Privacy Policy

Who We Are and Scope

Pebbles & Pathways Psychology is a private child- and family-focused psychology practice. This policy applies to all services we provide, including clinic consultations, telehealth sessions, website interactions, email or phone correspondence, and communication with third parties such as schools, GPs, and funding agencies (including the NDIS). We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Key Definitions

Government identifiers – numbers such as Medicare or NDIS participant numbers, which are only used as required by law (e.g., for claiming rebates).
Young person – any individual under 18 years.
Capacity to consent – a young person’s ability to understand what consent means, including its risks, benefits, and consequences.
Parental responsibility – the legal duties and authority of parents or guardians.

Information We Collect

We collect information that is relevant to your care and to the safe operation of our practice, including:

Personal information (information that identifies you, such as, name, date of birth, address, phone number, email)
Sensitive information (personal information given higher protection, such as details of race, religion, sexual orientation, criminal history, or health information.
Clinical details – referral letters, medical history, assessments, session notes, treatment goals, and reports.
Administrative and funding information – government identifiers, billing history, insurance details, and correspondence.
Website and telehealth data – information provided during online sessions, forms, or website use.

Information may be collected:

Directly from you during intake, sessions, or when you provide details via email, phone, or paper/online forms.
From third parties (e.g., GP, paediatrician, school, NDIA) with your consent, or where required by law.

Why We Collect and Use Information

We use your information to:

Deliver psychological care, including assessment, diagnosis, and intervention.
Coordinate with professionals and agencies involved in your young person's care.
Manage practice operations such as bookings, billing, supervision, and compliance.
Meet legal and professional obligations (e.g., court orders, risk management, child protection).

Confidentiality, Consent, and Information Sharing

What you share with Pebbles & Pathways Psychology is treated as confidential. Information will only be disclosed in the following circumstances:

With your consent – we may share relevant information with professionals and agencies involved in your care, such as GPs, paediatricians, schools, allied health providers, the NDIS, Medicare, or insurers.
For practice operations – service providers such as practice management software, secure storage, telehealth platforms, or payment processors may access limited information. These providers are bound by strict confidentiality and security standards.
Where required by law – such as, subpoenas, court orders, mandatory child protection reports, or regulator directions.
To prevent serious harm – if disclosure is necessary to reduce or prevent a serious risk of harm to you or others.
In clinical supervision – client matters may be discussed for professional development, but identifying details are removed and protected.
All significant disclosures are documented in your file for accountability.

Working with Children and Young People

Our approach balances parental responsibility with the emerging autonomy of young people, consistent with APS Ethical Guidelines and ACT legislation.

Parents/guardians are considered to have parental responsibility and have a right to request access to their young person’s information. Parents/guardians usually hold decision-making rights, subject to court orders. Where disputes exist, the young person’s wellbeing remains paramount.
Young people are involved in decisions wherever possible, considering their capacity to consent. Those with sufficient maturity may be acknowledged as having capacity to make their own decisions about whether and how their information is shared with others (including parents/guardians). In the ACT, young people aged 14 years or older who are assessed as having capacity will have their consent considered before information is shared.
Parental access may be limited where permitted by law (e.g., if disclosure could cause harm or the young person objects with capacity).

Storage, Retention, and Access

We take reasonable steps to ensure information is accurate, complete, and secure. Measures include encrypted systems, password protection, locked cabinets, and access restrictions based on need-to-know principles.

Session notes and AI Transcription Tools: Our session notes are completed securely within Splose, our practice management system. Splose offers a private voice-to-text feature that helps with accurate and efficient note-taking.If used, no audio recordings are kept, and all information is encrypted and stored securely.
Retention: Records are kept for at least 7 years after last contact, or until age 25 if created when under 18, unless law requires longer.
Destruction: When records are destroyed, a record of destruction (client name, date, period covered) is kept for accountability.

Your Choices, Access, and Correction

Anonymity: Clients and/or parent/guardians of clients may request to remain anonymous or use a pseudonym, unless this is impracticable or unlawful (e.g., Medicare/NDIS claims).
Correction: If clients and/or parent/guardians of clients believe their information is inaccurate, incomplete, or misleading, they may request a correction. We will take reasonable steps to amend the information and notify them of the outcome.
Access to information:
- All requests must be made in writing and should include your full name, address, and contact details.
- Requests should specify the particular records you wish to access and, where possible, the format you would like them provided (copies, inspection, or summary).
- We will respond within 30 days, unless an exception under the Privacy Act 1988 (Cth) applies.
- Administrative fees may apply for photocopying, preparing files, or professional appointments to review records.

Cross-Border Disclosure

We prioritise Australian-based service providers. Where overseas disclosure is unavoidable (e.g., secure cloud platforms in the USA or EU), we take reasonable steps to ensure protection to Australian standards. Consent will be sought where appropriate.

Changes to this Policy

This policy may be updated if laws, technology, or practice operations change. The most current version will be available on our website or by request.

Questions or Complaints

Pebbles & Pathways Psychology takes privacy and confidentiality seriously. If you have a concern about how your information is handled, please contact our Privacy Officer via email on admin@pebblespathwayspsychology.com

We will acknowledge complaints within 5 business days and aim to provide a full response within 20 business days or advise you if more time is required. We encourage you to raise concerns with us first, as this often allows issues to be resolved quickly and respectfully.

If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC) for privacy complaints
📞 1300 363 992 | 🌐 www.oaic.gov.au