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Privacy Policy

Your Privacy is Important

This privacy policy outlines how Neuroinclusive Pty Ltd (referred to as “VCP”, “we”, “us”, or “our”) collects, uses, stores, and discloses your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

When does this Privacy Policy apply?

This Privacy Policy applies to the personal information we handle when responding to psychology and related services to you. By providing your personal information to us, eg using the contact form, you consent to us handling that information in accordance with, and for the purposes specified in this Privacy Policy. 

What Information We Collect

We may collect and hold personal information such as your name, contact details (address, email, phone number), date of birth, medical and psychological history, session notes, billing details, and other information relevant to your care.

How We Collect Information

  • Directly from you (in person, by phone, email, or online forms)
  • During telehealth sessions (via Coviu, MS Teams, or Zoom)
  • Through our website (hosted by GoDaddy and Network Solutions)
  • Via email (Network Solutions and Microsoft)
  • Through accounting and billing systems (Xero, Heritage Bank)
  • Through the use of Ring video cameras on the premises (see below)
  • Via cloud storage (Microsoft 365 OneDrive, Apple iCloud)
  • During session transcription (Heidi Scribe, Novonote)

Disclosure of Information

Like most businesses, we work with third parties to deliver psychology services for you. Your information may be disclosed to:

  • Other health professionals and carers with your consent
  • Third-party service providers (see Subprocessors, below) for the purposes of storage, transcription, or telehealth
  • In the event of unexpected cessation of practice (see below)
  • Where required by law (e.g., mandatory reporting)

Mandatory Reporting

Mandatory notification requirements of AHPRA registered practitioners supports public protection and safety.  Mandatory Reporting is State specific and includes:

  • In Queensland, mandatory reporters must report a reasonable suspicion that a child is suffering or at risk of suffering significant harm from physical or sexual abuse to Child Safety. If the abuse is sexual abuse by an adult against a child, any adult must report it to the police. Reports can be made by calling Child Safety’s After Hours Service on 1800 177 135 or by contacting your local Regional Intake Service during business hours.
  • In the ACT, effective 12 June 2025, Psychologists who believe that an individual holding or applying for a heavy vehicle licence has a condition that may impact their ability to drive safely must report this to Access Canberra. Fitness to Drive form Key requirements:
    • Report must be submitted within 7 days of forming the opinion.
    • Patient must be informed of the contents of the report.

    Practitioners are not required to assess fitness to drive or determine licensing outcomes. Access Canberra will review the report and may:

    • Take no action,
    • Recommend further investigation, or
    • Adjust the person’s licence status.

    Individual clients will not be contacted by Access Canberra if no action is taken.

Including parents, carers, and other persons in your Services

‘Carer’ is a term commonly used to describe people who provide support to individuals who need help. A carer may be, and will continue to be, primarily the person’s spouse, partner, son, daughter, parent, neighbour, friend or, in some cases, their child/children.

Involving a family member or carer can help client outcomes. The people closest to clients often have information that can help the psychologist to understand the client’s treatment needs and contribute to their wellbeing and recovery. They are also available to support the client between sessions and indirectly facilitate the attainment of treatment goals. Best practice requires identification, recognition, and involvement of families and carers, including children where appropriate, across the service continuum. However, some clients may not want their families involved, some families may not wish to be involved, and it may not always be clinically appropriate to include carers or family members.  

It is always the clients’ decision whether to involve someone else in their treatment (if they have the capacity to make decisions).  Where clients lack the capacity to make decisions regarding the involvement of others in their treatment, they should be assisted in making decisions that are in their best interest and as closely aligned with their preferences as possible regarding what information is shared with others. 

Use of Third Party, Artificial Intelligence (AI) and Cloud Services

For the purpose of providing you with services, we may transfer, process and store your personal information outside of Australia, to where our third-party service providers operate. Whenever we share personal information overseas, we take reasonable measures to ensure that our service providers or recipients are required to protect this information in accordance with the Privacy Act. They are only permitted to use the personal information for the specific purpose for which it was shared.

  • Heidi Scribe and Novonote: Used to transcribe session notes. These services process personal information for the purpose of accurate record-keeping.
  • ChatGPT and AAPi Ava: Used only for the development of generic documents. No client personal information is shared with these services.
  • Halaxy, Medical Objects, Microsoft 365 OneDrive and Apple iCloud: Used for secure storage of client notes and documents.
  • Telehealth Platforms (HealthDirect / Coviu, MS Teams, Zoom): Used for remote sessions, which may involve the transmission and temporary storage of personal information.
  • Email (Network Solutions, Microsoft Outlook): Used for communication and may contain personal information.
  • Telephone (Telstra): Used for mobile telephone communication and may contain personal information.
  • Psychometrics: Used to administrate and score questionnaires and scales for the purpose of providing psychology services and outcome monitoring.
  • Ring Video camera (see below)

Legal implications of using AI. 

The Supreme Court of NSW introduced a Generative AI Practice Note and Judicial Guidelines, effective from 3 February 2025. These guidelines stipulate that written submissions to the court, including expert opinions, must include a declaration specifying which, if any, parts of the report were prepared using generative AI. Should your client file be supboaned by the court, please be aware that all client notes, letters, and reports that have been prepared in part using Generative AI tools are identified as such. That is, ensure transparency by clearly disclosing its use in the preparation of notes or reports.

Use of Ring Video Cameras

Ring video cameras are installed at our residential practice address for security purposes. These cameras may record or store video of individuals on the property, including clients and their vehicles. The primary purpose is personal and property security. While every effort is made to protect your privacy, your image may be incidentally recorded when attending the premises. Ring does not record biometric information. For more details, refer to the Ring Privacy Policy.

Why We Collect Your Information

  • To provide psychological services and care
  • To communicate with you, by various channels including by email or sms
  • For billing and administration
  • For important service-related communications, such as clinic holiday closure periods, or changes to our terms and conditions
  • To comply with legal and regulatory obligations
  • For security and safety of the premises

Unexpected Cessation of Practice

In the event that your clinician is unable to practise (due to incapacitation, illness, injury, or death), a nominated company director or another registered practitioner will be required to access your contact information (name, email, phone) solely to notify you of the situation and provide guidance on next steps for your care. If you cannot be contacted directly, where possible your GP or Emergency contact / next of kin, will be notified instead.

Security of Your Information

While we take all reasonable steps to protect your personal information, no data transmission or storage system is guaranteed to be 100% secure. If a data breach occurs that is likely to result in serious harm, we will notify you in accordance with our obligations under the Privacy Act 1988 (Cth). For more information please refer to the Security Policy below.

Access and Correction

You have the right to access and correct your personal information. Please contact us in writing to request access or correction (please note there may be an administration fee charged for the delivery of this service). If we decide to impose a charge, we will advise you in writing and give you an estimate before proceeding with your request.

FOI

A request to us for access to a document under the Freedom of Information Act 1982 (Cth) (FOI Act) must:

  • be in writing; and
  • state that you are making the request under the FOI Act; and
  • provide sufficient information about the document as is reasonably necessary for VCP to identify it (eg, date and/or type of documents, author, subject matter of the documents); and
  • be specific and avoid broad statements like ALL and ANY documents relating to you; and
  • give details of how notices under the FOI Act may be sent to you (e.g. by providing a postal or email address); and
  • be posted, delivered, or emailed to vcp@victoriaclark.com with the subject heading FOI Request

Postal Adress:
FOI Request 
Neuroinclusive Pty Ltd
PO Box 193 HELENSVALE, QLD 4212

FOI Charges

There is no application fee for making an FOI request to us.

However, we may charge you a fee for processing your FOI request under the Freedom of Information (Charges) Regulations 1982. If we decide to impose a charge, we will advise you in writing and give you an estimate before proceeding with your FOI request.

If a decision is made to grant access to the documents sought, you will be asked to pay any applicable charges prior to access being provided, except in cases where waiver or remission is appropriate.

You can ask for the charge to be waived or reduced for any reason, including financial hardship or on the grounds of public interest. If you do so, you should explain your reasons and you may need to provide some evidence.

 

Complaints

If you have concerns about your privacy, please contact us directly. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner, using the information below:

Phone: 1300 363 992
Website: www.oaic.gov.au
Complaints form: https://www.oaic.gov.au/privacy/privacy-complaints

We may update this Policy periodically. The most current version is always available on our website

Collection Statement

Collection of Personal Information

VCP collects your personal information to provide psychological services, manage appointments, communicate with you, and comply with legal obligations. We may use third-party services for storage, transcription, telehealth, and security, some of which may store data outside Australia. Your information will only be shared with your consent, unless required by law. If you do not provide your information, we may not be able to provide services to you. 

How long do I keep your records

VCP keeps your file indefinitely.

VCP has a legal obligation to keep client records for a period of time. This can be different in different states and territories and for different circumstances. Generally, according to the Health Records Act, records should be kept for a minimum of 7 years from the time that you have last had contact with VCP for adult clients. If the client is a minor when last seen by VCP the client records must be kept for 7 years after they turn 18. These requirements override any requests from you to dispose of your files.

Records of Aboriginal & Torres Strait Islander peoples

There has been a lot of information lost regarding the backgrounds and past of Indigenous Australians. This has contributed to the inter-generational trauma and grief the community has experienced. Non-Government organisations in some states such as NSW and NT are required to keep the records of Aboriginal and Torres Strait Islander peoples indefinitely. Some states have no statutory obligation to retain their records or expend resources preserving and indexing them.

Organisations can show their care and support for our first people by choosing to keep the records of Aboriginal and Torres Strait Islander people, and making the records easily accessible.

Disposing of your client file

The practice management software, Halaxy, does not dispose of your file directly. For digital disposal you file will be marked as “Archived” or “Discharged” within your client profile. This keeps your file in the practice management software system but separates it from active clients. Please discuss your wishes for the storage of your complete client file after the mandatory retention period.  

Terms of Use

Terms of Use for Clients

By engaging with VCP, you agree to the following terms:

  • You will provide accurate and complete information as required for your care.
  • You understand that telehealth sessions may be conducted via Coviu, MS Teams, or Zoom, and that these platforms have their own privacy and security policies.
  • You acknowledge that Ring video cameras may record your image when attending the premises for security purposes.
  • You consent to the use of transcription services (Heidi Scribe, Novonote) for session notes, letter and reports. 
  • You agree to communicate respectfully and maintain appropriate boundaries.
  • You understand that in the event of unexpected cessation of practice, your contact information may be accessed by a nominated person to notify you.
  • You are responsible for ensuring your own privacy during telehealth sessions (e.g., choosing a safe, private location).

Telehealth and Virtual Care Guides

Ahpra and the National Psychology Board have released updated information guides to help health practitioners and employers/practice managers understand the requirements to deliver safe and effective telehealth/virtual care services.

There are separate guides for health practitioners, employers/managers, and the public.

As a registered health practitioner providing virtual care to clients – if you, the client, are outside Australia

  • Please notify me prior to your travels to advise which country you intend to be located when receiving virtual care services as I am required to be registered by the relevant regulatory authority for their profession in the country where the patient is located and comply with legislative requirements in that jurisdiction, including for prescribing and professional indemnity insurance.
  • All sessions will be charged as private paying fees.  

Client File and Session Notes

A psychologist’s notes are essential to allow for accurate and factual recall of client related information. There will be times where I need to look back on information recorded about you in order to provide the best possible care. The level of detail and content included in your client notes take into consideration privacy and confidentiality. Extra information that is not essential to your service may not be included into your file. Having a complete file allows for your treatment to continue without interruption or the client needing to re-tell their story all over again. There is always the possibility of having your records subpoenaed by the courts, a complete and factual record helps to ensure the accuracy of the information. 

Your complete client file may contain:

  • Documented informed consent signed by the client, outlining how their records are maintained Demographic information such as name, date of birth, address, contact details, emergency contact details
  • Release of information forms signed by the client in order to give permission for you to communicate with others about their health information
  • Clinical notes
  • Dates and times of appointments
  • Assessments that have been completed and their results
  • Any reports that have been written
  • Referral letters/reports from other professionals
  • Client history
  • Fees paid and outstanding
  • Letters to other healthcare providers
  • Provisional/differential diagnosis or diagnosis, case formulation Treatment plan response to treatment
  • Risk management plans and actions taken when required to enact the management of risk

The file is maintained and stored electronically and aims to contain sufficient information about you and your sessions that another psychologist would be able to continue the treatment.

 

Security Policy

Keeping Your Information Secure

As a sole practitioner, I take the following steps to keep your electronic information secure:

  • All devices used for client information are password-protected and have up-to-date security software.
  • Two-factor authentication is enabled where possible.
  • Sensitive documents are stored in reputable provider cloud environments (Microsoft 365 OneDrive, Apple iCloud).
  • Session notes are transcribed using secure, reputable services (Heidi Scribe, Novonote).
  • Telehealth sessions are conducted using secure, professional platforms (Coviu, MS Teams, Zoom).
  • Email communications are conducted via a web services provider (Go Daddy and Network Solutions), and sensitive information is minimised in emails.
  • Banking and accounting information is managed securely using Xero and Heritage Bank.
  • Physical access to devices and records is restricted.
  • Regular backups are maintained in secure locations.
  • Public Wi-Fi is not used for accessing or transmitting client information.
  • Maintaining separate devices or logins for business and personal use
  • In the event of unexpected cessation of practice, only a nominated company director or registered practitioner will access client contact information to notify clients.

Subprocessors

The following lists links to third-parties with whom your personal information may be shared as part of providing our services to you. 

  • Heidi AI Scribe https://www.heidihealth.com/au/legal/privacy-policy
  • Novonote https://novopsych.com/novonote-privacy-policy-security/
  • ChatGPT https://openai.com/policies/row-privacy-policy/
  • AAPi Ava https://www.aapi.org.au/Web/Web/Privacy-Policy.aspx
  • Halaxy https://www.halaxy.com/article/privacy
  • Medical Objects https://www.medicalobjects.com/privacy/
  • Microsoft 365 https://www.microsoft.com/en-gb/privacy/privacystatement
  • MS OneDrive https://learn.microsoft.com/en-us/sharepoint/onedrive-privacy-security-overview
  • MS Teams https://www.microsoft.com/en-au/microsoft-teams/security
  • Apple iCloud https://support.apple.com/en-au/102651
  • Coviu https://www.coviu.com/en-au/privacy-policy
  • Zoom https://www.zoom.com/en/trust/privacy/privacy-statement/
  • Network Solutions https://www.netsg.co/au/privacy-policy
  • GoDaddy https://www.godaddy.com/en-au/legal/agreements/privacy-policy
  • Telstra https://www.telstra.com.au/privacy
  • Novopsych Psychometrics https://novopsych.com/security/
  • Multi-Health Systems Inc. (MHS) https://mhs.com/privacy-policy/
  • Pearson https://www.pearsonclinical.com.au/legal/pearson-clinical-privacy-policy.html
  • QGlobal (Pearson clinical) https://qglobal.pearsonclinical.com/qg/agreement/downloadAgreement.seam?agreementId=2014&businessUnitId=2004
  • WPS https://www.wpspublish.com/wps-privacy-policy
  • PAA https://paa.com.au/privacy-policy/?v=8bcc25c96aa5 
  • PAR and SDS https://www.parinc.com/legal-privacy-policies/general-privacy-policy

If you require further information or wish to access your personal information, please contact us directly.

Effective Date: 16 August 2025