Privacy Policy

1. About This Policy

This Privacy Policy applies to all personal information collected, used, held, and disclosed by Fields of Hope Counselling (ABN: 98 278 017 834), operated by Delaney Chow, a Registered Counsellor (ACA Level 4, PACFA Clinical) and ACA-Accredited Supervisor (the Practice, we, us, our).

This policy applies to information collected through our website (www.fieldsofhope-counselling.com.au), our booking platform, our telehealth platform (Zoom), our clinical records system, and through direct engagement with our services — including counselling, psychotherapy, and professional supervision.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Health information is treated as sensitive information under the APPs and is afforded the highest level of protection.

By accessing our website or engaging with our services, you agree to the collection and handling of your information as described in this policy.

2. What Information We Collect

2.1 Personal Information

Personal information is any information or opinion about an identified individual or an individual who is reasonably identifiable. We collect personal information necessary to provide our services, including:

• Full name, date of birth, and contact details (address, phone number, email address)
• Emergency contact details
• GP and referrer details
• Billing and payment information
• Booking and appointment history
• Communications with the Practice (emails, phone messages, online enquiries)
• Website usage data (see Section 9)

2.2 Health and Sensitive Information

In the course of providing counselling or supervision services, we collect health information and other sensitive information, including:

• Mental health history, current presentation, and clinical notes
• Medical history and current medications where relevant to treatment
• Information about family, relationships, and personal circumstances disclosed in sessions
• Risk assessments and safety plans
• AI-generated session summaries or transcripts, where consent has been obtained
• Supervision notes and professional development records (for supervisees)

Health information is sensitive information under the Privacy Act. We only collect it where necessary for the provision of our services, and handle it with the highest standard of care.

2.3 Website and Digital Information

When you visit our website or interact with our digital platforms, we may automatically collect:

• IP address and approximate geographic location
• Browser type, device type, and operating system
• Pages visited, time spent on the site, and referring URL
• Cookie data (see Section 9)
• Online enquiry and contact form submissions

2.4 Information About Minors

Where services are provided to clients under the age of 18, we collect personal and health information from both the minor client and their parent or legal guardian. This is handled in accordance with our Working with Minors Policy and with additional care given the sensitive nature of services involving young people.

3. How We Collect Information

We collect personal information in the following ways:

• Directly from you — through intake forms, consent agreements, session notes, and communications
• From your nominated GP, referrer, or treating practitioner — with your consent
• From a parent or legal guardian — where you are under 18
• Through our online booking platform (Halaxy) — when you schedule an appointment
• Through our telehealth platform (Zoom) — when you attend sessions
• Through our website — via contact forms, enquiry submissions, or cookies
• From third parties — including courts, insurers, or other health providers, where we are legally authorised or required to receive such information

4. How We Use Your Information

We use your personal and health information for the following primary purposes:

• Providing counselling, psychotherapy, and professional supervision services
• Maintaining clinical records and ensuring continuity of care
• Communicating with you about appointments, invoices, and service-related matters
• Corresponding with your GP, referrer, or other treating practitioners — with your consent
• Preparing clinical reports, letters of support, or medico-legal documents — with your consent or as required by law
• Complying with mandatory reporting obligations under child protection legislation
• Responding to subpoenas or court orders
• Processing payments and managing billing
• Improving the quality and safety of our services through clinical supervision and audit
• Meeting our obligations under professional association membership (ACA, PACFA)

We will not use your information for any purpose inconsistent with the primary purpose of collection without your consent, except where permitted or required by law.

5. AI Tools and Automated Processing

Fields of Hope Counselling uses approved artificial intelligence (AI) tools to assist with certain clinical and administrative functions, including drafting session notes, client communications, and administrative documents. The full framework governing AI use is set out in our AI Use Policy. Key points relevant to your privacy:

• AI tools are used only with platforms approved by the Practice for data security, privacy compliance, and clinical appropriateness.
• Your identifiable health information is not entered into general-purpose, consumer-grade, or publicly available AI platforms.
• All AI-generated content relating to your care is reviewed and approved by your practitioner before it is used, filed, or sent to you.
• Where AI tools process your information, this occurs within platforms that meet Australian data residency and encryption standards, or with your explicit consent where offshore processing is required.
• AI-generated session transcripts (where consent has been obtained) are clinical records and are stored, retained, and deleted in accordance with the same obligations as all clinical records.
• You have the right to request that AI tools not be used in connection with your records or communications. Please raise this with your practitioner.

5.1 Client Prohibition on AI Recording Tools

This policy operates on a reciprocity principle: the Practice does not record or transcribe your sessions without your consent. You are held to the same standard. Unauthorised recording may constitute a breach of the Surveillance Devices Act 2007 (NSW) and equivalent legislation in other Australian states and territories.

6. Telehealth and Digital Platforms

Our services are delivered via telehealth using Zoom. In connection with this:

• Zoom processes audio and video data during sessions in accordance with its own privacy policy and data processing terms. We encourage you to review Zoom's privacy policy at zoom.us/privacy.
• Sessions are not recorded without explicit prior written consent from all parties.
• Appointment bookings are managed through Halaxy. Personal information submitted through the booking platform is handled in accordance with that platform's privacy policy as well as this policy.
• Clinical records are stored in Halaxy, which is Australian-hosted / compliant with Australian data residency requirements.
• All digital platforms are selected on the basis of data security, encryption standards, and compliance with Australian privacy requirements.

No digital platform can guarantee absolute security. We take all reasonable steps to protect your information from unauthorised access, misuse, loss, or disclosure.

7. Disclosure of Your Information

7.1 With Your Consent

We will only disclose your personal or health information to third parties with your written consent, except as described below. Third parties to whom we may disclose information with your consent include your GP or referrer, other treating practitioners, insurers, NDIS planners, employers (for reports), and legal representatives.

7.2 Mandatory Reporting

We are mandatory reporters under the Children and Young Persons (Care and Protection) Act 1998 (NSW). Where we have reasonable grounds to suspect that a child or young person is at risk of significant harm, we are legally required to report to the NSW Child Protection Helpline (132 111) regardless of confidentiality obligations.

7.3 Risk to Life

Where there is a serious and imminent risk to your life or the life of another person, we may disclose information to emergency services or other relevant parties to prevent that harm, without your consent. We will inform you of any such disclosure where it is safe and appropriate to do so.

7.4 Legal Process — Subpoenas and Court Orders

Where we receive a subpoena, court order, or other lawful legal process requiring disclosure of your records or testimony, we are required to comply. We will notify you where we are legally permitted to do so before disclosure, and may seek legal advice prior to producing any documents.

7.5 Clinical Supervision

Your practitioner engages in regular professional supervision as required by ACA and PACFA membership standards. Your case may be discussed in supervision without your name or identifying details wherever practicable. Supervisors are bound by the same confidentiality obligations as treating practitioners.

7.6 Overseas Disclosure

Some digital platforms we use may process or store data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure that overseas recipients handle your information consistently with the Australian Privacy Principles. By using our services and consenting to the use of these platforms, you acknowledge that your information may be transmitted to and stored in overseas jurisdictions. Please contact us if you have concerns about overseas disclosure.

8. Storage and Security

We take reasonable steps to protect your personal and health information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:

• Storage of clinical records in an encrypted, access-controlled clinical records system
• Password protection and multi-factor authentication on all digital systems
• Encrypted data transmission (minimum TLS 1.2) for all digital communications
• Restricted access — limited to your treating practitioner and authorised administrative staff
• AI platform data subject to the security and deletion standards set out in the AI Use Policy
• Physical records (where held) stored in locked, secure storage

9. Cookies and Website Tracking

Our website uses cookies to improve your browsing experience. We use essential cookies (required for functionality), analytics cookies (to understand site usage), and booking platform cookies (to enable online booking). You can disable cookies in your browser settings, though some website features may be affected.

We do not use retargeting pixels, custom audience tools, or advertising trackers that could link your website activity to your status as a client or potential client seeking mental health services.

10. Retention and Destruction of Records

We retain your personal and health information for as long as required by law and professional standards:

At the end of the applicable period, records are permanently deleted from both the Practice's systems and any AI platform where they were processed. Physical records are cross-cut shredded or destroyed by a certified confidential destruction service.

11. Your Rights

11.1 Access to Your Information

You have the right to request access to the personal and health information we hold about you. Requests must be made in writing to admin@fieldsofhope-counselling.com.au. We will respond within 14 days. We may decline access in limited circumstances and will provide a written explanation if we do.

11.2 Correction of Your Information

If you believe information we hold about you is inaccurate, incomplete, or out of date, you have the right to request a correction. We will respond within 14 days. Original entries are retained with a note of any amendment.

11.3 Opt-Out of AI Processing

You have the right to request that AI tools not be used in connection with your clinical records or communications. Please advise your practitioner and this will be documented and honoured where clinically and operationally practicable.

11.4 Complaints

If you believe we have breached your privacy or mishandled your personal information, please contact us first:

• Email: admin@fieldsofhope-counselling.com.au
• Phone: (02) 9159 6043

We will acknowledge your complaint within 3 business days and provide a response within 21 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner:

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

12. Children's Privacy

Where we provide services to clients under the age of 18, we collect and handle personal and health information from both the minor and their parent or legal guardian. Parental or guardian consent is required before services commence. See our Working with Minors Policy for full details, including how we balance the minor's right to privacy with parental rights and our duty of care.

13. Related Policies

This Privacy Policy should be read alongside the following policies, all available on our website or upon request:

14. Links to Other Websites

Our website may contain links to third-party websites, including crisis support services, professional associations, and booking platforms. We are not responsible for the privacy practices of external websites and encourage you to review their privacy policies before submitting any personal information.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in legislation, our services, or the platforms we use. The current version will always be available at www.fieldsofhope-counselling.com.au/privacy-legal. Material changes will be communicated to current clients in writing with reasonable notice.

16. Contact Us

For all privacy-related enquiries, access or correction requests, or complaints, please contact: