Privacy Policy

It can take a lot to open up. So you should know how we look after what you tell us. This policy covers our online psychology and counselling services. It covers this website, the Get Matched questionnaire, our booking system and every psychology, counselling, ADHD assessment and couples and family session we provide.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). As a health service based in Victoria, we are also bound by the Health Records Act 2001 (Vic) and its Health Privacy Principles. If you live in another state or territory, its health records law may also apply.

In this policy, "we", "us" and "our" mean 3 Star Symphony Pty Ltd, trading as The Symphony Clinic.

Who we are

• Legal name: 3 Star Symphony Pty Ltd
• Trading name: The Symphony Clinic
• ABN: 44 703 105 435
• Registered address: 5 Blessington Parade, Lalor VIC 3075
• Privacy Officer email: [email protected]
• Phone: 1300 704 901

We are a telehealth clinic. All sessions happen by video or phone. We don't have a consulting room you can visit.

What we collect

We only collect what we need to provide your care and run the clinic.

Personal information. Your name, date of birth, gender, address, phone number and email. An emergency contact. Payment details. Your Medicare, DVA or private health fund details if you are claiming. Your GP's name and practice.

Health information. This is sensitive information under the Privacy Act. It gets a higher level of protection. For us it includes:

• what you tell your clinician before and during sessions
• the notes your clinician writes after each session
• intake forms, questionnaires and assessment results, including those from an ADHD assessment
• any diagnosis, formulation or treatment plan
• referrals, Mental Health Treatment Plans and letters to or from your GP or other practitioners
• assessment reports and other correspondence about your care
• your mental and physical health history, and any medicines you tell us you take
• appointment details: who you saw, when, for how long and whether it was by video or phone
• Medicare and health fund claims made for your sessions

We may also hold other sensitive information if you choose to share it and it's relevant to your care. That could include your cultural background, religion or sexual orientation.

Website information. When you use this site, we may collect technical details such as your browser, device and the pages you visit. See Cookies, analytics and pixels.

How we collect it

We collect information directly from you wherever we can. That happens when you:

• book an appointment or fill in an intake form
• talk with your clinician in a session
• send us a message through this website
• phone, email or text us
• submit your Get Matched answers to us

Sometimes we receive information from other people. This could be your GP (for example, a referral or a Mental Health Treatment Plan), another practitioner involved in your care, a parent or guardian, or Medicare and your health fund. We only collect it this way when you have agreed, or when it isn't reasonable to collect it from you directly.

We will not collect health information about you without your consent, unless the law requires or allows it.

The Get Matched questionnaire

Get Matched asks a few short questions to suggest a service and clinicians. It isn't an assessment and it doesn't diagnose anything.

While you answer, your answers stay in your browser. We don't receive them. If you close the page at that point, nothing is sent.

At the end, you can choose to send your answers to us with your contact details. Your answers describe how you're feeling, so we treat them as health information. We ask for your consent with a tick box before you send them. We use them to follow up your enquiry and help you choose a clinician. We keep your answers only as long as we need them to respond to you and arrange your care. If you do book, they become part of your clinical record.

Dealing with us anonymously

Due to the nature of the health services we provide, it is generally impracticable for us to deal with individuals who have not identified themselves. Accurate identification is required to ensure the safety and continuity of clinical care, to comply with our legal and professional obligations under applicable health legislation, and to meet the requirements of Medicare and private health insurance billing.

You can still ask a general question without giving your name. You can also browse this site and use Get Matched without telling us who you are.

Information we did not ask for

From time to time, we may receive personal or health information that we did not solicit. Where we receive unsolicited personal information, we will promptly assess whether that information is of a kind we could have collected under our standard collection practices.

If it isn't, and the law doesn't require us to keep it, we will destroy it or de-identify it as soon as it is lawful and reasonable to do so.

How we use your information

We use your information to:

• provide your care and keep an accurate clinical record
• match you with a clinician and manage your appointments
• send appointment confirmations and reminders
• bill you and process Medicare or health fund claims
• communicate with your GP or other practitioners, with your consent
• meet our legal, professional and insurance obligations as health practitioners
• check and improve the quality of our service, including clinical supervision and audits
• respond to your questions and complaints

If we want to use your information for any other purpose, we will ask for your consent first. The exception is where the law requires or allows it.

When we review how the service is working, we use de-identified information wherever we can. That means information that no longer identifies you.

Who we share it with

Only people who need your information for your care, or to run the clinic, can see it. We don't sell your information. We don't share it with anyone for their marketing.

We may share your information with:

• your GP or other practitioners involved in your care, with your consent (for example, a report after an ADHD assessment or a progress update under a Mental Health Treatment Plan)
• another clinician at the clinic, if you change clinician or your clinician is away, and for clinical supervision
• Medicare, the DVA and your health fund, to process claims
• service providers who help us run the clinic, such as our booking system, video platform, payment processor, email provider, IT support and website host (they may only use it to provide their service to us)
• our insurers and professional advisers, where needed

Limits of confidentiality. What you say in a session stays private. There are a few situations where the law requires or allows us to share information without your consent. These are:

• where we believe there is a serious threat to your life, health or safety, or someone else's
• where a child may be at risk of harm and reporting laws apply
• where a court order, subpoena or other law requires it, including the Health Practitioner Regulation National Law
• to help locate a missing person, where the law permits
• to establish or defend a legal claim

Your clinician will explain these limits in your first session. That way you know them before you decide what to share.

Overseas disclosure

We aim to keep your health information in Australia. Some of the services we use to run the clinic may store or process data overseas. Under APP 8, we must tell you about this.

Some of the service providers we use, such as our booking, email, form and video systems, may store information outside Australia. Where they do, we take reasonable steps to make sure your information is protected in line with the Australian Privacy Principles.

If a provider stores or processes data outside Australia, we take reasonable steps first. We make sure it handles your information in line with the APPs. We will not send your health information overseas for any other reason without your consent, unless the law requires it.

Telehealth and your privacy

• Your clinician will confirm who you are at the start of your first session.
• Your clinician will ask if anyone else is in the room with you. You can ask them the same.
• Your clinician writes notes, and those notes form part of your clinical record. We don't record sessions. If that ever changes, we'll ask for your permission first. Please don't record a session unless everyone in it agrees in writing first.
• Please join from a private space if you can. We can't control the privacy of where you are or the network you use. Headphones can help.
• Video sessions run on our video platform. You'll get the link when you book.
• Telehealth doesn't suit every situation. If it isn't right for you, your clinician will tell you and help you find other options.

Couples and family sessions

In a joint session, everyone present hears what is said. In couples and family sessions, your clinician will explain how information shared in joint and individual sessions is handled before you begin.

Medicare and other identifiers

We collect your Medicare number, DVA number or health fund details so we can process claims. We may also use your Individual Healthcare Identifier where the law allows.

We only use and share these identifiers where the law permits. We don't use them as our own way of identifying you. Your record is kept under our own client number.

My Health Record

We'll talk with you before adding anything to your My Health Record. You can ask us not to upload anything.

Automated tools and AI

Get Matched uses your answers to suggest a service and clinicians. The suggestion is a starting point only. No automated tool makes a clinical decision about you. A clinician is responsible for every decision about your care.

If we use any automated or AI tools, a clinician reviews everything, and they never make clinical decisions.

We never put your personal or health information into public AI tools.

Direct marketing

We will only send you news or updates if you have said yes. That choice is a separate, unticked box on our forms. It is never part of your consent to care.

Every message has a way to unsubscribe. You can also ask us to stop at any time. We never use your health information to decide what marketing you receive.

Cookies, analytics and pixels

Visiting a mental health website can reveal something private about you. So we keep tracking to a minimum.

Advertising pixels. We don't use Meta, TikTok, Google Ads or any other advertising pixel on this site. We don't send your details to advertising platforms. If that changes, we'll update this policy first. We'll ask for your opt-in for each pixel. No pixel will run on pages about mental health concerns, our services, our articles, our clinicians, Get Matched or booking.

Analytics. If we use an analytics tool on this site, we'll list it here, with what it collects and how to opt out.

Your choice. If we use analytics or a pixel, the site asks you first with a banner. Nothing loads unless you choose Allow, and the site works the same if you decline. You can change your answer at any time with Cookie settings at the foot of every page. We remember your choice in your browser for up to 12 months, then ask again.

Your browser. The site stores a small amount of information in your browser. It notes the link that brought you here for up to 30 days. If that link came from an ad, this can include an ad click code from Google or Meta. The code is sent to us with your form. We don't send it on to any ad platform. The site also counts form submissions to help stop spam.

You can block or delete cookies and stored data in your browser settings at any time. The site will still work.

This site may link to other websites. Their own privacy policies apply there, not this one.

How we protect your information

We store your records electronically. Access is password protected and limited to people who need it for your care or for administration. Everyone who works with us must keep your information confidential.

No system is completely secure. Email and web forms can be intercepted. Please don't send detailed health information through our contact form or by email. Your clinician can talk with you about it in a session instead.

Data breaches

We are covered by the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.

If we suspect a breach, we act quickly to contain it. We assess it within 30 days. If it is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as soon as practicable. We will tell you what happened and what you can do to protect yourself.

How long we keep records

We keep health records for the periods the Health Records Act 2001 (Vic) requires:

• for adults, at least 7 years after the last time we provided you with a service
• if we collected the information while you were under 18, until you turn 25, or 7 years after your last session if that is later

We may keep records longer if the law requires it, for example during a legal matter. When records are no longer needed, we destroy them securely or de-identify them.

Accessing and correcting your information

You can ask for a copy of the information we hold about you. You can also ask us to correct it if it's wrong, out of date or incomplete.

To ask, contact our Privacy Officer in writing. We'll check your identity before we release anything. We aim to respond within 30 days.

Asking costs nothing. If giving you access has a cost, such as preparing a large file, we'll tell you the amount before we go ahead.

In a few cases the law lets us refuse access. One example is where access could pose a serious threat to someone's life or health. In that case we may offer to give access through another health practitioner you choose. If we refuse, we'll explain why in writing and tell you how to complain.

Complaints

If you're unhappy with how we've handled your information, please tell our Privacy Officer. We'll acknowledge your complaint as soon as we can and aim to respond within 30 days.

If you're not satisfied with our response, you can contact:

• the Office of the Australian Information Commissioner (OAIC), on 1300 363 992 or at oaic.gov.au. The OAIC usually asks that you raise it with us first.
• the Health Complaints Commissioner in Victoria, on 1300 582 113 or at hcc.vic.gov.au. It handles complaints about health records and health services.
• Ahpra, on 1300 419 495 or at ahpra.gov.au, if your concern is about a registered psychologist's conduct. If you live in New South Wales, contact the Health Care Complaints Commission. If you live in Queensland, contact the Office of the Health Ombudsman.
• if your concern is about a counsellor, the professional counselling association they are registered with

If you live outside Victoria, you can also contact the health complaints body in your state or territory.

Making a complaint will not affect your care.

Changes to this policy

We review this policy at least once a year, and whenever the law or the way we work changes. The date at the top shows when it was last updated. If we make a significant change, we'll let current clients know.

Our Terms and conditions explain booking, fees and cancellations.

If anything here is unclear, just ask. We're happy to talk it through. You can contact our Privacy Officer at [email protected] or call 1300 704 901.