Privacy Policy – Equana Minds

Equana Pty Ltd (ACN 690 073 057) (‘we’, ‘us’, ‘our’, ‘Equana minds’) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we collect, hold, use, protect and manage your Personal Information. You agree that using the Website or clicking ‘I Accept’ when signing up for a user account on the Website implies your consent to the collection and use of your personal information in accordance with this Privacy Policy.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

The objective of this document is to provide you, our client, with clear information on how your personal information is collected and used within the practice. Occasionally we also need to share your personal information to involve others in your healthcare and this policy outlines when, how, and why we share your information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

When and why is your consent necessary

When you register as a client of this practice, you provide consent for therapist you book and practice staff to access and use your personal information to facilitate the delivery of therapy. Access to your personal information is restricted to practice team members who require it for your care. If we ever use your personal information for purposes other than outlined in this document, we will obtain additional consent from you.

It is important to us that as our patient, you understand why we collect and use your personal information. By acknowledging this Privacy Policy you consent to us collecting, holding, using, retaining and disclosing your personal information in the manners described below.

What is Personal Information and why do we collect it

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes but is not limited to:

names, date of birth, addresses, contact details, emergency contact,
medical information including medical history, medicines, allergies, and adverse reactions immunisations, social history, family history and risk factors
Medicare number (where available) for identification and claiming purposes
healthcare identifier numbers
health fund details
information relating to method of payment and your consultation dates and times
We may collect log data associated with how you use our Website. This can include details such as your IP address, the type and version of your browser, pages or features you view or interact with, your navigation path, actions taken during your visit, timestamps for each session, time spent on each page, the number and length of consultations, information about how your video connection performs, and other technical usage data.

The practice collects, uses, stores, and shares your personal information primarily to manage your health safely and effectively. This includes providing healthcare services, managing medical records, and ensuring accurate billing and payments. Additionally, we may utilise your information for internal quality and safety improvement processes such as practice audits, accreditation purposes, and staff training to maintain high-quality service standards.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

We collect your Personal Information for the primary purpose of providing our services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

If we collect your sensitive information, we will do so only with your consent, if it is necessary to prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law, and we take appropriate measures to protect the security of this information.

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you. You can deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.

How do we collect your personal information

Equana Minds collects your personal information in different ways. When you make your first appointment, you will fill out the Patient Intake Form. Alternatively, the practice team will collect your personal and demographic information via your registration. We may also collect your personal information when you create an account on our portal, attend a therapy session, visit our website, send us an email or SMS, telephone us, make an online appointment, or communicate with us using social media.

In some circumstances, personal information may also be collected from other sources, including:

Your guardian or responsible person.
Other involved healthcare providers, such as specialists, allied health professionals, hospitals, community health services, and pathology and diagnostic imaging services.
Your health fund, Medicare, or the Department of Veterans’ Affairs (if relevant).
While providing medical services, further personal information may be collected via:
- electronic prescribing
- My Health Record
- online appointments.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law.

What information are retained by Therapists

All therapists who provide services through our platform operate as independent contractors, not as employees of our organisation. Each therapist holds registration with recognised professional associations that outline strict standards for record-keeping, confidentiality, and the delivery of therapy services.

During your therapy sessions, your practitioner may collect additional information relevant to your care. It is common for therapists to write notes during or after a session to help support ongoing treatment. Therapists record notes in the practice management system Zanda, and they are individually responsible for safeguarding these records in line with the confidentiality rules of their professional bodies and in compliance with Australian privacy legislation.

We collect personal information only when it is necessary for the operation, enhancement, and delivery of our services. Given the therapeutic nature of our platform, this can include sensitive information such as details about your health and wellbeing.

We may gather information in various ways, including but not limited to:

Through your interactions with our website
When you use our services
As part of setting up an online account
Directly from clients and users
Through administrative and support services we provide
Via optional surveys or feedback opportunities
Through competitions, events, or marketing activities
During recruitment processes or in the course of employment
Through communication with us by phone, email, video call, post, or other channels

Wherever possible and appropriate, we aim to collect your personal information directly from you.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

Third parties where you consent to the use or disclosure; and
Where required or authorised by law.
our third party service providers (for example, our IT providers);
our marketing providers;
our professional services advisors;

We sometimes share your personal information:

with third parties for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with APPs and this policy
with other healthcare providers (e.g. In referral letters)
when it is required or authorised by law (e.g. court subpoenas)
when it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent
to assist in locating a missing person
to establish, exercise or defend an equitable claim
for the purpose of confidential dispute resolution process
When it is a statutory requirement to share certain personal information (e.g. some diseases require mandatory notification)
When it is provision of medical services, through electronic prescribing, My Health Record (e.g. via Shared Health Summary, Event Summary).
Only people who need to access your personal information will be able to do so. Other than providing medical services or as otherwise described in this policy, the practice will not share personal information with any third party without your consent.
We may share your personal information with someone outside Australia if you choose to attend a session with a therapist that is based overseas. The information will still be stored in Australia.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized 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. We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.

Equana will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:

Ensuring our third party providers that we use to store your personal information have a robust physical security of their premises and databases / records;
taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;
having technological measures in place (for example, anti-virus software, fire walls);

We take reasonable steps to safeguard the personal information we handle from misuse, interference, loss, and unauthorised access, alteration, or disclosure.

While we implement security protections, no data transmitted online can ever be guaranteed to be completely secure. Our Website and related services use technical and organisational measures aimed at preventing unauthorised access or misuse of the information we hold.

Despite these efforts, we cannot promise that information you submit to us will always remain secure during transmission or storage. By using our services, you acknowledge that you provide personal information at your own risk. If you suspect any unauthorised access or compromise of your information in connection with our Website, please contact us as soon as possible.

Disclosures cross-border

We may share personal information with third-party technology providers who support our systems and data hosting. Some of these organisations are located outside Australia, including in regions such as the United States and Europe.

Other than these arrangements, we will only transfer your personal information overseas when:

you have given your consent; or
we are legally required or permitted to do so under Australian law, applicable international laws, or by order of a court or tribunal.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Equana will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Online Activity

Cookies

Our website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website. This improves your experience and the Equana Minds website(s).

We do not use cookies to identify you, just to improve your experience on our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

Website analytics

Our website uses Google Analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.

Direct marketing

We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe” set out in the relevant communication / contacting us using the details set out in the “How to contact us” section below.

In addition, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising, including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites).

The practice will not use your personal information for marketing any goods or services directly to you without your express consent. If you do consent, you may opt out of direct marketing at any time by notifying the practice in writing.

How is your information used to improve services?

The practice may use your personal information to improve the quality of the services offered to patients through research, analysis of patient data for quality improvement and for training activities with the practice team.

We may provide de-identified data to other organisations to improve population health outcomes. If we provide this information to other organisations patients cannot be identified from the information we share, the information is secure and is stored within Australia. You can let reception staff know if you do not want your de-identified information included.

At times, our practice may be approached by research teams to recruit eligible patients into specific studies which require access to identifiable information. You may be approached by a member of our practice team to participate in research. Researchers will not approach you directly without your express consent having been provided to the practice. If you provide consent, you would then receive specific information on the research project and how your personal health information will be used, at which point you can decide to participate or not participate in the research project.

How are Artificial intelligence (AI) Scribes used?

The practice uses an AI scribe tool to support therapists take notes during their consultations with you. The AI scribe uses an audio recording of your consultation to generate a clinical note for your health record. The practice AI scribe service is BizzyAI.

Zanda’s BizzyAI:

does not share information outside of Australia for Australian practices
does not store the audio file once the transcription is complete.
retains sensitive, personal identifying information as part of the transcription

The practice will only use data from our digital scribe service to provide healthcare to you.

Links to Third Party Sites

Equana Minds website(s) may contain links to websites operated by third parties. If you access a third party website through our website(s), personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

Inquiries and Complaints

For complaints about how Equana Minds handles, processes or manages your personal information, please contact us at enquiries@equanaminds.com.au. Note we may require proof of your identity and full details of your request before we can process your complaint.

Please allow up to 21 days for Equana Minds to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with Equana Minds’ response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au) to lodge a complaint.

Inquiries and Complaints

Please allow up to 21 days for Equana Minds to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with Equana

Minds’ response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au) to lodge a complaint.

Mandatory Data Breach Notifications

Pursuant to the Privacy Act 1988, we are required to notify you and the Australian Information Commissioner if we suspect that a data breach (relating to your personal and/or health information) has occurred and there is a real risk of serious harm to you as a result of the breach.

How to Contact Us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows:

Email
enquiries@equanaminds.com.au

Contact number
0485 506 955

Policy Updates

This Policy may change from time to time and is available on our website. Any changes will be posted on our Website. By continuing to use the Website after an update is published, you are taken to have accepted the revised Privacy Policy.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

Equana Pty Ltd
Unit A1/35 – 39 Bourke Rd, Alexandria NSW 2015
enquiries@equanaminds.com.au