Privacy policy
Thank you for accessing our Policy and this Notice.
Your privacy is important to us
We are committed to protecting your privacy in your dealings with us. Through this Policy
and Notice, we would like to tell you about:
• what kinds of personal information we collect from you; and
• how we collect, hold, use, and disclose your personal information, in the in the course of
providing services to you and in the context of our business.
1. PART 1 – ABOUT THIS POLICY
a. Purpose
Nova Speech Clinic (ABN 29 595 269 738) (“We, Us or Our”) is committed to protecting the
ongoing privacy of all individuals (“You or Your”) from whom personal information is
collected.
We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth),
other privacy laws that govern how healthcare service providers handle personal
information (including health or sensitive information), and Speech Pathology
Australia’s Code of Ethics (2020).
This Privacy Policy explains how We collect, store, use and disclose Your personal
information. We encourage You to read this policy carefully so that You understand
Our information handling practices clearly.
2. PART 2 – HOW WE HANDLE YOUR PERSONAL INFORMATION
a. Our legal obligations
In order to provide You with the healthcare services that You have requested. We will need
to collect and use Your personal information.
If You provide incomplete or inaccurate information to Us or withhold personal or health
information from Us, We may not be able to provide You with the services You are
seeking. We are committed to treating you in a dignified way that maintains your
personal privacy.
Privacy is about more than simply meeting our legal obligations. It is also about the way we
deliver our services to people with a disability or those who may be vulnerable such as
children. We will work hard to be aware of your privacy needs and preferences and will
deliver our services in a way that maintains your personal dignity. Without limiting what we mean by this commitment, we will:
• explain and request your permission to perform procedures that involve physical touch or
the invasion of your personal space;
• provide services in a timely manner to prevent your embarrassment and discomfort, e.g.
such as toilet breaks; and
• consider your everyday personal needs, such as being able to shower or dress in a private
or comfortable space.
b. What, specifically, are this Policy and Notice about?
In this Policy and Notice, we explain:
• the kinds of personal information that we collect and hold, including recorded audio and
visual materials;
• why we hold this information;
• who will have access to this information;
• how we ensure that information is secure;
• how we use the information;
• how you can access and amend information held about you; and
• how to make a complaint if you feel that we have breached our privacy obligations to you.
We have several obligations to you under the Privacy Act 1988 (Cth) (including the Australian
Privacy Principles) (the Privacy Laws). This Policy and Notice are intended to reflect our
obligations under the Privacy Laws as well as under the NDIS Code.
Hard copies of this Policy and Notice are available for free in our reception area, and you
may request a portable document format (pdf) copy, again at no charge, by way of
email to our Privacy Officer.
When we refer to “clients” or "you" below, we mean both former and current clients, as well
as people who make inquiries about our products and services (i.e. potential clients).
c. What kinds of personal information do We collect and hold?
We will only collect personal information We need for the particular function, purpose or
activity We are carrying out for You or on Your behalf.
In this Policy and Notice, “personal information” means information or an opinion about an
individual whose identity is apparent or can reasonably be ascertained. To provide our
services to clients, we need to know personal information about them and others,
including:
• names, ages, dates of birth, genders, and other identifying information;
• Medicare and health fund details (including Medicare numbers and health fund
insurers and the extent of their coverage);
• developmental, medical, ethnic, language, cultural and social histories (including
medications, diagnoses, surgeries, and allergies);
• details about disabilities, impairments, challenges, barriers and facilitators;
• family histories, to the extent they may be relevant to our services;
• work and education histories;
• hobbies, motivations, interests, and activities in which clients and their families like to
participate;
• financial information concerning the ability of clients to pay for our products and
services;
• details related to the NDIS, including details of negotiations, assessments, plans and
packages;
• call records, wireless locations, and unique web browser details (when you use our
products and services, including online services).
For sensitive information – such as information about your health that is reasonably
necessary for us to provide you with services or products – we will seek your informed
consent.
d. How do We collect Your information?
We may collect personal information about you in several ways, including:
- by telephone (e.g. when you or someone else call us);
- via our website when you use our networks, products and services, including our
- online services;
- via pages on our social media sites;
- through our client questionnaires;
- by written letters, reports and other documents (e.g. through reports you provide to
- us); through emails, SMS and other forms of electronic communication; in interviews and other interactions with you (including face-to-face interviews and
- interviews conducted electronically, such as by way of Zoom, Microsoft Teams or other means); and
- by taking notes and making recordings of our interactions with you (including audio and visual recordings).
When we ask for your consent to use your personal information, we will ensure that consent
is opt-in, affirmative and freely given. At any time, you have the ability to withdraw
consent by contacting us to tell us that you are withdrawing your consent.
e. Who do we collect personal information from?
We collect personal information from clients or someone authorised to act on the behalf of
clients (e.g. their parents, carers or guardians). Wherever practicable, we will ask for the
information directly. However, we may need to contact others when relevant to a
client’s circumstances (e.g. when working with clients who cannot communicate their
needs without the assistance of others).
In these cases, we will, when practicable, make you aware of the fact that we have collected this information and the circumstances of
the collection.
f. Why do we collect personal information?
We collect personal information to deliver, review and improve the products and services
that we provide. Generally, these services and products relate to allied health services.
If we didn’t collect this information, we wouldn’t be able to carry out our business or
provide our products and services to you in accordance with the standards required by
law, the NDIS Code, or our professional ethics requirements.
If you do not provide the personal information that we request, we would not be able to carry out our business and provide our products or services to you.
More specifically, we need personal information (including health information) to provide
clients with assessment, diagnosis and management services and products related to
what you do for participants. We also need this information:
• for administrative purposes of managing our business;
• when necessary, to fulfil our obligations under law, regulation, the NDIS Code and/or
our professional ethics rules;
• for billing management (either directly or through insurers or other compensation
agencies);
• for discussions between workers related to the care of clients;
• for discussions and other communications, e.g. with your doctors, other health
professionals, and others related to your care;
• for discussions with insurers (including the NDIS and its agents);
• for any insurance or compensation or other claims or litigation (including threatened
litigation);
• for security and workplace safety purposes, e.g. to monitor the safety of participants,
workers and others;
• for discussions with insurers (including the NDIS and its agents);
• for any insurance or compensation or other claims or litigation (including threatened
litigation);
• for security and workplace safety purposes, e.g. to monitor the safety of participants,
workers and others/
From time to time, we may use personal information (but not sensitive health information)
to provide you with news or offers about our products or services that may be of
interest to you. We will ensure that your consent to receive this type of communication
from us is opt-in, affirmative and freely given. These products and services will be
related to our services described above and will be products and services that we
believe will be relevant to you.
You have a right, at any time, to tell us that you don’t want to receive this type of material.
PART 3 – HOW WE HANDLE YOUR PERSONAL INFORMATION
a. Can people access our products and services anonymously?
No. Due to the nature of our services and products, we cannot offer them to people who
wish to be anonymous, wish to use a pseudonym or who do not provide us with
enough information to properly identify them for the purposes of providing services
and products.
b. Who will see or have access to your personal information?
Your information may be seen or used by people working for or on behalf of us
and other service providers including (without limitation):
• names, ages, dates of birth, genders, and other identifying information;
• Medicare and health fund details (including Medicare numbers and health fund
insurers and the extent of their coverage);
• developmental, medical, ethnic, language, cultural and social histories (including
medications, diagnoses, surgeries, and allergies);
• details about disabilities, impairments, challenges, barriers and facilitators;
• family histories, to the extent they may be relevant to our services;
• work and education histories;
• hobbies, motivations, interests, and activities in which clients and their families like
to participate;
• financial information concerning the ability of clients to pay for our products and
services;
• details related to the NDIS, including details of negotiations, assessments, plans and
packages;
• call records, wireless locations, and unique web browser details (when you use our
products and services, including online services).
• our directors and owners;
• our professional workers (employed or contracted);
• our administrative staff (employed or contracted);
• our third-party professional advisors and service providers, including (without
limitation) our lawyers, book-keepers, accountants, auditors, tax consultants, actuaries, management consultants and IT service providers (including software-as-a-service providers); Medicare, private health insurance providers, our insurers and reinsurers; the National Disability Insurance Agency and its agents;
We will not rent, sell, trade or otherwise disclose to any other third parties any personal
information about you without your consent, or unless we are required to by law
(including pursuant to a court or tribunal order), or where a permitted general situation
(including a permitted health situation) exists within the meaning of the Privacy Act
1988 (Cth), or if we reasonably believe disclosure is necessary for enforcement-related
activities.
c. Security of your personal information and data retention
We know that you are concerned about your personal information – especially your health
information. We will use reasonable endeavours to prevent unauthorised access to,
modification of, disclosure, misuse, or loss of that information, except as required by
law (e.g. under mandatory reporting laws, and our obligations to report incidences of
violence, exploitation, neglect and abuse, and sexual misconduct to the NDIS Quality
and Safeguards Commission and the police).
Our directors and staff have reviewed the requirements of the Privacy Laws and our third-
party service providers are aware that they are required to comply with the requirements of the Privacy Act 1988 (Cth).
We have data protection measures in place including password-locked computers when
we store personal information electronically. Our hard copy health records are stored
in a locked filing cabinet on site accessible only to authorised staff.
If we no longer need personal information about you for any purpose described above,
then we will take reasonable steps to destroy the information or to ensure that such
information is de-identified. This obligation is subject to an important exception – we
may be required to retain some information (e.g. health, financial or tax records) to
comply with our statutory and other legal obligations.
d. Access to and accuracy of your personal information
We take reasonable steps to ensure that personal information we collect about or from you
is accurate, complete, up-to-date and relevant whenever it is used, collected or
disclosed.
Subject to the recognised exceptions to access for organisations contained in the Australian
Privacy Principles (APP12.3), you have a right to access your information if you wish
(subject to any privilege or legal restrictions); and, if it is reasonable and practicable to
do so, we will give you access to the information in the manner requested by you. By
law, we may charge you a reasonable fee to cover the cost of retrieving and processing
the information.
If you believe personal information that we hold about you is inaccurate, out-of-date,
incomplete or misleading, we will, on receipt of your request, take steps that are
reasonable in the circumstances to correct the information.
e. What happens if personal information is disclosed outside Australia?
Given the increasing globalisation of electronic information systems and the businesses of
service providers, it is likely that personal information may be disclosed to a person or
entity outside Australia (e.g. to a third-party technology-related service provider
managed outside Australia). For the same reason, it is not practicable to specify the
countries in which such recipients may be located.
If your personal information is disclosed by us to an overseas recipient (e.g. to an insurer or
IT-service provider), we will take reasonable steps in the circumstances to ensure the
overseas recipient does not breach the Australian Privacy Principles in relation to the
information.
f. Information about newsletters and updates
If you have signed up or otherwise agreed to receive newsletters, emails, or other update
services from us, we will use you contact data (including your name and email) to
provide those services to you. We tailor information provided to you, we will look at
user statistics and preferences. These activities are for marketing and business
development purposes.
PART 4 – HOW WE HANDLE WEBSITE AND SOCIAL MEDIA
a. How is my information used through the Nova Speech Clinic website?
When You use our Website, We do not attempt to identify You as an individual user and
We will not collect personal information about You unless You specifically provide
this to Us.
Sometimes, We may collect Your personal information if You choose to
provide this to Us via an online form, proprietary or third-party booking platform or
by email, for example, if You:
• submit an online enquiry via Our website;
• book an appointment with Us through either our online booking platform;
• receive emails or newsletters from Us; or
• send a written complaint or enquiry.
b. Links to third party websites
We may create links to third party websites. We are not responsible for the content or
privacy practices employed by such websites that are linked from or to Our website.
c. Use and disclosure
We will use any personal information collected via Our website in accordance with Our
Privacy Policy.
d. Information about social media plug-ins
To improve the quality of our services to clients, our website includes social media plug-ins
of the large social media networks, including Facebook. Upon opening a website on
which a social media plug-in is embedded, the social network provider will collect and
process information on your visit to our website for its own business purposes. This is
not initiated or controlled by us, but is a built-in feature of most social media plug-ins.
For further information about these plug-ins and privacy, refer to the social media
platform’s privacy policy.
e. Cookies
Our websites use cookies to enable, optimise and analyse site operations, as well as to
provide content and to allow you to connect to social media. Cookies are small text
files that are stored on your computer’s browser directory or program data subfolders
when you visit our website. They are stored on your computer for the duration of
your visit or for when you re-visit our website at a later time. They allow our website
to store or access information from your browser about you, your settings, or your
device. They are uses mainly to ensure our website works well and, as a rule, do not
contain information that could identity you directly. You can find out more about
cookies via: www.allaboutcookies.org.
When you first click on our website, you will get a message that says something like:
“This website uses cookies to enable, optimise and analyse site operations, as well as to
provide personalised content and to allow you to connect to social media. By clicking
“I agree” you consent to the use of cookies for non-essential functions and the related
use of personal data.”
PART 5 – GENERAL INFORMATION
a. Changes to Our Privacy Policy
As Our clinic continues to expand and evolve over time, Our processes, policies and
systems will be reviewed and may be revised. We may change Our Privacy Policy at
any time to account for these changes. We will notify You of any change by posting
an updated version of Our Privacy Policy on Our website.
b. Complaints and asserting your privacy rights
We are committed to constantly improving Our procedures so that personal information is
treated appropriately. At any time, if:
• You have questions or comments about this Privacy Policy;
• We do not agree to provide You with access to Your personal information; or
• You have a complaint about Our information handling practices;
If you believe your privacy has been prejudiced by something we have done or failed to do,
you have a legal right to lodge a complaint. If you make a complaint to us, our
Privacy Officer will treat it very seriously, and will apply our [Complaints Management
NDIS Complaints Management and Resolution System Policy].
Our Privacy Officer can be contacted by email at admin@novaspeechclinic.com.au
In any event, we will respond to you in writing within 15 days of receiving your complaint.
If you are not satisfied with our response, you can refer your compliant to our [insert
name of owner or director], at [insert address] who will respond to you within 15 days
of receive such complaint.
A breach of your privacy may constitute a breach of the NDIS Code. In this situation, you or
anyone can make a complaint to us, or to the NDIS. As suggested in the NDIS Code,
we encourage you to contact us first, to see if we can resolve the matter directly.
You also have the right to lodge a complaint with the Office of the Australian Information
Commissioner, who is the competent supervisory authority.
A breach of privacy by a professional who works for us (e.g. a health care worker) may also
be a breach of their professional code of conduct or code of ethics.
As noted above, you have several statutory rights under privacy laws, including rights to
information, access, rectification and the withdrawal of your consent to the collection
and use of personal information. If you wish to assert any of these rights, please contact our Privacy Officer using the contact details included above.
c. Want more information?
If you have any questions about this Policy or this Notice, or have any concerns about the
personal information you or others have given us about you, please contact us at 0416 718 303.
More information on the Privacy Act 1988 (Cth) can be found on the website of the Office of the
Australian Information Commissioner: https://www.oaic.gov.au/
This Policy and Notice are in addition to, and do not relieve, remove or replace our rights and
responsibilities under applicable laws. If there is a conflict between this Policy and this Notice, on
the one hand, and an applicable law, on the other hand, the law shall prevail to the extent of any
conflict.
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