Privacy Policy

Paul Clifford Psychology
ABN: 60 886 726 788

Address: 144 Nepean Highway Aspendale VIC 3195
Phone: 0423771839

Email: paul@paulcliffordpsychology.com.au
Effective Date: 20 June 2026

  1. Commitment to Privacy

Paul Clifford Psychology is committed to protecting your privacy and handling your personal and health information in accordance with:

  • The Privacy Act 1988 (Cth)
  • The Australian Privacy Principles (APPs)
  • The Health Records Act 2001 (Vic)
  • The Victorian Health Privacy Principles (HPPs)

As a registered psychologist, I am also bound by professional confidentiality obligations under AHPRA and the Psychology Board of Australia.

This policy explains how your personal information is collected, used, stored, disclosed and managed.

  1. Who This Policy Applies To

This practice provides psychological services to adult clients only.

  1. What Information Is Collected

Information collected may include:

Personal Information

  • Name, address, telephone number, email
  • Date of birth
  • Emergency contact details
  • Medicare or private health fund details
  • Referral information

Health Information (Sensitive Information)

  • Medical and psychological history
  • Assessment results
  • Clinical notes
  • Risk assessments
  • Treatment plans
  • Reports and correspondence from other health professionals
  • Information relevant to billing and Medicare compliance

Health information is classified as sensitive information under Australian law and receives a higher level of protection.

  1. How Information Is Collected

Information is usually collected directly from you during consultations or through:

  • Referral letters from GPs or specialists
  • Telephone, email or written communication
  • Medicare or other funding bodies
  • Other health professionals involved in your care (with your consent)

Where possible, information is collected directly from you.

  1. Why Information Is Collected

Your information is collected for the primary purpose of:

  • Providing psychological assessment and treatment
  • Communicating with you
  • Meeting Medicare or other funding requirements
  • Preparing reports (with your consent)
  • Managing appointments and billing
  • Complying with legal and professional obligations

Information may also be used for secondary purposes that are directly related to the primary purpose, where you would reasonably expect this (e.g., professional supervision, de-identified case discussion, or clinical audit).

  1. Disclosure of Information

Your personal information will not be disclosed without your consent except where permitted or required by law.

Disclosure may occur:

  • To your referring GP (e.g., under a Mental Health Care Plan)
  • To other treating health professionals (with consent)
  • To Medicare or other funding bodies
  • If required by subpoena or court order
  • Where there is a serious and imminent risk to your life, health or safety or that of another person
  • Where mandatory reporting obligations apply

Where appropriate and practicable, you will be informed before disclosure occurs.

  1. Use of Artificial Intelligence (AI)

Where artificial intelligence (AI) tools are used within the practice (e.g., for documentation assistance), they are used only to support administrative or documentation functions.

AI tools:

  • Do not replace clinical judgment
  • Do not make autonomous clinical decisions
  • Are subject to clinician review before any information is entered into the clinical record

Where AI tools process identifiable health information, reasonable steps are taken to ensure compliance with Australian privacy laws, including appropriate data security safeguards.

  1. Overseas Disclosure of Information

Some electronic practice management systems or secure cloud storage providers may store data on servers located outside Australia.

Where personal information is disclosed overseas, reasonable steps are taken to ensure the recipient complies with Australian privacy law obligations in accordance with APP 8.

Information is not otherwise routinely disclosed overseas.

  1. Storage and Security

As a sole practitioner:

  • Client records are accessed only by the treating psychologist
  • Electronic records are stored on secure, password-protected systems
  • Data encryption and secure backup systems are used where available
  • Paper records (if any) are stored in locked facilities

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

  1. Retention of Records

In accordance with Victorian law:

  • Adult client records are retained for a minimum of 7 years from the last date of service

After this period, records are securely destroyed.

  1. Access to Your Information

You have the right to request access to your personal information.

Access may be refused in limited circumstances, including where:

  • Providing access would pose a serious threat to life or health
  • It would unreasonably impact the privacy of others
  • The request is frivolous or vexatious
  • Denial is authorised by law

Requests for access should be made in writing. Access will generally be provided within 30 days. Reasonable fees may apply for copying or preparing summaries.

  1. Correction of Information

If you believe information held about you is inaccurate, incomplete or out of date, you may request correction.

If the information is not corrected, you may request that a statement be added to your record noting your view.

  1. Anonymity and Pseudonymity

You may request to interact with the practice anonymously or under a pseudonym where lawful and practicable.

However, due to the nature of psychological treatment and legal requirements for health records and Medicare billing, it is generally not practicable to provide services anonymously.

  1. Data Breaches

If a data breach occurs that is likely to result in serious harm, the practice will comply with obligations under the Notifiable Data Breaches scheme, including notification to affected individuals and the Office of the Australian Information Commissioner where required.

  1. Complaints

If you have concerns about how your personal information has been handled, please contact:

Paul Clifford
0423771839 or paul@paulcliffordpsychology.com.au

If your concern is not resolved, you may contact:

Office of the Australian Information Commissioner (OAIC)
www.oaic.gov.au

Office of the Victorian Information Commissioner (OVIC)
www.ovic.vic.gov.au

Health Complaints Commissioner (Victoria)
www.hcc.vic.gov.au

  1. Changes to This Policy

This policy may be updated from time to time. The current version will be available upon request or via the practice website.