Privacy Policy

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Terms

1. Purpose
1.1 The purpose of the Fuller Life Therapy Services Privacy Policy (hereinafter referred to as “the Privacy Policy”) is to explain to you how Fuller Life Therapy Services uses, collects and manages all personal information, including but not limited to your health information from patients and the circumstances in which Fuller Life Therapy Services may share such information with third parties.
1.2 The Privacy Act was significantly amended in 2014 by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and with effect from 22 February 2018, further amendments require Fuller Life Therapy Services to report eligible data breaches that are likely to cause serious harm.
1.3 Fuller Life Therapy Services is a health service provider and we are required to comply and abide with The Australian Privacy Principles (hereinafter referred to as “APP”) which has been enacted in accordance with the Privacy Act 1988 (hereinafter referred to as the “Privacy Act”).
1.4 The APP regulates how Fuller Life Therapy Services may collect, use, disclose, divulge and store your personal and health information which we retain with regards to patients.

2. Important Defined Terms
2.1 In this Privacy Policy, Fuller Life Therapy Services adopts the definitions in Section 6 of the Privacy Act, as amended from time to time, of the terms which we set out below;
Personal Information means all information and opinion including but not limited to personal and health information about an identified individual, or an individual who is reasonably identifiable:
• whether the information or opinion is true or not; and
• whether the information and opinion is recorded in a material form or not:
Health Information means all information and opinion about:
• the health and disability (at any time) of an individual; or
an individual’s expressed wishes about the future provisions of health services to him or her; or
• a health service provided or to be provided to an individual that is also personal information; or
• other personal information collected to provide, or in providing, a health service.
Sensitive Information would include information or an opinion about an individual’s:
• racial or ethnic origin; or
• political opinions; or
• membership of a political association; or
• religious beliefs or affiliations; or
• philosophical beliefs; or
membership of a professional or trade association; or
• membership of a trade union; or
• sexual orientation or practices; or
• criminal record
that shall be deemed also as personal information; or
• health information about an individual; or
• genetic information about an individual that is not otherwise health information; or
• biometric information that is to be used for the purposes of automated biometric verification or biometric identification; or
• biometric templates.
2.2 For the avoidance of any doubt, reference in this Privacy Policy to personal and health information is a collective reference to Personal Information and Health Information as herein defined in clause 2 above.

3. Patient Anonymity and Pseudonymity
3.1 Where it is lawful and practicable to do so by virtue of any rules, regulations or laws our clients may deal with Fuller Life Therapy Services anonymously or by using a pseudonym. An example of this, would be when you make a general inquiry about the services Fuller Life Therapy Services provides or offers to its clients without providing us with your personal or health information.

4. Why we collect, use, hold and share information and opinion about you
4.1 Fuller Life Therapy Services only collects and holds personal and health information about our clients that is deemed reasonably fit and necessary for us to:
• provide our clients with health care services and, in particular, to best attend to and treat the presenting health concerns and conditions; or
• contact our clients to provide advice or information in relation to the why in which the service will be provided; or
• administer and manage those services including charging, billing and collecting debts; and
• as required by Australian legislation.

5. Types of information we collect and store about you
5.1 We may collect personal and health information from third parties including, but not limited to:
• our client’s parent, guardian, legal advisor or other authorised representative; or
• other health service providers that our client has attended; or
ther health professionals that have treated our client; or
• a client’s family member; or
• other persons or organisations that possess personal and health information reasonably required by Fuller Life Therapy Services to assist us in providing health services to our clients.
5.2 The type of information that we collect about our clients include, but is not limited, to the following;
• names;
• date of birth;
• gender;
• residential address;
 emails;
• occupation;
• telephone numbers;
• medicare details;
• medical referrer details (for example; referring Obstetrician, General Practitioners, Dentists and Medical Practitioners); and
• any other personal and health information that is reasonably deemed fit and necessary for the provision of paediatric health services to you.
5.3 Fuller Life Therapy Services will not collect Sensitive Information about a client unless;
• prior consent to the collection of that type of information and that information is reasonably necessary for the provision of paediatric health services; and/or
• if we are required or authorised to do so pursuant to any Australian law, rules or regulations.

6. How we hold your information
6.1 Fuller Life Therapy Services stores your personal and health information in hard copy and electronic form including but not limited in its practice database software known as SPLOSE and no matter in which form your personal and health information is stored, the terms of this Privacy Policy will be applicable to that information.

7. How do we use your information
7.1  Fuller Life Therapy Services only uses your personal and health information for the purposes you have given that information to us unless disclosure of your personal and health information is required for the purposes of:
• continuity of care with other health service providers involved in our client’s treatment or diagnostic services; or
• providing a client with further information about treatment options; or
• conveying information to a responsible person including a parent, guardian or spouse when a client is incapable or cannot communicate, unless the client has requested otherwise;
• conveying information to close family members in accordance with the recognised customs of medical practice; or
management, funding, service monitoring, planning, evaluation and compliant handlings; or
• legislative and regulatory compliance; or
• quality assurance or clinical audit activities; or
• accreditation activities; or
• health insurance funding; or
• billing and debt recovery; or
• addressing liability indemnity arrangements including reporting to our insurers and legal representatives;
• preparing the defence for anticipated or existing legal proceedings; or
• research or the compilation or analysis of statistics relevant to public health
and safety; and
• activities directly related to the provision of health services to an individual where the individual would reasonably expect disclosure.

Independent Contractors
7.2 Fuller Life Therapy Services may outsource services or hire contractors to perform professional services within our practice and if we do so we require all contractors to comply with the Privacy Act and our Privacy Policy.

Direct Marketing and Research
7.3 Fuller Life Therapy Services may also use your information for other purposes such as including you on a marketing mail list, fundraising or research but only if you provide us with your prior consent to do so.

8. Access to and correction of your information
8.1 All client files that include personal and health information are the property of Fuller Life Therapy Services.
8.2 You have the right to have access to the personal and health information that we hold in your health record subject to certain legal exceptions, as set out in the APP 12 in relation to Access to Personal Information being;
• Fuller Life Therapy Services reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
giving access would have an unreasonable impact on the privacy of other individuals; or
• the request for access is considered or deemed frivolous or vexatious; or
• the information relates to existing or anticipated legal proceedings between Fuller Life Therapy Services and the individual, and would not be accessible by the process of discovery in those proceedings; or
• giving access would reveal the intentions of Fuller Life Therapy Services in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
• giving access would be unlawful; or
• denying access is required or authorised by or under an Australian law or a
Court or Tribunal Order; or
• Fuller Life Therapy Services has reasons to suspect that unlawful activity, or misconduct of a serious nature, that relates to Fuller Life Therapy Services’ functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
• giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
• giving access would reveal evaluative information generated within the organisation in connection with a commercially sensitive decision-making process.
8.3 Fuller Life Therapy Services may, on your written and signed request, disclose your personal and health information to your legal representative or other authorised representative.
8.4 You can also request an amendment to your personal and health information if you believe that information is inaccurate, out of date, incomplete or misleading.
8.5 Fuller Life Therapy Services will allow access or make the requested changes unless there is a reason under the Privacy Act or other relevant law to refuse such access or refuse to make the requested changes.
8.6 If Fuller Life Therapy Services does not agree to change your personal and health information in accordance with your request, we will permit you to make a written statement of the requested changes and file a copy of that statement on your medical record.
8.7 Should you wish to obtain access to or request changes to your health record you can ask our Privacy Officer (details as stated herein below in clause 14), who can give you more detailed information about Fuller Life Therapy Services’ access and correction procedure.
8.8 Fuller Life Therapy Services may charge you a reasonable fee associated with supplying a copy of your personal and health information to you.

9. Data Quality
9.1Fuller Life Therapy Services will take reasonable steps to ensure that your personal and health information that we collect are accurate, up to date and complete.
9.2 Fuller Life Therapy Services will take reasonable steps to ensure that your personal and health information that we use or disclose, having regard to the purpose of that use or disclosure, is accurate, up to date, complete and relevant.

10. Data Security
10.1 Fuller Life Therapy Services will take reasonable steps to protect your personal and health information from misuse, interference, loss, unauthorised access, modification or disclosure.
10.2 If Fuller Life Therapy Services holds personal and health information about you and we no longer need that information for any purpose for which that information many be used or disclosed, that information is not contained in a Commonwealth record and we are not required by or under an Australian law, or a Court or Tribunal Order, to retain that information, we will take such steps as are reasonable in the circumstances to destroy that personal and health information or to ensure that information is de-identified.

11. Identifiers
11.1 Fuller Life Therapy Services assigns its own identifiers, being a unique number within our practice database system SPLOSE to identify clients and/or a clients parent/guardian and, where appropriate, Fuller Life Therapy Services collects government identifiers such as Medicare, Health care/Pension Card numbers, Private Health fund membership number etc.

12. International Disclosure
12.1 Fuller Life Therapy Services may communicate with organisations outside of Australia and it may be necessary to make disclosure of a clients personal and health information to an organisation outside of Australia.
12.2 If Fuller Life Therapy Services makes disclosures of a clients personal and health information to an organisation outside Australia it will only do so if it is reasonably satisfied that the country has a substantially similar privacy regime to Australia.

13 Complaints
13.1 Fuller Life Therapy Services takes complaints and concerns regarding privacy seriously.
13.2 In the event:
• you have questions or comments about this Public Policy; or
• Fuller Life Therapy Services does not agree to provide you with access to your personal and health information; or
• you have a complaint about our information handling procedures,
You can lodge a complaint with or contact our Privacy Officer by using the contact
details as stated herein below in Clause 14.
13.3 You also have the legal right to lodge a complaint in writing to the Office of the Australian Information Commissioner (OAIC) by visiting www.oaic.gov.au and using the online Complaint Form or in writing and posted to:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
For further information kindly visit www.oaic.gov.au or call the OAIC on 1300 363 992.

14. Contact us
14.1 Privacy Officer
14.2 By Letter: PO Box 493, Marleston DC SA 5033
14.3 By Email: admin@fullerlifetherapyservices.com.au
14.4 By Telephone: 0433422404

15. Privacy Policy Version
15.1 This Privacy Policy was last updated on 30th December 2022 and may change from time to time in accordance with changes to the Privacy laws.
15.2 This Policy will be reviewed regularly to ensure that it is in accordance with any changes that may occur by virtue of any amendment to the Privacy laws.
15.3 The updated Policy can be requested by contacting Fuller Life Therapy Services to ensure that you have the latest version of this Privacy policy.

16. Data Breaches
16.1 Data breach occurs when there is an unauthorised access or disclosure, or loss of personal information held in our practice. This could be an email sent to the wrong person, a loss of laptop containing patients’ personal and health information or our database being hacked.
16.2 Effective from 22 February 2018, Fuller Life Therapy Services is required to investigate a data breach or suspected/alleged data breach and decide if it is likely to result in serious harm to one or more individuals. Fuller Life Therapy Services may be able to remedy the negative impact of the breach by retrieving an email sent incorrectly or by having good security in place depending on the type of data breach. In the absence of a remedy, Fuller Life Therapy Services has the legal obligation to notify the affected patient/(s) and the OAIC accordingly.