the Individual’s health, health services, or wishes regarding health care; and
    • information collected to provide, or in providing, a health service of any kind.

Provider collects health information from Individuals in providing the Services. If Individuals disclose other sensitive information to their Practitioner, this may be included in records and sometimes managed by the Provider. Practitioners, not the Provider, take responsibility for storing sensitive information disclosed to them during appointments (ie casenotes or session records).

6. How Provider stores Personal Information

Provider holds and stores Personal Information using:

  • (Storage Services) third party data storage services with servers basd in Australia and overseas including, but not limited to, Google Email and applications, Amazon Web Services Sydney Data Centre, Halaxy or Powerdiary (practice management software), National Australia Bank (NAB) Transact, Asana, Xero and any other applications and software used for business operations;
  • (Provider Devices) devices operated by contractors to and employees of Provider’s business; and
  • (Paper Files) printed paper and files.

7. Security

Provider will take reasonable precautions to protect Personal Information from unauthorised access. This includes measures to secure the Provider’s physical facilities and electronic networks. Provider secures Personal Information that Provider collects with requirements and agreements between Provider and employees and contractors used by the provider.

Provider limits access to personal information to those with a valid reason for using that information. Provider’s document storage includes security measures such as passwords, pins, encryption, session expiries, firewalls, SSL network encryption, SSL certificate and website transmission encryption, the use of reputable vendors (eg Amazon, Google, Halaxy, Powerdiary), physical locks and storage on physical files and datacentres housing servers.

Amazon security information:

Google security information:

Halaxy security information:

Powerdiary security information:

National Australia Bank security information:



For more information on security, please contact Provider using the details in the “contacting us” section below.

8. Deletion Procedures

  • Provider deletes Personal Information when considered appropriate under relevant state and national laws.
  • Provider’s deletion process:
  1. Provider identifies all digital records relating to the individual and delete them from these digital storage media; and
  2. Provider identifies any paper records relating to the individual and shred these onsite or personally de-identify them.
  • Records relating to adult clients will be kept for seven years following the date of last contact and records regarding children are to be kept until the child attains the age of 25 years. 
  • Provider has certain obligations under Australian law to retain some client information for a prescribed period of time.

9. Why data is held, used and disclosed

Provider’s handling of Personal Information includes holding, using and sometimes sharing the Personal Information so that Provider can:

  • facilitate the booking of appointments with psychologists;
  • manage records about Individuals’ appointments and psychological health and treatment;
  • offer surveys and questionnaires;
  • transact with Individuals and process payments;
  • facilitate medicare and health insurance claims;
  • assess and improve the Services; and
  • provide secure access to the Services.
  • For more information on when Provider shares Personal Information, see below.

10. Disclosing Personal Information

Provider shares Personal Information with others in the following ways:

  • sharing information with the treating health practitioners, governmental institutions including Medicare and private healthcare insurers; and
  • sharing information with administration staff and business service providers and contractors to provide services.

11. Information requests in relation to family court orders and parent plans

Provider has a clear process for verifying the identify of any person requesting information in relation to a person under 18 years, if they are not the parent or caregiver that has initiated the engagement of our services, as well as verify that person’s right to access information about a child with written evidence, to ensure that we only share information with people who are appropriately authorised to access this information about a child.
Changes Psychology process for actioning information requests:
Step 1. We need to receive copies of the following documents via email or post, from people that have not personally initiated the engagement of a child with our services, before we are able to communicate any information in relation to a person under 18 years who is accessing our services:
  1. A clear scanned copy of your drivers licence or Passport so we have evidence of your identify
  2. A full copy of the family court order with your personal details as they appear on your proof of identity – please indicate which section/s or clause/s describe accessing health related information in relation to the child mentioned in the order
  3. A letter from you stating your full name date of birth, the child’s name and date of birth, your relationship to the child and that you wish to request a written overview of health information in relation to this child and the purpose for this information request. Please note we only provide written overviews for information requests.
Step 2. As the contents of a written overview takes a psychologist time to carefully prepare and check over, and typically takes them 1.5 hours, we charge an information request service fee of $300 (1.5 hours @ our hourly rate of $200) to prepare and provide this overview.
  1. We need to receive full payment t before commencing the preparation of this document via this secure payment link
  2. We will provide the overview within 10 business days of receiving payment to prepare the document
  3. This overview is not an assessment or report, as we have a company policy to not provide assessments or reports for family court and custody related purposes
  4. As we are bound my our professional code of ethics to maintain confidentiality of the child and the parent who has engaged treatment from us, the overview will not contain records or transcriptions of information any parties have communicated in confidence. The overview will discuss the findings of any assessments conducted, interventions provided and recommendations the treating psychologist has made in regards to the child engaged in treatment.
Note: All information requests must meet the requirements stated above, and if they don’t, we will not be able to provide information in relation to any person under 18. Further emails or calls from anyone requesting information, will not remove the need to follow the processes outlined above, and alls such communications will be ignored or reported to the authorities if they are persistent or threatening in any way.

12. Service providers can access personal information

When Provider uses the services of companies that Provider works with to provide the Services, they may get access to the Provider’s data, including Personal Information. Such third party services may include:

  • (Hosting) Cloud and web hosting service providers (see Amazon Web Services, Google applications, Ventra IP, Health Kit Practice Management Software;
  • (SaaS) providers of software as a service;
  • (Support) administration staff and contractors, IT support services, web and software development staff and contractors;
  • (Data analytics) Google Analytics (see [](;
  • (Online payment) National Australia Bank (NAB) provider of online payment system NAB Transact;
  • (Billing) private health insurers and Medicare; Halaxy practice management practice management software Medicare Australia, any private health insurer that accepts claims relating to services rendered in Australia.

Provider will only share Personal Information with these third parties to the extent reasonably necessary to perform their functions.These third parties may have their own privacy and security policies. For more information about this, please contact Provider using the details listed in the “contacting us” section below.

13. Contacting us

Individuals contact the Provider using the details below if they want to access, correct or delete Personal Information or lodge a complaint. Privacy Officer –

Provider reserves the right to refuse access or correction where there are reasonable grounds for doing so, for example if providing access would be unlawful or would compromise the privacy of another person.

14. Complaints process

If Individuals have a complaint about privacy, they can contact Provider using the details listed above.Provider will respond to complaints in writing within a reasonable period (usually 10 business days from the day Provider receives an email).

Provider will try to work with Individuals to resolve complaints entirely within 20 business days, although that period may be longer if it is reasonable to take longer given the nature of the complaint.

If Individuals are unsatisfied with our response, they may refer the complaint to the Office of the Australian Information Commissioner (

15. Amendment

Provider may amend the Privacy Policy at its sole discretion. Individuals that continue to use the Services after receiving notice from Provider of such an amendment, agree to be bound by the Privacy Policy as amended.

16. Definitions

Individual, Individuals

means a natural person.

Personal Information

means information about an Individual whose identity is apparent, or can reasonably be ascertained, from that information. This includes information like names, telephone numbers, email addresses and physical addresses.

Policy, Policies

means this document, drafted in accordance with the Privacy Act 1988 (Cth).


means Changes Psychology Pty Limited and its staff and contractors.

Service, Services

means the following services:

  • arranging appointments with qualified psychologists including telephone appointments, and home and school visits;
  • facilitating medicare and private health insurance claims in relation to appointments;
  • facilitating electronic payment for appointments;  and
  • managing the documentation and records associated with appointments.