Privacy Policy

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 The Source Holistic Therapies

1. Purpose and Scope

The Source Holistic Therapies is a social holistic health organisation providing counselling support, and complementary therapy, anywhere and anytime. This policy sets out how we collect and treat your personal information. This Policy explains how The Source Holistic Therapies complies with the relevant Australian Federal, State and Territory Acts and Legislation in relation to the collection, use, disclosure, and handling of your personal information. This Policy does not apply to the collection or use of information about corporations.

2. Statement

We are committed to protecting the privacy of individuals who use our services. However, due to the nature of some of our services, it may be necessary for us to collect personal data to facilitate the therapist in meeting the clients’ needs as best possible. We respect your privacy. The Source Holistic Therapies respects your right to privacy and is committed to safeguarding the privacy of our clients and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). 

3. Types of information we collect

3.1 Personal Information

Personal information that we collect, and hold is information that is reasonably necessary for the proper performance of our functions and activities in providing remote professional counselling services, and face to face therapy.

While the type of personal information we collect and hold may vary depending on the nature of our interactions with you, we may collect the following information at a minimum for every interaction

· Your phone number for telephone counselling and support

· Your email address for alternative means of contact

If you choose not to share this information with us, we may not be able to provide you with the counselling and support you need.

Additional information we may collect will generally include the following:

· your name, date of birth and address

· e-mail addresses

· comments and feedback

· interests and communication preferences

· other personal information collected to provide a health and counselling support service

You may choose not to share any additional information with us; or alternatively, use a Pseudonym for your interaction with us.

3.2 Sensitive Information and Health Information

Subject to this Policy, we may also collect and hold sensitive information and/or health information disclosed by you, including (but not limited to):

· physical, mental, or psychological health of an individual

· a disability of an individual

· sexual preference / gender identity

· political or religious views

· membership or affiliation with an industry union

4. Collection

We collect information only by fair and lawful means where it is reasonable and practicable to do so. We do so to conduct our organisation, effectively deliver our services, to provide accurate information to you, to market our goods and to meet our legal obligations.

If you do not provide us with information that we reasonably request, we may not be able to provide the requested services in the most efficient manner possible, or at all. We also may not be able to provide you with the information about the services that you may want.

4.1 How we collect Information

a) We collect information that you provide:

· when visiting our website at https://thesourceholistictherapies.com/

· in applications you lodge with us

· during telephone, video, in person, or online conversations with us

· through transactions conducted with us; and

· in written correspondence to us (including email correspondence)
 

b) We also collect information provided by third parties when it is necessary for a specific purpose, such as checking information that you have given us or where you have consented, or would reasonably expect us, to collect your information in this way.

If it is unclear to us whether you have consented to the collection of information from a third party, we will take reasonable steps to contact you to ensure that you are aware of the reason and purpose of the collection.

c) We will also collect information about you if we are required to do so under an Australian law. If so, we will inform you of this, where practicable, including details of the law requiring the collection.

4.2 Internet usage

It is important that you understand that there are risks associated with use of the internet and you should take all appropriate steps to protect your information. You can contact us by telephone or post if you have concerns about making contact via the internet. We may use cookies and web beacons when you visit our website (https://thesourceholistictherapies.com/) and, therefore, we may collect certain information from you such as:

· your browser type

· your location

· your IP address

· information about when and how you use our website

· your computer, device, and connection information, such as browser type and version, operating system, mobile platform and unique device identifier and other technical identifiers; URL click stream data, including date and time, and content you viewed or searched for; and

· information about your past internet usage, such as websites you visit before coming to our website. You can manage the use of cookies on our website (https://thesourceholistictherapies.com/) by clicking “help” on the toolbar in your internet browser. However, if you block the use of cookies, you may not be able to log in or make full usage of our website.

4.3 Disposal

TSHT shall have processes in place for destruction of, or de identification of personal and health information to prevent unauthorised access following retention periods. 

4.4 Unsolicited Information

Where we receive unsolicited information about you, we will check whether that information is reasonably necessary for our functions. If it is, we will handle this information in the same way we do other information we seek from you. If not, we will destroy or de-identify it.

5. Use

5.1 Personal Information

We 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 relevant Federal, State or Territory Act or legislation that applies.

In general, we use and disclose your personal information to:

· conduct our organisation

· provide our services to you

· market our organisation and services

· communicate with you and assist you with enquiries

· comply with our legal obligations

· help us manage and enhance our service standards

· gain an understanding of your needs

· respond to requests, inquiries, complaints, or applications

· update you on relevant new services and benefits

· personalise the service and to select content to be communicated to you

· contact you regarding our services or other services from third parties

· invite you to participate in surveys, sweepstakes, competitions, and similar promotions

· conduct website administration, such as for the technical support of our websites and computer systems

· conduct data analysis and audits

· identify usage trends and analyse the effectiveness of our promotional campaigns

· prevent and detect security threats, fraud, or other malicious activity

· comply with our legal obligations, resolve disputes, and enforce our agreements.

5.2 Sensitive Information and Health Information

We will not collect Sensitive Information and Health Information about you unless:

· we obtain your consent to collect and use such sensitive information and/or health information; or

· the sensitive information and/or health information is reasonably necessary for one or more of our functions or activities; or

· the collection of the sensitive information and/or health information is required or authorised by or under Australian law or a court/tribunal order; or

· a permitted general situation exists in relation to the collection of the sensitive information by us; or

· a permitted health situation exists in relation to the collection of the sensitive information by us.

If you do not consent to these Policy terms, we may not be able to provide services to you.

5.3 TSHT Services and Consent

If you engage with a TSHT service (by any means including, but not limited to, in person, by telephone, online chat, video) you will be:

· informed if your interaction with us will be digitally recorded and electronically stored by us, which may include the collection of your information

· informed that information you provide is subject to the terms of this Policy and where you can read this Policy; and

· provided with the opportunity to consent or not consent to these Policy terms.

If you do not consent to these Policy terms, we may not be able to provide services to you.

5.4 Disclosure

We may only disclose your information (including producing documents) to another person, entity, authority, or government body if:

· we are required to do so by an Australian law;

· we are ordered to do so by a court/tribunal order; and/or

· there is an immediate or imminent risk of serious harm to you, an identified third party and/or the general public.

· you have disclosed to us that you or another person has engaged in, or is planning to engage in, suspected unlawful activity or serious misconduct.

· Where a permitted general or health situation exemption applies under the Federal Privacy Act 1988
 

Disclosure to Related Entities and Service Funders
We may disclose information to our related entities and service funders according to the contractual obligations of our service agreement with each of those affiliated organisations. Where practicable, this information will be de identified.

6. Marketing and Internal Use

We may use and/or disclose your information in order to:

· provide you with news and information about our services and our organisation generally

· conduct counselling supervision and/or ongoing professional development (provided such information is de-identified);

· provide you with marketing and promotional material that we believe you may be interested in; or

· seek your feedback on our services.

Only with your express consent will we use or disclose information about you for the purposes of direct marketing. You can ask us not to do this at any time by contacting us at privacy@thesourceholistictherapies.com. We will never sell your information.

7. Storage and Security

We take reasonable steps to protect your information against misuse, interference, loss, unauthorised access, modification, and disclosure. The protective steps we take include:

· confidentiality requirements 

· document and file storage security 

· security measures for restricted access to our systems; and

· deletion, destruction, or de-identification of information where it is no longer required by us.

8. Corrections

We aim to ensure that the information we hold is accurate, complete, and up to date. We encourage you to contact us in order to update any information we hold about you. Our contact details are set out at the end of this Policy. If you contact us regarding an apparent inaccuracy in relation to your information and we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, then reasonable steps will be taken to correct the information within 30 days, or a longer period as we agree with you in writing. If a correction is made to any information that was previously disclosed to a third party, as long as it is reasonable to do so, we will give each such recipient written notice of the correction within a reasonable period. We will also notify you that the correction has been made.

8. Access to your Information

You are entitled to access your information held by us.

If you wish to access your information, you must lodge a written request for access by contacting The Source Holistic Therapies by email on privacy@thesourceholistictherapies.com Your request must contain your name and address, the contact number you used to access our services, sufficiently identify the information you wish to access. You will be provided with access to the information within 30 days of the request (unless unusual circumstances apply).

We are not required to give you access to your information if:

· it would be unlawful to do so; or

· denying access is required or authorised by an Australian law or a court/tribunal order; or

· to do so would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

If we do not give you access to your information you will receive written notice that explains the reason for the refusal.

9. Complaints

Complaints about alleged breaches by us of a relevant Australian Federal, State or Territory Act, legislation related to Information Privacy, or this Policy can be made by contacting The Source Holistic Therapies via

Phone: (03) 53093289

Email: privacy@thesourceholistictherapies.com

10. Access to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing environment that our organisation operates in. The most current version of this Policy will be uploaded to our website at https://thesourceholistictherapies.com/privacy or can be obtained by contacting The Source Holistic Therapies as above.