Our Policies

Last reviewed September 2024

Eastern Child & Adolescent Psychology is committed to providing quality services through our clinic and website. In providing this service, we may collect or be provided with personal information about you online (website enquiry, chat or email) or offline (phone call). This policy outlines our ongoing obligations regarding managing your personal, sensitive and health information. We have adopted the Australian Privacy Principles (APPs) from the Privacy Act 1988. The APPs govern how we collect, use, disclose, store, secure, and dispose of your Personal Information. A copy of the Australian Privacy Principles can be obtained from the Office of the Australian Information Commissioner's website.

Types of Information Collected

Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

Sensitive information is a subset of personal information that is given higher protection under the Australian Privacy Principles. It includes information about your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.

Health information is a type of sensitive information and includes any personal information that is collected while providing you with a health service. For example, any details you share with us in a consultation about your medical history or mental health will be health information.

When you send an enquiry through our website or email, we may collect the following:

Your name
Your contact details (email address and phone number)
Your child’s name
Your child’s school
Any other required personal information requested by us and/or provided by you or a third party

When you register or book appointments with us as a client, we may collect the following:

Your contact details, including email, phone and residential address
Your child’s name and date of birth
Your and your child’s Medicare number
Details of your referring doctor or paediatrician
A brief overview of the presenting concern
Any other required personal information requested by us and/or provided by you or a third party

When you attend a psychological consultation, we may collect the following:

Personal details
Sensitive information (including health information)
Detailed information about your or your child’s medications, your physical health and psychological health
Your and your child’s race/ethnic origin
Your and your child’s religious beliefs
Any other sensitive details you choose to share with us

Purpose

Your personal, sensitive and health information is gathered and used for the purpose of providing psychological services, including assessing, diagnosing and treating a presenting issue. This information is retained to document what happens during sessions and enables the psychologist to provide a relevant and informed service.

We may also use the personal information we have collected from you for the purposes related above and to:

Verify your identity
Register you as a client
Administer and provide our services (including invoicing or billing for our service and booking an appointment)
Enable your referring doctor to refer you to us and/or book an appointment for internal record keeping
Notify you of new or changed services offered concerning our Services
Carry out marketing or training relating to our Services
Comply with laws and regulations in applicable jurisdictions
Communicate with you
To enable you to access and use our website and trusted associated applications and platforms and
To comply with our legal obligations and resolve any disputes that we may have.

We will only use your personal information for the purposes described in this Policy or with your express written permission.

Disclosure

Your personal information will not be disclosed except when:

It is subpoenaed by a court
Failure to disclose the information would, in our reasonable belief, place you or another person at serious risk to life, health or safety
When communicating with our employees, contractor, GP/Paediatrician and/or other medical practitioners when referred under a Medicare Scheme, NDIS and other referral schemes or
When third-party service providers require the information to enable them to assist us in providing our services to you, including our practice management cloud-based software
Software to send and receive emails and for internal business purposes, including for accounting purposes and business document storage
IT services for IT support, advice and management
Telehealth solutions
Payment service providers
Telecommunication service provider
It is required for the delivery of our services
To comply with the legal requirement, such as the law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request

Your prior written approval has been obtained to:

Provide a written report to another professional or agency, e.g., a GP or a lawyer, or
Discuss the material with another person, e.g., a parent, employer or health provider, or
Disclose the information in another way; or
Provide our services to you in accordance without AI Policy; or
Disclosure is otherwise required by law; or
When we make a clinical decision to disclose your personal information to any other relevant third parties, we do so based on an assessment of your best interests, considering your age, health, safety, and any possible immediate or substantial risk to you.

Overseas disclosure: We take reasonable steps to use Australian-based third-party service providers where practicable. However, these providers are occasionally located outside of Australia or need to transfer or access your information outside of Australia to assist us in providing our services. Some information is held on our servers or service provider servers that can be overseas.

By providing us with personal information, you understand we may disclose a limited amount of your information outside of Australia and acknowledge that where we disclose personal information to a third party outside of Australia, we will only use reputable third parties. We will only disclose the personal information necessary for the recipient to assist us in supplying our Services to you.

Your personal information will not be used, sold, rented or disclosed for any other purpose.

Your sensitive information may only be used and disclosed for purposes for which you may consent, such as:

To provide a written report to another agency or professional, such as a general practitioner or a lawyer
To discuss the material with another person, such as a parent, employer, health provider, or third-party funder.
To disclose the information in another way; or
Provide our services to you in accordance without AI Policy; or
To disclose to another professional or agency, such as your general practitioner.
secondary purposes directly related to the primary purpose for which your sensitive information was collected, including disclosure to the above-listed third-party service providers as reasonably necessary to provide our services to you
To refer you to medical or health service providers or to speak with your family, partner or support person where we reasonably believe there is a severe risk to the life, health or safety of you or another person and it is impractical or we are unable to obtain your consent; and if otherwise required or authorised by law, such as where the information is subpoenaed.

Storage, Retention & Security

Your information is stored in a manner that reasonably protects it from misuse and loss and unauthorised access, modification or disclosure. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files, which will be kept by us for a minimum of 7 years. If the client is under the age of 18 at the time of service, the documents will be kept until they are over 25 years old.

We are committed to ensuring that the personal information we collect is secure. To prevent unauthorised access or disclosure, we have established suitable physical, electronic and managerial procedures to safeguard and secure your personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

These procedures include:

Securing any personal information we hold in an electronic format behind password log-ins (typically with multi-factor authentication)
Securing any personal information we hold in physical files in a locked cabinet
Encrypting data, using virus protection software, implementing firewalls, and
Limiting internal access to the personal information we hold about you based on a need-to-know basis.

Although we take measures to safeguard against unauthorised disclosures of information, due to the inherent risks associated with the Internet, we cannot assure you that the personal information we collect and send over the Internet will not be disclosed in a manner inconsistent with this Privacy Policy.

Rights & Access

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, youunderstand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us; however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and Unsubscribe: If you have previously agreed to ECA Psychology using your personal information for direct marketing purposes, you may change your mind by contacting us using the details below. To unsubscribe from our e-mail database or opt out of communications (including any marketing communications), please get in touch with us using the details below or opt-out using the opt-out facilities provided in the communication.

Access and Correction: At any stage, you may request to see and correct the personal information about them kept on file. The psychologist may discuss the contents with them and/or give them a copy, subject to the exceptions in the Privacy Act 1988 (Cth). If satisfied that personal information is inaccurate, out of date, or incomplete, reasonable steps will be taken to ensure that this information is corrected.

All requests by you for access to or correction of personal information held about them should be lodged with the administration at info@ecapsych.com.au. A request must state your name and address, particularise the health information to which access is sought, and specify the form you would like the information provided. These requests will be responded to in writing within 30 days, and, if necessary, an appointment will be made for clarification purposes. An administrative fee for providing such information and professional fees for appointments may be payable. Please note that we may be legally permitted to withhold access to your personal information or the personal information you requested in some situations.

Following the Health Records and Information Privacy Act 2002 No 71, if you are a parent or legal guardian and you would like to request access to your child’s information, in addition to the information that needs to be included in a regular request for information, we also require that you provide evidence of your parental authority or guardianship to have access to the information in their request.

If you are the parent or legal guardian of a child between the ages of 14-16 years old, and the child has been deemed by us to have the capacity to make independent decisions about their health care. In that case, we may legally withhold the child’s information from you.

Policy Updates & Concerns

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website and making it available to you in hard copy within our practice. We recommend you regularly check our website and the policy available in our practice to ensure you know our current Privacy Policy.

We do not have any control over any website that is not ours, and we cannot be responsible for the protection and privacy of any personal information you provide while visiting other websites. Those websites are not governed by this Privacy Policy, and we recommend that you review the privacy policies on those other websites before using them.

Concerns: If you are concerned about managing their personal information, they may inform the administration (info@ecapsych.com.au). Upon request, you can obtain a copy of the Australian Privacy Principles, which describe their rights and how their personal information should be handled. Ultimately, suppose you wish to lodge a formal complaint about the use of, disclosure of, or access to their personal information. In that case, they may do so with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at https://www.oaic.gov.au/privacy/privacy-complaints or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001.

Software & Artificial Intelligence (AI) Policy

Last reviewed September 2024

Eastern Child & Adolescent Psychology’s commitment to the legal, ethical and responsible use of AI

Eastern Child & Adolescent Psychology (“us”, “we” or “our”) is committed to using AI to improve the health outcomes of clients, in a way that is legal, ethical and responsible.
The purpose of this AI Policy is to create a set of guiding principles that comply with the legal and ethical obligations that govern the responsible use of AI applications by clinicians.
Eastern Child & Adolescent Psychology takes the privacy of clients’ information seriously, and our Privacy Policy sets out how we collect and treat your Personal Information and Sensitive Information. Our Privacy Policy and this AI Policy operate together.
This AI Policy deals with both the general principles Eastern Child & Adolescent Psychology is committed to in order to ensure the legal, ethical and responsible adoption and use of AI applications, as well as guidelines for the AI applications used by Eastern Child & Adolescent Psychology to ensure the use of those applications is of benefit to clients and promotes client health outcomes while protecting client data and information.

Definitions. In this Policy:

“AI” stands for artificial intelligence, and refers to the capability of a machine to imitate intelligent human behaviour.
“AI application” describes any software program that uses AI to perform tasks.
“Large language model” or “LLM” is a type of artificial intelligence model designed to understand, generate or manipulate human language. They are trained on very large amounts of text data and use statistics and machine learning techniques to generate text based on the input they receive.
“Generative AI” is a type of machine learning model that generates new content (for example, text, images, videos etc) as outputs.

Eastern Child & Adolescent Psychology’s Statement of Values and Ethics in the use of AI

Eastern Child & Adolescent Psychology believes that with appropriate policies in place, AI can support the delivery of healthcare outcomes.
We believe that human-delivered care must never be replaced by AI, but that AI has the potential to assist in care delivery and improve client outcomes. AI is seen by Eastern Child & Adolescent Psychology as a means to achieving the goal of improved healthcare but can only support the psychologist and client to reach this goal.
Improved client health and well-being will always be the primary and guiding focus of the adoption of all AI applications by Eastern Child & Adolescent Psychology. AI applications will only be adopted by Eastern Child & Adolescent Psychology where this will genuinely contribute to improving health outcomes of clients.
The adoption and implementation of all AI applications by Eastern Child & Adolescent Psychology will be client-centred and used to benefit clients’ health and well-being.
AI must never compromise the clinician’s clinical independence or professional autonomy.
A registered health practitioner or otherwise appropriately qualified clinician must always be ultimately responsible for decisions and communications and should have meaningful involvement at all stages of the client journey.
All AI applications implemented by Eastern Child & Adolescent Psychology must uphold and support clients’ rights to make their own informed healthcare decisions.
It is important to Eastern Child & Adolescent Psychology to be accountable and transparent to clients, the health profession and the wider community about the use of AI in supporting clients’ healthcare outcomes.
The application of AI in health care must never lead to greater health inequalities for any population.
Clients have the right to refuse to be involved in the use of AI.
AI applications will only be adopted by Eastern Child & Adolescent Psychology after first establishing robust and effective frameworks for managing risks which ensure client safety and guarantee the privacy for all involved. These frameworks will be bespoke to the AI application being adopted, and regularly and vigorously reviewed.
Eastern Child & Adolescent Psychology will never establish protocols where the clinical independence of the clinician is undermined by AI or the final decision is made by a person in a non-clinical role with the aid of AI.
AI applications will not be used by administrative (non-clinical) staff.

Use of client data and information

As outlined in our Privacy Policy, Eastern Child & Adolescent Psychology may receive and store your Data.
We are committed to the protection of the privacy of client health information.
We will always use AI in accordance with the Privacy Policy in place at the relevant time.
We will only adopt and use AI applications following a careful review of that application’s approach to privacy, and has adopted a protocol of regular checking the application to ensure there has been no material change to the way client data and information is stored, used and deleted.
AI applications will not be used, disclosing a client’s personal or sensitive information, without written consent from the client.
The disclosure of Health Information must be limited to initiatives that exclusively aim to provide the health service to the client and/or improve the client’s health outcomes.

Complaints about our AI policy

If you have any complaints about our AI practices, please feel free to send in details of your complaints to: info@ecapsych.com.au
We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

Changes to our AI policy

Our AI Policy is subject to change.
We may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website, or through distribution by email. Please check back from time to time to review our AI policy.

Current AI applications in use

We will maintain a list of AI applications that are regularly used by clinicians. At present, we use: Heidi Health & Grammarly
Summaries of Heidi Health and Grammarly are set out below.

Heidi Health

What Heidi Health does: Heidi Health is a note-taking service that makes a note of what is said during a consultation or is dictated by the clinician after a client consultation and then uses AI to produce and record a summary document of key information in accordance with ethical principles.
Why Heidi Health has been adopted: Heidi Health will assist clinicians by recording all relevant information during a consultation. This information if often, especially in initial assessment consultations, quite broad and detailed. Heidi Health will ensure that the practitioner’s focus will be on the client, and not on recording the information (beyond a handful of key points). This will enable the practitioner to focus on engaging with the client, providing better eye contact and open communication signals, as well as the delivery of psychological interventions, which will assist the client in establishing a better therapeutic rapport with the practitioner and lead to better client outcomes. Heidi Health will also reduce the time spent by the practitioner in preparing records following the consultation, which will instead be allocated to a larger focus on treatment planning and preparation for psychological intervention.
What Heidi Health will be used for: Client consultations and case consultation notes. Heidi Health will only be used by clinicians.
What Heidi Health will not be used for: Heidi Health cannot and will not be used to make decisions in relation to client care. Heidi Health will not be used by administrative (non-clinical staff). Notes generated by Heidi Health will not be adopted as a part of the client’s file without a careful review by the clinician, and a record of the person who reviewed the note.
Written consent: Heidi Health will only be used with clients who have provided written consent for the use.
Accountability: The clinician using Heidi will be responsible for adopting the notes made by Heidi Health. That is, the notes will not be automatically saved to the client’s file, but will be reviewed for accuracy and completeness by the practitioner, who is ethically responsible for the client’s records.
Key Points Notes: The key point notes are an important safeguard in ensuring the notes generated by Heidi Health are accurate and record the important parts of all client consultations. During the consultation, the practitioner will make a record of the key points that must be included in the client’s records. The practitioner will use these key points when reviewing the note prepared by Heidi Health, to ensure that the note is both accurate and complete. In this way, each note will have an independent human lead review to ensure that case notes created by Heidi Health are at least as good as the notes that would have been recorded by the practitioner during the client consultation.
Transparency: for internal record-keeping purposes, content created with the assistance of Heidi will be labelled as such, by including a note like the following: “Case note [or other appropriate description of document] created with the use of Heidi, and reviewed and adopted by [clinician’s name].”
Data storage by Heidi Health: Heidi Health will store a recording of the client consultation or practitioner’s dictation on local servers in Australia. Although the data can be stored for longer periods of time, we will set a mandatory timeframe for all data to be deleted within 7 days. Heidi Health has been carefully selected by Eastern Child & Adolescent Psychology as it complies with the Australian Privacy legislation and the Australian Privacy Principles.
Authorised Use: Only clinicians will have access to and use Heidi Health. Administrative staff will not use the application and will not have access to the system.
Assessment and review schedule: Eastern Child & Adolescent Psychology is committed to a regular assessment and review of the adoption and use of Heidi Health. In addition to the contemporaneous review for accuracy and completeness conducted before the adoption of every single note created by Heidi Health, Eastern Child & Adolescent Psychology will conduct a comprehensive random audit every 6 months. The purposes of the random audit include confirmation that the AI Policy is being adhered to, that the information contained in the AI policy in relation to each AI application adopted is correct and up-to-date, and that the notes generated after consultations are both accurate and complete.

Grammarly

What Grammarly does: Grammarly is a writing app that ensures documents are written clearly and reduces grammatical and sentence structure mistakes. Grammarly is an AI-powered writing enhancement that happens in real time to improve grammar, spelling, punctuation and sentence structure.
Why Grammarly has been adopted: Grammarly has been adopted because it improves the clarity of written documentation, enhancing the service offered to clients through improved communication in notes, emails, letters, and reports.
What Grammarly will be used for: To review my written documentation (letters and reports) and provide written work developed to the best of its ability to service our clients.
What Grammarly will not be used for: Grammarly cannot and will not be used to replace the clinical decision-making of psychologists.
Written consent: Grammarly will only be used with clients who have provided written consent for the use.
Accountability: The clinician using Grammarly will be responsible for reviewing the sentence structure modifications made by Grammarly. The psychologist continues to write their reports and letters as typical and then goes through a review process with Grammarly suggestions and elects whether to include or not include the recommendations.
Data storage: Grammarly reports that it adheres to copyright requirements, does not provide data to third parties, and does not run in sensitive fields. Grammarly reports that it encrypts all data before it is stored in the United States.
Authorised Use: Only clinicians will have access to and use Grammarly. Administrative staff will not use the application and will not have access to the system.
Assessment and review schedule: Eastern Child & Adolescent Psychology is committed to a regular assessment and review of the adoption and use of Grammarly. In addition to the contemporaneous review for accuracy and completeness conducted before the adoption of every single document reviewed by Grammarly, Eastern Child & Adolescent Psychology will conduct a comprehensive random audit every 6 months. The purposes of the random audit include confirmation that the AI Policy is being adhered to, that the information contained in the AI policy in relation to each AI application adopted is correct and up-to-date, and that the notes generated after consultations are both accurate and complete.