Privacy Policy

AnnOT Occupational Therapy ("AnnOT", "we", "us" or "our") is committed to protecting the privacy, confidentiality and security of personal and health information entrusted to us.

AnnOT provides Occupational Therapy services to adolescents and adults, including community-based and telehealth services. We handle personal and health information in accordance with applicable Australian privacy and health-records laws, including the Privacy Act 1988 (Cth), the Australian Privacy Principles and, where applicable, the Health Records Act 2001 (Vic) and Victorian Health Privacy Principles.

This policy explains the kinds of information we may collect, why we collect it, how it may be used or disclosed, how it is protected, and how you may request access, correction or make a privacy complaint.

1. Personal and health information we may collect

The information we collect depends on your contact with AnnOT and the service being requested or provided. It may include:

• name, date of birth, address and contact details;
• details of a parent, guardian, nominee, representative, carer or emergency contact;
• referral information and reason for referral;
• health conditions, disability, medical history and other health information relevant to Occupational Therapy;
• functional abilities, support needs, goals, routines, participation and living arrangements;
• information relating to mobility, cognition, communication, personal care and daily living;
• information about assistive technology, equipment, home modifications and living environments;
• assessment findings, clinical observations, progress notes, recommendations and reports;
• NDIS, funding, billing and payment information where relevant;
• appointment, correspondence and communication records; and
• other information reasonably necessary to provide services or meet professional, administrative and legal obligations.

Health information is sensitive information and is handled with additional care. AnnOT aims to collect only information reasonably necessary for its functions and the safe and appropriate provision of services.

2. How we collect information

AnnOT may collect information:

• directly from a participant or client;
• through our online referral form;
• during telephone, email, telehealth or in-person communications;
• during Occupational Therapy assessment and intervention;
• from an authorised parent, guardian, nominee, family member or carer;
• from Support Coordinators, allied health practitioners, health professionals and other authorised referrers; and
• from documents, reports or records provided to us.

Where another person provides information about a participant, they should only provide information they are authorised to disclose. Where practicable, AnnOT seeks to collect health information directly from the person concerned.

3. Why we collect, use and hold information

We may collect, use and hold personal and health information to:

• review and respond to enquiries and referrals;
• assess whether AnnOT is an appropriate service provider;
• arrange and manage appointments;
• provide Occupational Therapy assessment, intervention, consultation and telehealth services;
• understand functional needs, goals and support requirements;
• prepare clinical documentation, recommendations and reports;
• communicate with authorised people involved in a participant's care or supports;
• manage funding, invoicing and payments;
• maintain clinical and business records;
• respond to complaints, access or correction requests; and
• meet professional, insurance, regulatory and legal obligations.

We generally use or disclose information for the purpose for which it was collected, or for a related purpose that would reasonably be expected. Where required, consent will be sought before information is used or disclosed for another purpose unless the use or disclosure is otherwise authorised or required by law.

4. Referrals

A referral may be submitted by a participant, family member, guardian, Support Coordinator, health professional, allied health professional, community organisation or other appropriate referrer.

The online referral form may request personal and health information necessary to understand the referral, assess service suitability, contact relevant people and arrange next steps. Providing incomplete information may affect our ability to assess or respond to a referral.

Submitting a referral does not automatically create a therapeutic relationship or guarantee that AnnOT can accept the referral.

5. Splose and other service providers

AnnOT uses third-party technology and service providers to support administration and service delivery. The AnnOT online referral form is provided through Splose, a practice management platform used by allied health providers.

Information submitted through the embedded Splose referral form is handled using Splose's systems and may be subject to Splose's own privacy, security and data-handling arrangements in addition to AnnOT's obligations.

AnnOT may also use service providers for functions such as email, telehealth, website hosting, information technology, accounting, payment processing, document management and professional advice. We take reasonable steps to use providers appropriate to the sensitivity of the information involved.

6. Disclosure of information

AnnOT does not sell personal or health information.

Where reasonably necessary, authorised, consented to, or otherwise permitted by law, information may be disclosed to:

• the participant or their authorised representative;
• parents, guardians, nominees or carers where appropriate;
• Support Coordinators and other relevant support providers;
• treating, referring or allied health professionals;
• funding bodies where required;
• technology, administration, accounting or professional service providers supporting AnnOT; and
• government, regulatory or law-enforcement bodies where disclosure is required or authorised by law.

AnnOT aims to disclose only the information reasonably necessary for the relevant purpose.

7. Overseas processing or disclosure

Some technology providers or their subcontractors may operate, support systems or process information from locations outside Australia. Where AnnOT discloses personal information to an overseas recipient and Australian privacy law applies, we will take reasonable steps required by applicable law in relation to that disclosure.

If you would like current information about the technology providers used by AnnOT or the locations in which information may be processed, please contact us using the details below.

8. How we protect information

AnnOT takes reasonable steps to protect personal and health information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include:

• password-protected systems and access controls;
• secure practice-management and communication systems;
• security features provided by technology providers;
• limiting access to information to people who require it for their role;
• appropriate clinical and administrative procedures; and
• secure retention and disposal practices.

No electronic communication or storage system can be guaranteed to be completely secure, but AnnOT takes reasonable steps appropriate to the sensitivity of the information it holds.

9. Email and electronic communications

Email and other electronic communications can involve privacy and security risks. Participants and referrers should avoid sending unnecessary sensitive information through unsecured communication channels. If you have concerns about sending sensitive information electronically, please contact AnnOT to discuss an appropriate method.

10. Telehealth

Where telehealth is used, AnnOT may collect and discuss personal and health information necessary to provide the service. Participants are encouraged to attend telehealth appointments from a private environment where possible. AnnOT takes reasonable steps to use technology and processes appropriate for confidential telehealth services.

11. Website information, cookies and Google services

When someone visits the AnnOT website, technical information may be collected automatically by the website or third-party services, such as browser and device information, IP address, pages visited, date and time of access and general usage information.

The AnnOT website uses Google web technologies, including a Google tag, and may use cookies or similar technologies for website measurement, advertising measurement, security and service improvement. Google and other service providers may process information in accordance with their own privacy terms.

You may be able to control or delete cookies using your browser settings. Blocking some technologies may affect website functionality or measurement.

12. Anonymous or pseudonymous enquiries

You may make a general enquiry without providing unnecessary clinical information. However, AnnOT may need to know a person's identity and relevant health information before it can assess a referral, provide Occupational Therapy services, prepare reports, manage funding or meet legal and professional obligations.

13. Direct marketing

AnnOT will not use health information for direct marketing except where permitted by law and any required consent has been obtained. Where AnnOT sends promotional communications, recipients may request that those communications stop. Clinical and service-related communications are not marketing communications.

14. Access to your information

You may request access to personal or health information AnnOT holds about you. AnnOT may require reasonable identity verification before information is released and will respond in accordance with applicable privacy and health-records laws.

In some circumstances, access may be limited or refused where permitted or required by law. If this occurs, AnnOT will explain the reason where legally permitted.

15. Correction of information

AnnOT aims to keep personal and health information accurate, complete and up to date. If you believe information we hold about you is inaccurate, incomplete, out of date, irrelevant or misleading, please contact us. We will consider the request and take reasonable steps to correct information where appropriate.

16. Retention and disposal

AnnOT retains clinical, health and business records for the periods required by applicable professional, legal, insurance and regulatory obligations. When information is no longer required to be retained, AnnOT will take reasonable steps to securely destroy or de-identify it where appropriate and permitted by law.

17. Privacy incidents and data breaches

If AnnOT becomes aware of a suspected privacy or data-security incident, we will assess and respond to the incident in accordance with applicable legal obligations, including the Notifiable Data Breaches scheme where it applies.

18. Privacy complaints

If you have a concern or complaint about how AnnOT has handled your personal or health information, please contact us first so we can investigate and respond.

If you are not satisfied with our response, you may have the right to contact the Office of the Australian Information Commissioner (OAIC) or, for Victorian health-information matters, the Health Complaints Commissioner Victoria.

19. Changes to this policy

AnnOT may update this Privacy Policy from time to time to reflect changes to services, technology, information-handling practices or legal obligations. The current version will be published on this website with the date it was last updated.

20. Contact AnnOT