Privacy Policy
1. PURPOSE
(a) ARIAH Group Pty Ltd ABN 76 666 404 128 (“ARIAH”) Privacy Policy aims to protect and maintain the privacy of the personal information it collects, uses, discloses, and otherwise handles.
2. POLICY STATEMENT
(a) The proper management of personal information is important to ARIAH. ARIAH is committed to protecting and maintaining the privacy of clients’ personal information.
(b) This Privacy Policy explains how ARIAH handles and protects the personal information.
(c) This Privacy Policy is in addition to the Terms and should be read in conjunction with these Terms. Your use of the Website or use of our services infers your acceptance of this Privacy Policy.
(d) References to “ARIAH”, “we”, “us” and “our” are references to ARIAH Group Pty Ltd ABN 76 666 404 128.
(e) References to “you” and “your” are references to any individual about whom we collect personal information.
3. DEFINITIONS
(a) Definitions used are consistent with those defined under the Privacy Act 1988 (Cth) (the “Act”).
(b) “ARIAH” means ARIAH Group Pty Ltd ABN 76 666 404 128.
(c) “Personal Information” means information or an opinion about an identifiable individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Some “Sensitive Information” (described further below) can also be “Personal Information” where it falls within the definition of “Personal Information”.
(d) “Psychiatrist” means a psychiatrist employed by ARIAH.
(e) “Responsible Person” includes:
(i) a parent of the patient;
(ii) a child or sibling of the patient (who is at least 18 years old);
(iii) spouse or de facto partner of the patient;
(iv) a patient’s relative (if the relative is over 18 years old and part of the patient’s household);
(v) the patient’s guardian;
(vi) a person exercising an enduring power of attorney granted by the patient that is exercisable in;
(vii) relation to decisions about the patient’s health;
(viii) a person who has an intimate personal relationship with the patient;
(ix) a person nominated by the patient to be contacted in the case of emergency;
(x) step relationships, in-laws, adopted relationships, foster relationships and half-brothers and sisters.
(f) “Sensitive Information” is a subset of Personal Information and is defined as:
(i) information or an opinion (that is also Personal Information) about an individual’s:
(A) racial or ethnic origin;
(B) political opinions;
(C) membership of a political association;
(D) religious beliefs or affiliations;
(E) philosophical beliefs;
(F) membership of a professional or trade association;
(G) membership of a trade union;
(H) sexual orientation or practices; or
(I) criminal records.
(ii) health information about an individual (refer to B.74-B.78 of the Act);
(iii) genetic information (that is not otherwise health information;
(iv) biometric information that is to be used for the purpose of biometric verification or biometric identification; or
(v) biometric templates (s.6(1) of the Act).
(g) “Terms” means the Terms & Conditions governing our Website.
(h) “Website” means psyxia.com, ariahgroup.com.au and subsidiaries.
4. WHAT PRIVATE INFORMATION DOES ARIAH COLLECT?
(a) Collection of Personal Information
We strive to collect your Personal Information directly from you whenever it is practical to do so. This information is gathered through various means, including:
(i) During the course of providing psychiatry services;
(ii) Phone interactions;
(iii) In-person interactions;
(iv) Online interactions through our Website;
(v) Internally built survey software and third party vendors (such as Halaxy, Squarespace, Google);
(vi) Correspondence such as letters or documents;
(vii) Electronic communications such as emails, SMS, and social media platforms; and
(viii) Details provided for appointment bookings.
(b) Indirect Collection of Information
In certain cases, we may collect Personal Information, including Sensitive Information, indirectly from other sources, such as:
(i) General practitioners or healthcare professionals through referrals, correspondence, and report;
(ii) Government agencies responsible for your benefits and entitlements (for example, Medicare or the Department of Veteran Affairs);
(iii) The My Health Record system;
(iv) the Pharmaceutical Benefits Scheme;[HR Law1]
(v) Responsible Person;
(vi) Legal professionals; and
(vii) Individuals responsible for your healthcare decisions.
(h) Collected Information:
ARIAH may collect the following information from clients or referrers:
(i) Your name, address, and date of birth;
(ii) Contact details;
(iii) Current and past medical information;
(iv) Family medical history, if relevant to current services;
(v) Educational and occupational history;
(vi) Legal or offending history (applicable to medico-legal services);
(vii) Responses and results from tests and questionnaires;
(viii) Medicare number (where available) for identification and claiming purposes;
(ix) Healthcare identifiers;
(x) Health fund details;
(xi) Responses and results from neuropsychological assessments, which may be conducted through paper-based or computer-based methods; and
(xii) Session notes, treatment plans, and your response to treatment.
5. USE OF PERSONAL INFORMATION
(a) Our main purpose for collecting, using, holding and sharing your Personal Information is to manage the services we provide to you. The collection and use of Personal Information is integral to the accurate assessment, diagnosis, and formulation of treatment plans for you. The absence of this information may lead to incorrect assessment, diagnosis, and treatment outcomes and/or our inability to provide psychiatry services to you.
In addition to this, ARIAH may use Personal Information (not limited to) to:
(i) Initiate communication regarding engagement with the ARIAH;
(ii) Facilitate correspondence between clients and Psychiatrists, such as appointment reminders, booking confirmations, feedback requests, surveys, or questionnaires;
(iii) Use de-identified data for analysis, research, and quality assurance measures;
(iv) Disseminate information about products and services, as well as those of third parties, provided prior consent is obtained. Clients can cease such communications at any time by contacting us on hello@ariahgroup.com.au;
(v) Enhancing engagement with services via targeted online advertising;
(vi) Delivering push notifications to mobile devices, with the option for users to control settings;
(vii) Facilitating form pre-filling;
(viii) Conducting data analytics to enhance services and user experiences;
(ix) Implementing security measures for access control, monitoring potential fraudulent activity, and ensuring adherence to this Privacy Policy and Terms of Use; and
(x) Facilitating payment processing.
6. DISCLOSURE OF PERSONAL INFORMATION
(a) We sometimes share your Personal Information:
(i) With other healthcare providers;
(ii) When it is required or authorised by law (e.g. court subpoenas);
(iii) When it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patients consent;
(iv) To establish, exercise or defend an equitable claim;
(v) For the purpose of confidential dispute resolution process; and
(vi) With third parties to collect and process data, such as IT service providers, data storage, web-hosting and server providers (including SquareSpace);
(b) Only people that need access to your information will be able to do so. Other than, in the course of providing medical services or as otherwise described in this Privacy Policy, our practice will not share Personal Information with any third party without your consent.
(c) We may share your Personal Information with individuals or entities outside of Australia. Recipients may include our related entities or employees, external service providers such as administration providers or information technology providers such as cloud storage, data processing and web-hosting. We only transfer information to an overseas recipient where:
(i) we reasonably believe that the recipient is legally or contractually bound to principles that are substantially similar to the Australian Privacy Principles in the Act; or
(ii) exceptional circumstances are permitted by law; or
(iii) with your consent.[HR Law2]
7. STORING AND SECURITY OF PERSONAL INFORMATION
(a) Your Personal Information may be stored at our practice in various forms including paper records, electronic records, visual records (videos and photos), audio recordings.
(b) ARIAH will take reasonable steps to protect the Personal Information ARIAH holds from misuse or loss and from unauthorised access, modification or disclosure.
(c) ARIAH currently prevents unauthorised access to ARIAH’s premises by:
(i) ensuring physical security over our paper and electronic data records is maintained where possible;
(ii) maintaining security systems, for example, by using a firewall, using passcodes to control access to electronic devices, and using two-factor authentication when available to access electronic systems;
(iii) taking reasonable steps to destroy or de-identify your Personal Information once we no longer need it;
(iv) disposing of all hardcopy documentation that contains Personal Information that is no longer needed in a secure manner.
(v) conducting regular privacy and data security audits to assess whether we have adequately complied with and implemented these measures.
8. ACCESSING AND CORRECTING PERSONAL INFORMATION
(a) You have the right to request access to, and correction of, your Personal Information.
(b) ARIAH acknowledges clients may request access to their medical records. We require you to put this request in writing and our practice will respond within a reasonable time e.g. 60 days.
(c) Clients may be charged an administrative fee of $600 for preparation of the requested records.
(d) ARIAH will take reasonable steps to correct your Personal Information where the information is not accurate or up to date. From time to time, we will ask you to verify that your Personal Information held by our practice is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to hello@ariahgroup.com.au.
9. OUR USE OF COOKIES
(a) Cookies are pieces of information that a website transfers to your computer’s hard disk for record keeping purposes. Most web browsers are set to accept cookies. However, if you do not wish to receive any cookies, you may set your browser to refuse them. In some instances, this may mean you will not be able to take full advantage of parts of our Website.
(b) The use of cookies can enhance your enjoyment of our Website, because they can help us personalise your experience of our Website by providing information which is most relevant to your interests. Cookies provide us with aggregated information on how users interact on our Website, track which advertisements are effective and help us improve your experience on our Website. Cookies do not personally identify you, but your browser.
(c) We may use independent companies to measure and analyse Internet usage across our Website. The tracking collects the following core information on usage of the Website:
(i) the number of page views (or page impressions);
(ii) the number of unique visitors;
(iii) how long these unique visitors (on average) spend on the Website; and
(iv) common entry and exit points into our Website.
(d) This aggregate, non-personal information is collated and provided to us to assist in analysing usage of our Website. The data is also accessible by media organisations and research companies for the purpose of conducting industry comparisons with other Internet sites.
(e) Pages on our Website may be coded with tracking software. This is transparent to the user, as the software makes use of an invisible image (via Javascript) or an invisible Java Applet, at the bottom of the web page. This software stores a cookie in your browser, which contains a unique identifier. This enables tracking of the number of unique visitors to this Website. In no way does this unique identifier identify a user personally. We do not and will not marry any data collected by independent tracking software with any personal information collected on the Website.
10. RESOLVING ISSUES
(a) To raise a privacy related issue with ARIAH, or to discuss any issues about the Privacy Policy, please contact ARIAH by emailing us at hello@ariahgroup.com.au.
11. PRIVACY POLICY CHANGES
(a) From time to time, it may be necessary for ARIAH to review and revise the Privacy Policy. ARIAH reserves the right to change the Privacy Policy at any time.
12. FURTHER INFORMATION ON PRIVACY
(a) For more information about privacy issues in Australia, visit the Australian Federal Privacy Commissioner’s website (www.privacy.gov.au/law/act).
We strive for HIPAA Compliance where possible.
Please note an APP entity that discloses personal information to an overseas recipient is accountable for any acts or practices of the overseas recipient in relation to the information that would breach the APPs (s 16C).