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Privacy Policy

Last updated: 23 September 2025


Applies to: earthsoulcounselling.com.au and counselling services delivered by Earth Soul Counselling (Michelle Collier)

Earth Soul Counselling (“I”, “me”, “my”) respects your privacy and is committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. What this policy covers
This policy explains how I collect, use, store, and disclose your personal information when you visit my website, make an enquiry, or engage in counselling (in person, phone, or telehealth).

2. The information I collect

  • Personal information: name, date of birth, address, phone, email, emergency contact.

  • Sensitive information (as defined by the Privacy Act): health and mental health information, family and social history, cultural background, court orders, and other information you share that is necessary for counselling.

  • Payment information: invoices and payment confirmations (I do not store full card details).

  • Website/technical data: IP address, device/browser details, pages visited, and cookies/analytics data (see Section 9).


3. How I collect information

  • Directly from you (verbally in sessions; by phone/video; via email/SMS/forms).

  • Through my online booking and practice management system (Halaxy).

  • From a referrer (e.g., GP or support service) with your consent, or where permitted by law.

  • For clients under 18, from a parent/legal guardian providing consent.


4. Why I collect and use your information

  • To provide counselling safely and effectively (assessment, planning, delivery, and continuity of care).

  • To manage bookings, reminders, billing, receipts, and record-keeping.

  • To communicate with you about appointments and service updates.

  • To meet legal, regulatory, and professional obligations (e.g., clinical records, supervision in de-identified form).

  • To operate and improve my website and services.


5. Your choice and consent
Providing personal information is voluntary, but if you choose not to provide information needed for safe and ethical practice, I may be unable to offer services. You may use a preferred name, however a legal name (as per ID) is required for clinical and legal records.

6. Confidentiality and disclosure
I keep information confidential unless disclosure is:

  • Required or authorised by law (e.g., subpoena, child protection, court order), or

  • Needed to prevent or lessen a serious threat to life, health, or safety, or

  • Made with your informed consent (e.g., liaising with a GP or another provider).


7. How I store and protect your information
Clinical records are stored securely in my practice management system (Halaxy) and in encrypted file storage accessible only by me. I apply reasonable technical, administrative, and physical safeguards to protect against unauthorised access, alteration, or misuse.
 
I may use a transcription/note-assist provider during sessions to generate draft clinical notes or letters (currently Novo Note; I may change to Heidi Health). These tools process live audio to create text; session audio is not retained by the provider. Drafts are reviewed by me and, once finalised, saved to your Halaxy record.

 These tools are not used for bookings, reminders, or payments. (See Section 10 for provider details and links.)
 
I do not store full card details; payments are processed by a compliant payment provider.
 
If a data breach is likely to cause serious harm, I will follow the Notifiable Data Breaches scheme (assess, contain, notify affected individuals and the OAIC as required).
Some systems may use cloud infrastructure located in or outside Australia. I take reasonable steps required by the Australian Privacy Principles, including APP 8, to ensure any overseas handling is consistent with the APPs. I remain responsible for your information.

8. Retention and deletion
I retain clinical records for at least 7 years after the last contact, or longer where required (for clients under 18, records are generally retained until at least age 25).
 
When no longer required, information is securely destroyed or de-identified, subject to legal obligations.

9. Website, cookies, and analytics
My website may use cookies and analytics to improve performance, security, and user experience (e.g., page load, navigation insights). You can adjust your browser settings to refuse cookies; some features may not function properly without them.

10. Third-party platforms, telehealth and recordings
To deliver services and run my practice I use reputable providers who process limited personal information on my behalf:

  • Halaxy (bookings/records/billing): appointments, reminders, invoices/receipts, and system of record for clinical notes.

  • Transcription / note-assist provider (real-time drafting of notes):

    • Current: Novo Note - optional audio-to-text transcription used only with your express, opt-in consent given in advance. Policy: https://novopsych.com/novonote-privacy-policy-security/

    • Possible alternate provider: Heidi Health - similar function; if adopted, audio-to-text transcription would also require your express, opt-in consent. Policy: https://www.heidihealth.com/au/legal/privacy-policy

    • In all cases, the provider processes live audio to create text; session audio is not retained. I review drafts and save final notes to Halaxy.
       

  • Telehealth: Sessions may be conducted via a secure video platform or phone. A link is provided once consent and payment are completed. I do not record sessions by default.

  • Email/SMS: Used for confirmations and reminders. As these channels are not end-to-end encrypted, please avoid sending sensitive clinical details by email/SMS.

  • Payments/website: Payments are processed by compliant providers; my website is hosted on a reputable platform. Only the minimum information necessary is shared with them.
     

Recording policy (privacy context)
Sessions are not recorded by me or my systems without explicit written consent for a defined purpose. Clients must not audio- or video-record sessions without my prior written consent (see Counselling Service Terms).

11. Access and correction
You may request access to, or correction of, your personal information. I’ll respond within a reasonable time and may ask you to specify what you need. Access can be refused in circumstances allowed by the Privacy Act (you’ll receive a written explanation if so). Administrative fees may apply for compiling copies.

12. Complaints
If you have a privacy concern, please contact me first so I can try to resolve it promptly.
If you are not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC). See oaic.gov.au for how to lodge a complaint.

13. Children and adolescents
Where counselling is provided to a person under 18, I generally require parent/guardian consent. Mature-minor considerations may apply on a case-by-case basis consistent with law and professional standards.

14. Changes to this policy
This policy may be updated from time to time. The latest version will always be available on my website and will state the effective date.

15. Contact
Earth Soul Counselling – Michelle Collier
Email: michelle@earthsoulcounselling.com.au
Phone: (07) 5241 1057

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