Neil Locke is committed to protecting your privacy and handling personal and health information respectfully, securely and transparently.
 

This Privacy Policy explains how personal information is collected, used, stored and disclosed in connection with counselling, coaching and occupational therapy services provided by Neil Locke, including services provided under the Neil Locke — Counselling & Coaching and Authentic Me Therapy and Coaching names.
 

The practice handles personal and health information in accordance with applicable Australian privacy legislation, including the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and, where applicable, the Health Records Act 2001 (Vic).
 

Information I may collect
 

The information collected depends on the services you use and may include:

• your name, date of birth and contact details;

• appointment and booking information;

• billing and payment information;

• information you provide through enquiries, intake forms or questionnaires;

• health, disability and other sensitive information relevant to providing services;

• information about your circumstances, relationships, family, work, goals and concerns;

• clinical notes and records of counselling or occupational therapy services;

• coaching notes and information relevant to coaching services;

• assessments, reports and other documents provided by you or, where appropriate, another person or professional;

• correspondence between you and the practice;

• information provided by a parent, guardian, family member, referrer, health professional, school, support provider or other person where relevant and permitted;

• information required to meet professional, legal, insurance or regulatory obligations; and

• limited technical information generated when you use the websites, such as IP address, browser/device information and website usage information.
   

I aim to collect only information that is reasonably necessary for providing services or operating the practice.
 

How information is collected
 

Where practicable, personal information is collected directly from you.
 

This may occur when you:

• make an enquiry;

• book an appointment;

• complete an intake or consent form;

• participate in a counselling, coaching or occupational therapy session;

• provide documents or other information;

• communicate by email, telephone, video consultation or another agreed method; or

• use one of the practice websites.
   

Information may also be received from another person or organisation where you have consented to this, where it is reasonably necessary to provide a health service, or where collection is otherwise permitted or required by law.
 

Depending on the service, this could include information from a parent or guardian, family member, referrer, GP or other health professional, school, support provider, plan manager or other relevant person.
 

Why information is collected and used
 

Personal information may be collected, held and used to:

• respond to enquiries;

• assess whether the service is appropriate for you;

• arrange and manage appointments;

• provide counselling, coaching and occupational therapy services;

• understand your circumstances, goals and needs;

• maintain appropriate clinical and business records;

• communicate with you about your services;

• prepare reports or correspondence where agreed or required;

• process payments and maintain financial records;

• communicate with other professionals or people involved in your care where appropriate and authorised;

• meet professional, insurance, regulatory and legal obligations;

• manage complaints, concerns and risk;

• maintain and improve the administration and security of the practice; and

• operate and understand use of the practice websites.

Health information will not be used for direct marketing without the consent required by law. Australian privacy protections place additional restrictions on the use of health information for direct marketing.
 

Confidentiality and disclosure
 

Information discussed during counselling, coaching or occupational therapy is treated as confidential.
 

Personal or health information may be disclosed where:

• you have consented to the disclosure;

• disclosure is reasonably necessary for the purpose for which the information was collected or for a directly related purpose you would reasonably expect;

• disclosure is necessary to another provider or service involved in your care and is permitted by law;

• disclosure is required or authorised by law, including in response to a valid court order, subpoena or other legal requirement;

• there is a serious threat to your life, health or safety or that of another person and disclosure is permitted by law;

• disclosure is otherwise permitted under applicable privacy or health-records legislation; or

• information needs to be provided to professional advisers, insurers or service providers for legitimate practice purposes and appropriate privacy protections apply.

Where appropriate and practicable, I will discuss disclosure with you before information is shared.

These exceptions reflect that Australian health information can sometimes lawfully be disclosed without consent, including where required by law or in circumstances involving a serious threat to life, health or safety.

Technology and service providers

The practice uses third-party technology providers to operate efficiently and securely. Depending on how you interact with the practice, these may include:

• Splose for practice management, appointments, forms, records, communication and related administrative functions;

• Google services, including Google Meet, for videoconferencing and relevant business communication;

• Wix for operation of NeilLocke.me;

• website hosting and technology providers associated with AuthenticMe.com.au;

• payment-processing providers where electronic payment is used;

• email and communication services; and

• OpenAI/ChatGPT, as described below.
   

These providers may process or store information on infrastructure located in Australia or overseas.
 

I take reasonable steps when selecting and using service providers to protect the privacy and security of personal information. However, information transmitted or stored electronically carries inherent security risks and no electronic system can be guaranteed to be completely secure.
 

Use of artificial intelligence
 

Artificial intelligence tools, including OpenAI's ChatGPT, may be used as part of the practice's professional and administrative workflow.
 

AI may assist with tasks such as organising information, drafting or structuring clinical notes, preparing session material, considering possible areas for further exploration, drafting correspondence, and other administrative or professional-support tasks.
 

AI does not replace my professional judgement or responsibility for the services I provide. I remain responsible for reviewing clinical records, recommendations, correspondence and other professional work produced with the assistance of AI.
 

Where personal or health information is processed using an AI service, I take reasonable steps to use the technology in a manner consistent with applicable privacy, confidentiality and professional obligations.
 

AI is not used to independently make significant clinical or other decisions about you. Decisions about your services remain subject to human professional judgement.

Information processed through AI services may be processed or stored using infrastructure outside Australia. This is addressed further under Overseas processing and disclosure below.
 

If the practice's use of AI changes materially, this Privacy Policy will be reviewed and updated.
 

Telehealth
 

Counselling, coaching or occupational therapy may be provided by videoconference or telephone where appropriate.
 

Telehealth involves electronic transmission of information and therefore carries some privacy and security risks. Reasonable steps are taken to use appropriate technology and protect confidentiality.
 

You are responsible for choosing a location that provides an appropriate level of privacy at your end of the consultation.
 

Technical problems, internet disruptions or other limitations may occasionally affect telehealth sessions. If telehealth is not appropriate for a particular situation, this will be discussed with you.
 

Storage and security
 

Reasonable steps are taken to protect personal and health information from misuse, interference, loss, unauthorised access, modification and disclosure.
 

This may include use of password-protected systems, access controls, secure practice-management systems and appropriate physical security for any paper records.

Access to personal information is limited to people who require it for legitimate practice purposes.
 

Where third-party systems are used, their privacy and security arrangements are considered as part of deciding how they are used within the practice.
 

Australian privacy law requires health service providers to take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
 

Record retention and destruction
 

Clinical and health records are retained for the period required by applicable legislation and professional obligations.
 

For health information covered by Victorian legislation, this generally means records relating to an adult are retained for at least seven years after the last occasion on which a health service was provided, while records relating to a person who was under 18 when the health service was last provided generally need to be retained until that person reaches 25 years of age.
 

When personal information is no longer required to be retained, reasonable steps are taken to securely destroy or de-identify it where permitted by law.
 

Accessing or correcting your information
 

You may request access to personal information held about you or ask for information that is inaccurate, out of date, incomplete, irrelevant or misleading to be corrected.
 

In some circumstances, access may be limited or refused where permitted or required by law. If this occurs, the reasons and available options will generally be explained to you.
 

Requests can be made using the contact details below.
 

Australian privacy law provides rights to seek access to and correction of personal information, subject to specified exceptions.
 

Anonymity and pseudonyms
 

Where lawful and practicable, you may make general enquiries without identifying yourself or may use a pseudonym.
 

However, it will generally be impracticable to provide ongoing counselling or occupational therapy without sufficient identifying information to maintain appropriate health records, manage appointments and provide safe professional services.
 

APP 2 expressly requires the option of anonymity or pseudonymity where lawful and practicable.
 

Overseas processing and disclosure
 

Some technology providers used by the practice may operate infrastructure, service providers or data-processing facilities outside Australia.
 

As a result, personal information may in some circumstances be processed by or accessible to service providers located overseas, including in the United States and other countries in which the relevant technology providers operate.
 

Where overseas processing or disclosure occurs, reasonable steps are taken as required under applicable Australian privacy law.
 

Because technology providers and their infrastructure can change, it may not always be practicable to identify every country in which information may be processed. This policy will be updated where a material change to the practice's information-handling arrangements occurs.
 

Website information, cookies and analytics
 

The practice websites may automatically collect limited technical information about visits, including IP address, device or browser information, referring pages and interactions with the website.
 

Cookies or similar technologies may be used where necessary for website functionality, security, performance or analytics.
 

Third-party services integrated with the websites may also collect information in accordance with their own privacy policies.
 

The practice does not sell personal or health information to advertisers.
 

If advertising, tracking or analytics technologies used by the websites change materially, this Privacy Policy and any necessary cookie or consent arrangements will be reviewed.
 

Information about children
 

Authentic Me Therapy and Coaching provides services that may involve children and young people. Personal and health information about children is handled with particular care.
 

Depending on the child's age, capacity and circumstances, consent may be obtained from a parent, guardian or the young person themselves as appropriate and required by law and professional obligations.
 

Information about a child may sometimes need to be shared with a parent, guardian or another person involved in their care. How confidentiality operates will depend on the child's circumstances, capacity, the nature of the service, consent arrangements and applicable legal and professional obligations.
 

NeilLocke.me is primarily directed towards adult counselling and coaching, while services involving children and young people are generally provided through Authentic Me Therapy and Coaching.
 

Data breaches
 

The practice takes reasonable steps to prevent privacy and data-security breaches.
 

If a suspected or actual breach occurs, it will be assessed and managed in accordance with applicable privacy legislation, including the Notifiable Data Breaches scheme where applicable.
 

Where a breach is likely to result in serious harm and notification is legally required, affected individuals and the Office of the Australian Information Commissioner will be notified as required.
 

Privacy complaints
 

If you have a concern about how your personal or health information has been handled, please contact me in the first instance.
 

I will take the concern seriously, investigate it where appropriate and endeavour to respond within a reasonable period.
 

If you are not satisfied with the response, you may be entitled to make a complaint to an external body including the:

Office of the Australian Information Commissioner (OAIC) for matters concerning the Privacy Act and Australian Privacy Principles

or

Health Complaints Commissioner Victoria (HCC) for matters concerning the handling of health information under Victorian law.
 

Changes to this policy
 

This Privacy Policy may be updated from time to time to reflect changes in legislation, professional requirements, technology or the way services are provided.
 

The current version will be published on the relevant practice website with the date it was last updated.
 

Contact
 

For privacy questions, requests for access or correction, or privacy complaints:

Neil Locke
Authentic Me Therapy and Coaching / Neil Locke — Counselling & Coaching
Email: neil@authenticme.com.au
Phone: 0493 559 218
Melbourne, Victoria, Australia