Introduction

This privacy policy is to provide information to you, my client, on how your personal information (which includes your progress notes) is collected and used within my practice, and the circumstances in which I may share it with third parties. 

Why and when your consent is necessary 

When you register as a client of my practice, you provide consent for me and my practice staff to access and use your personal information so they can provide you with the best possible care. Only staff who need to see your personal information will have access to it. If I need to use your information for anything else, I will seek additional consent from you to do this. 

Why do I collect, use, hold and share your personal information? 

I will need to collect your personal information to provide therapeutic and other support services to you. My main purpose for collecting, using, holding and sharing your personal information is to manage your care. I also use it for directly related business activities, such as NDIS financial claims and payments, practice audits and accreditation, and business processes.

What personal information do I collect? 

The information I will collect about you includes your:

• names, date of birth, addresses, contact details 

• personal information including medical history, important life events, social history, family history and risk factors 

• NDIS number (where available) for identification and claiming purposes 

How do I collect your personal information?

My practice may collect your personal information in several different ways.

1. When you make your first appointment I will collect your personal and demographic information via our client information form. 

2. During the course of providing therapeutic and other support services, I may collect further personal information. 

3. I may also collect your personal information when you visit our website, send me an email or SMS, telephone me, make an online appointment or communicate with me using social media. 

4. In some circumstances personal information may also be collected from other sources. Often this is because it is not practical or reasonable to collect it from you directly. This may include information from:

• your guardian or responsible person

• other involved care providers, such as specialists, allied health professionals, hospitals, education services and community care services.

When, why and with whom do I share your personal information?

I sometimes share your personal information:

• with third parties who work with my practice for business purposes, such as accreditation agencies, clinical supervisors, or information technology providers 

• with other care providers

• when it is required or authorised by law (e.g. court subpoenas) 

• when it is necessary to lessen or prevent a serious threat to your life, health or safety or public health or safety, or it is impractical to obtain your consent

• to assist in locating a missing person

• to establish, exercise or defend an equitable claim

• for the purpose of confidential dispute resolution process 

• when there is a statutory requirement to share certain personal information (Child Safety and the Queensland Police Service sometimes require notification)

• during the course of providing care services, through Splose

Only people who need to access your information will be able to do so. Other than in the course of providing care services or as otherwise described in this policy, I will not share personal information with any third party without your consent.

I will not share your personal information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.

I will not use your personal information for marketing any of our goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying me in writing. 

I may use your personal information to improve the quality of the services I offer to my clients through research and analysis of my client data. 

I may provide de-identified data to other organisations to improve mental health outcomes, increase service provision and secure funding via grants. The information is secure, clients cannot be identified, and the information is stored within Australia. You can let me know if you do not want your information included. 

How do I store and protect your personal information?

Your personal information may be securely stored at my practice in various forms. These forms include paper and electronic records. 

My practice stores all personal information securely. Paper records are all stored within a locked cabinet inside a locked room. Electronic records are stored on a secure online system, Splose. Splose creates daily backups of data, encrypts it and stores it securely off-site. Splose is compliant with all relevant Australian Privacy legislation and requirements and uses industry-standard AES-256 encryption. 

Use of Artificial Intelligence

I use an AI-assisted feature within my practice management software, Splose, to support the administrative side of my work including case note writing and report writing. This section explains how and why I use it, and how your information is protected.

I do not audio or video record therapy sessions. All notes are taken by me, in writing, on my laptop during our session in the usual way.

After I have taken my own written notes during a session, I sometimes use Splose AI in one of the following ways:

• I ask Splose AI to help turn my written notes into asuccinct, objective, and appropriately general case note - one that documents what is clinically necessary without recording a detailed account of your personal disclosures, story, or the specifics of what we discussed. The detail of your story belongs to you, and it is your choice whether and how to share it elsewhere.

• On occasion, I maydictate a spoken summary of a session after it has ended (not a recording of the session itself) and use Splose AI to convert that summary into a formal case note.

In both cases, the AI is working from my summary or notes, never from a recording of you or an unfiltered transcript of the session.

I also use Splose AI to assist with drafting reports (for example, letters or reports for referrers, funding bodies, or other professionals). This helps me manage the time reports take to prepare, which in turn helps keep my fees lower and my service more accessible.

I also use this support as a disability-related accommodation for myself: I am dyslexic and have executive function difficulties, and AI assistance helps me structure, organise, and complete written case notes and reports more reliably and efficiently. This is part of how I manage my own access needs as a practitioner.

Regardless of how a report or note is drafted, I review, edit, and take full professional responsibility for its accuracy and content before it is finalised and sent.

Splose AI is a feature built into my existing practice management platform (Splose), rather than a separate, unrelated tool. Based on Splose's published documentation:

• Splose states that Splose AI complies with GDPR and Australian privacy regulations, including the Australian Privacy Principles (APPs).

• Data is encrypted both at rest (AES-256) and in transit (TLS 1.2+).

• Splose AI is powered by OpenAI, and Splose has a Business Associate Agreement with OpenAI requiring zero data retention, meaning submitted data is not used to train OpenAI's models or stored by OpenAI.

• Data is stored within Australia in line with local regulatory requirements, with hourly encrypted backups stored redundantly across multiple data centres.

You are welcome to ask me at any time for more detail about how Splose AI works, or to request that your notes be prepared without AI assistance.

If you would prefer that I do not use AI assistance for your case notes or reports, please let me know in writing and I will prepare all documentation manually instead.

How can you access and correct your personal information at my practice?

You have the right to request access to, and correction of, your personal information.

I acknowledge that you may request access to your records. I require you to put this request in writing and I will respond within 30 business days. 

I will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, I will ask you to verify that your personal information held by my practice is correct and current. You may also request that I correct or update your information, and you should make such requests in writing to me.

How can you lodge a privacy-related complaint, and how will the complaint be handled at my practice?

I take complaints and concerns regarding privacy seriously. You should express any privacy concerns you may have in writing. I will then attempt to resolve it in accordance with my resolution procedure. 

I can be contacted via:

• Email at hello@newleafsocialwork.com.au

You may also contact the OAIC. Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on 1300 363 992. 

Privacy and our website 

My website collects user data including your location, IP address, pages you visit on this website, and what operating system and device you use. This information helps me understand how people interact with my website. My website may contain information or links to other websites and service providers. I do not take responsibility for your use and engagement with these third parties. Please note the inclusion of third-party service information does not mean that I am endorsed by, or are endorsing, these parties. I take no responsibility for your privacy when accessing third party websites and services.