Ash Occupational Therapy is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers. This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our website www.ash-ot.com.au and from third parties. We don’t guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you and providing information to our clients. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. Ash Occupational Therapy understands and follows the Australian Health Practitioner Regulation Agency (AHPRA) Summary of Obligations for managing health records.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
Software systems used within this business include Halaxy and Xero:
· Within this business, Halaxy is used for the purposes of client record keeping, booking appointments, invoicing, business financial reporting, and third-party integration to Xero. Halaxy advise that “data is backed up daily and protected by bank grade security and encryption here in Australia, meaning that your data is secure at rest and in transit (where they are only accessible via TLS/SSL). Your data is stored safely here in Australia” (https://www.halaxy.com/article/security, 2025).
· Within this business, Xero is used for the purposes of invoicing, bookkeeping and accounting. Xero is a well renowned business and is “certified as compliant with ISO/IEC ISO27001:2022, the premier global information security management system (ISMS) standard" (https://www.xero.com/au/security/, 2025).
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
Ash Occupational Therapy acknowledges:
- Patients have a right to access information held about them, unless an exception applies.
- Ash Occupational Therapy must respond to a patient’s access request within 30 calendar days.
- Ash Occupational Therapy must give access in the manner requested, unless it is unreasonable or impracticable.
- If Ash Occupational Therapy refuses to give access, or refuses to give access in the manner requested, Ash Occupational Therapy must:
- take reasonable steps to give access in a way that meets both your own and the patient’s needs
- give the patient a written notice setting out the refusal grounds and complaint mechanisms.
Ash Occupational Therapy will continue to refer to the Office of the Australian Information Commissioner regarding Health Privacy, from which the previous information was acquired.
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing. You can write to us at ashleigh@ash-ot.com.au. Any request for records must be accompanied by an authority.
Ash Occupational Therapy will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information, we may require identification from you before releasing the requested information.
Please refer to the Right to Information Act 2009 and Information Privacy Act 2009 (public health sector); Privacy Act 1988 (Commonwealth) (private health sector); and the Health Records Act 2001 (the Act) for more information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Data Breach
A data breach happens when personal information is accessed, disclosed without authorisation, or is lost. For example, when:
- a USB or mobile phone that holds an individual’s personal information is stolen
- a database containing personal information is hacked
- someone’s personal information is sent to the wrong person.
A data breach can harm an individual whose personal information is affected. They can, for example, suffer distress or financial loss. Clients and/or their authorised representatives will be contacted if a data breach occurs immediately.
Ash Occupational Therapy will refer to “Assessing a Suspected Data Breach” (Office of the Australian Information Commissioner, 2025) to provide guidance about the process to follow when carrying out an assessment of ‘whether there are reasonable grounds to suspect that there may have been an eligible data breach’. Ash Occupational Therapy will also refer to the Office of the Australian Information Commissioner and the NDB scheme if a data breach is suspected. All breaches will be documented within the client’s record.
Policy Updates
This Policy may change from time to time and is available on our website.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy, please contact us at:
ashleigh@ash-ot.com.au
Last updated February 2025
