Privacy Policy

Purpose

Creative Growth Therapies (CGT) is committed to protecting your privacy of personal information that is collected in the provision of services to you. When using the term "you", we refer to you as a parent/carer/guardian, your child, or an adult enquiring about or attending the service.

 

As a private health care provider, we are required to comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), as well as the Privacy Amendment Act 2012, the Privacy and Personal Information Protection Act 1998 (NSW) and the Health Records and Information Privacy Act 2002 (NSW) to protect your privacy and personal information (including health information), as well as complying with relevant professional ethical codes of conduct. 

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In order to provide therapy services to clients, Creative Growth Therapies will need to use and collect personal information. Creative Growth Therapies relies on clients to provide accurate information. If clients withhold or provide inaccurate personal information to Creative Growth Therapies, clients need to be aware this could impact the ability of Creative Growth Therapies to provide the service that is requested or required. 

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The Creative Growth Therapies Privacy Policy is underpinned by the APPs which outlines our obligations in managing personal information that we hold about clients, potential clients, employees, suppliers, contractors, and others. Any information provided, including identification of individuals, will be used only for the purpose/s intended and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.

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Definitions

“Personal Information” includes a broad range of information, or an opinion, that could identify an individual. “What is personal information” will vary depending on whether a person can be identified or is reasonably identifiable in the circumstance. For example, personal information may include:

·  An individual’s name, signature, address, phone number or date of birth

·  Sensitive information

·  Credit information

·  Employee record information

·  Photographs

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Sensitive information is also personal information, however special protection applies to this type of information. For example, sensitive information may include:

·  Racial or ethnic origin

·  Political opinions or associations

·  Religious or philosophical beliefs

·  Trade union membership or associations

·  Sexual orientation or practices

·  Criminal record

·  Health and genetic information

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Policy

At Creative Growth Therapies, we take the privacy and personal information of the adults, parents, carers and children who visit us, and our suppliers very seriously. We won’t discuss you or your child's or give you or your child’s personal information to any individual, company or organisation outside of Creative Growth Therapies unless you’ve provided us with your written consent or we are legally obliged to under a Court Order.

 

Importantly, in the case of divorced or separated parents, we will ask to see Parenting an/or Court Orders to see who has the legal authority for the child and we will undertake a risk assessment to see if there are any exceptions to seeking consent from both parents.  We will only share information relating to the assessment and treatment of the child with the other parent and/or carers if we have the consent of the initial party or are legally obliged to disclose specified information.

 

We’ll never sell or trade your personal data to third party list brokers or direct marketing companies. We’ll do our very best to ensure that your personal data is kept safe and secure for as long as your details are in our care. Once our relationship has been concluded, Creative Growth Therapies will destroy or de-identify personal information due to redundancy, after our legal obligations to retain the information have expired.

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What kinds of personal information does Creative Growth Therapies collect?

In general, the type of personal information Creative Growth Therapies collects and holds includes (but is not limited to):

• Adults/Parent’s/carer’s names, marital status, occupation(s), child’s/children’s names and dates of birth, adult/parent and child’s home and postal address(es), adult/parent’s email address(es), mobile number(s), home telephone number(s), work number(s) and facsimile number(s).

• Adult diagnosis and reason for referral

• Child’s diagnosis and reason for referral

• General practitioner or referring doctor/practitioner 

• Other health professionals and agencies involved 

• Adult/parent work details

• School or kindergarten details 

• Your Medicare and private health fund details

• Any information relating to Federal Government Healthcare Programs (e.g. Medicare or NDIS), insurer or any other entity providing funding (this may include information about your income or information about other payments or benefits you receive)

• Bank account and/or credit or debit card details where this is provided to us for the purpose of making payments or receiving health fund or other payments or rebates

• Transaction details associated with services we have provided to you

• Any additional information provided to us by you

• Any information you provided to us through client surveys

• Other information which assists us in conducting our business, providing and marketing our services and meeting our legal obligations.

• We may also collect "sensitive information", as defined above

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Why does Creative Growth Therapies collect personal information?

Creative Growth Therapies collects personal information in order to conduct its business, to provide and market its services and to meet its legal obligations. We won’t use your personal data for any purpose that you have not agreed to, without first letting you know how and why we’d like to use your details. If that were to occur, we would always request your verbal and/or written permission first.

 

Information is used for:

• Setting up client profiles on our Practice Management Software

• Billing either directly or through a third-party agency

• When a handover is required between therapists across practices

• Communicating with other Health Care Professionals or others involved in the child’s care (after third party consent has been received)

• Audit purposes

• To liaise with NDIA, NDIS, Health Funds, Medicare

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When will Creative Growth Therapies collect personal information?

Creative Growth Therapies will usually gather personal information about children and families:

• When an adult or parent/carer/guardian books a child in for an assessment/therapy

• During the course of providing services

• When an adult or child, parent or family uses the Creative Growth Therapies website (e.g. when they fill out a referral form or subscribe to an online newsletter).

 

About whom does Creative Growth Therapies collect personal information?

The type of information Creative Growth Therapies may collect and hold includes (but is not limited to) personal information about:

• Clients (adults, parents/carers/guardian and children) and potential clients

• Employees, prospective employees and contractors

• Business associates

• Suppliers and their employees, and

• Other people who come into contact with Creative Growth Therapies

 

How does Creative Growth Therapies collect personal information?

Creative Growth Therapies will generally collect personal information with your agreement by way of telephone conversations, forms filled out either in hard copy or on-line, in face-to-face meetings, assessments, interviews, business cards and from third parties. In some circumstances Creative Growth Therapies may be provided with personal information about an individual from a third party, e.g. a report provided by a medical professional or a referral from another professional.

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Does Creative Growth Therapies use Commonwealth government identifiers?

We will not use Commonwealth government identifiers, such as Medicare numbers as our own identifiers of individuals.  We will only use or disclose identifiers in the circumstances permitted by the Privacy Act (Cth).

 

Website collection

Creative Growth Therapies collects personal information from the website https://www.creativegrowhtherapies.com through referral forms, emails or newsletter subscription. Creative Growth Therapies also uses third parties to analyse traffic at that web site, which may involve the use of cookies. Creative Growth Therapies may create links to third party websites and is not responsible for the content or privacy practices employed by websites that are linked from Creative Growth Therapies. 

 

How might Creative Growth Therapies use and disclose your personal information?

Creative Growth Therapies may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act 1988.

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In general, Creative Growth Therapies uses and discloses your personal information for the following purposes:

• To conduct its business

• To provide and market its services

• To communicate with you

• To provide treatment and care to you or your child

• To assist your treating health professionals to provide treatment and care to you e.g. speech pathologists, psychologist, counsellors 

• To assist us to provide you with information about your care, if required

• To assist with our internal administrative requirements

• To process Medicare, NDIS and private health fund claims

• To supply information to medical practitioners and other allied health professionals who provide necessary follow up treatment and ongoing care

• To conduct research and development

• To conduct service planning

• To communicate offers and special events

• For general marketing purposes

• To help us manage and enhance our services

• To comply with our legal obligations

 

To whom might Creative Growth Therapies disclose your personal information?

Creative Growth Therapies may disclose your personal information to:

• Other members of the Creative Growth Therapies team

• Legal practitioners, courts, tribunals and regulatory authorities, and

• Anyone else to whom you authorise us to disclose it to

• Creative Growth Therapies also collects personal information from these organisations and individuals, and will deal with that information in accordance with this Policy.

 

How does Creative Growth Therapies keep personal information accurate and up-to-date?

Creative Growth Therapies endeavours to ensure that the personal information we hold is accurate, complete and up-to-date. We encourage you to contact us to update any personal information we hold about you. Creative Growth Therapies works in partnership with a range of government departments and health services and is required by law to pass on certain information about clients.

 

We must also adhere to the laws of Mandatory Reporting, and therefore must notify relevant authorities about certain issues (e.g. child protection). External and internal quality auditors may view a small amount of personal information to check that Creative Growth Therapies is meeting its obligations for accreditation.  Auditors are bound by their own and/or Creative Growth Therapies confidentiality requirements.

 

In some cases, we share stories about Creative Growth Therapies clients/ families through training, newsletters, or publications. We will always seek your written permission to do this and will tell you exactly how your information will be shared.

 

Sending information overseas

Creative Growth Therapies will not send your personal information to recipients outside of Australia without:

• Obtaining your consent (in some cases this consent will be implied), or

• Otherwise complying with the APPs.

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Access to information

Clients may request access to their personal information held by Creative Growth Therapies by writing to the Business owner via email. Creative Growth Therapies will require you to verify your identity and to specify what information you require. In some instances, a fee may be charged for providing access. We will advise you of the likely cost in advance. Where we hold information that clients are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you may collect (e.g. information that we go through with you in person, by post or in-person collection). If you believe that personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request amendments. We will consider if the information requires amendment and if we do not agree, we will add a note to the personal information stating your disagreement with the information.

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In some circumstances, the Privacy Act entitles us to deny access to yours/your child's personal information. For example, we can't give you access if providing the information would:

• Unreasonably affects someone else's privacy

• Pose a serious threat to someone's life, health or safety

• Prejudice the taking of appropriate action in relation to suspected unlawful activity or serious misconduct. or

• Adversely affect our position in relation to legal proceedings or negotiations in which we are involved

 

Management of personal information

The APPs require Creative Growth Therapies to take reasonable steps to protect the security of personal information. Creative Growth Therapie personnel are required to respect the confidentiality of personal information and the privacy of individuals. As such, all staff sign a confidentiality agreement upon employment at Creative Growth Therapies. Creative Growth Therapies takes reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Where Creative Growth Therapies no longer requires your personal information for a permitted purpose under the APPs, they will take reasonable steps to destroy it. 

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Questions or complaints about the handling of private information

If you have any questions about this Privacy Policy or about how your information is handled, please contact us using the information below.

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If a person has a complaint regarding the way in which their personal information is being handled by Creative Growth Therapies, in the first instance they are to contact the Business Owner. The complaint will be dealt with as per the Complaints Management Policy (Please request a copy if you would like to read it). If the parties are unable to reach a satisfactory solution through negotiation, the person may request an independent person (such as the Office of the Australian Privacy Commissioner) or the NDIS Quality and Safeguards Commission to investigate the complaint. Creative Growth Therapies will provide every cooperation with this process.

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Questions/complaints:

Lucinda Mora, Business Owner

Telephone: 0436 659 475

lucinda@creativegrowththerapies.com

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