Privacy Policy
Effective Date: 27/05/2026 Last Updated: 27/05/2026
Welcome to Crystalline Counselling Pty Ltd. We are committed to protecting your privacy and managing your personal and sensitive health information in an open and transparent way.
This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit our website, use our services, or interact with our digital marketing (including Google Ads). We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and adhere to the strict requirements for handling sensitive health information.
1. Information We Collect
To provide you with safe, effective, and appropriate therapeutic services, we collect both personal and sensitive information.
1.1 Personal Information
Personal information is any information that can be used to identify you. We may collect:
• Contact Details: Name, email address, phone number, and physical address.
• Administrative Data: Emergency contact details, GP details, and Medicare/health fund information.
• Technical Data: IP address, browser type, device information, and interaction data collected via cookies when you visit our website.
1.2 Sensitive (Health) Information
Because we provide counselling and mental health services, we collect sensitive health information. This includes:
• Your medical, psychological, and family history.
• Presenting challenges (e.g., anxiety, depression, trauma).
• Clinical notes taken during therapy sessions.
We only collect sensitive information with your explicit consent and when it is reasonably necessary for providing our services.
2. How We Collect Your Information
We collect information in several ways:
• Directly from you: When you fill out intake forms, use our website contact forms, or communicate with us via email, phone, or during sessions.
• From third parties: With your consent, we may receive information from your GP, other allied health professionals, or referring agencies (e.g., a Mental Health Care Plan).
• Automatically: When you use our website, we (and third-party vendors like Google) may collect technical data using cookies and similar tracking technologies.
3. How We Use Your Information
We use your personal and sensitive information strictly for the purposes for which it was collected:
• Primary Purpose: To provide professional counselling, psychological assessment, and therapeutic support.
• Secondary Purposes:
◦ Administrative tasks, such as scheduling appointments and processing billing/Medicare claims.
◦ Communicating with you regarding your treatment or our services.
◦ Fulfilling legal and regulatory obligations.
We will never use your sensitive health information for direct marketing purposes.
4. Google Ads, Analytics, and Digital Marketing
We use digital marketing tools, including Google Ads and Google Analytics, to reach individuals who may benefit from our services. We adhere to strict advertising policies to protect your privacy.
4.1 How Third Parties Use Cookies
Third-party vendors, including Google, use cookies and/or device identifiers to serve ads based on your past visits to our website. These tools help us understand website traffic and improve user experience.
4.2 Health in Personalised Advertising
In compliance with Google Ads policies regarding "Health in Personalised Advertising", we do not use sensitive health information to target ads. We do not use remarketing (showing ads to past website visitors) based on inferred mental health conditions, personal struggles, or trauma.
4.3 Opting Out of Cookies and Tracking
You have the right to control how your data is tracked:
• Google Ads Settings: You can opt out of Google's use of cookies or device identifiers by visiting the Google Ads Settings.
• Browser Settings: You can configure your web browser to refuse cookies or alert you when cookies are being sent.
• Third-Party Opt-Out: You can opt out of third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.
(Note: If you choose to disable cookies, some features of our website may not function properly.)
5. Disclosure of Your Information
Your privacy and the confidentiality of our therapeutic relationship are paramount. We will not disclose your personal or sensitive information to third parties, except in the following circumstances:
• With your explicit consent: For example, providing a progress report to your referring GP or discussing your care with another health professional.
• To service providers: We may share non-sensitive data with trusted third-party service providers (e.g., secure practice management software, IT support) who perform services on our behalf. These providers are bound by strict confidentiality agreements.
• Legal and safety obligations: We are legally and ethically required to disclose information without your consent if:
◦ We reasonably believe there is a serious and imminent risk to your life, health, or safety, or that of the public.
◦ We suspect child abuse or neglect (mandatory reporting).
◦ Our records are subpoenaed by a court of law.
6. Data Security and Retention
We take reasonable steps to protect your personal and sensitive information from misuse, interference, loss, unauthorised access, modification, or disclosure.
• Digital Records: Stored securely using Australian-compliant, encrypted practice management software.
• Physical Records: Stored in locked filing cabinets accessible only to authorised personnel.
6.1 Data Breaches
In the unlikely event of a data breach that is likely to result in serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988.
6.2 Retention
By law, we are required to retain adult client health records for a minimum of 7 years from the date of the last consultation. For clients under 18, records must be kept until the client attains the age of 25. After this period, records will be securely destroyed or de-identified.
7. Access and Correction of Your Information
You have the right to request access to the personal and health information we hold about you, and to request that we correct any inaccuracies.
• To request access: Please submit your request in writing to our Privacy Officer (details below). We may require proof of identity before releasing records.
• Corrections: If you believe the information we hold is inaccurate, out of date, or incomplete, please inform us so we can amend our records.
We will respond to your request within 30 days. We do not charge a fee for making a request, but we may charge a reasonable administrative fee for the time and resources required to collate and provide copies of your records.
8. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or advertising platform policies. The updated policy will be published on our website with the revised "Effective Date."
9. Contact Us and Complaints
If you have any questions about this Privacy Policy, wish to access or correct your data, or want to make a complaint about a potential breach of the Australian Privacy Principles, please contact us:
Crystalline Counselling Pty Ltd
Email: info@crystallinecounselling.com.au
Phone: 0415 906 401
Address: 26 Amelia Pl, Kureelpa, QLD, 4560
We take all privacy complaints seriously and will investigate and respond to your complaint in writing within 30 days.
If you are not satisfied with our response, you may lodge a formal complaint with the Office of the Australian Information Commissioner (OAIC):
• Phone: 1300 363 992
• Website: www.oaic.gov.au
• Post: GPO Box 5218, Sydney NSW 2001