How Amy Simpson collects, uses, and protects your information. 1. About this Privacy Policy This Privacy Policy explains how Amy Simpson Naturopath collects, holds, uses, discloses and protects personal information, including health information, and the circumstances in which information may be shared with others. This policy applies to information collected through Amy Simpson’s naturopathic practice, including in-person and telehealth consultations, as well as through the website, online bookings and forms, email, SMS, social media, educational resources and other digital services. Amy Simpson handles personal and health information in accordance with applicable Australian privacy legislation, including the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs), and the Health Records Act 2001 (Vic) and Health Privacy Principles (VIC). Amy Simpson also practises in accordance with applicable professional standards, including the Code of Conduct for Australian Naturopaths and Western Herbal Medicine Practitioners. 2. Why does Amy Simpson collect and use personal information? Amy Simpson collects personal and health information where reasonably necessary to provide safe, appropriate and individualised naturopathic healthcare and to operate the practice. When a person becomes a patient of the practice, they provide consent for Amy Simpson to collect, access and use personal and health information reasonably necessary to provide their naturopathic care. Where consent is required for another use or disclosure, consent will be sought as appropriate. Information may be collected, used and held for purposes including: •assessing and managing naturopathic care needs •providing naturopathic healthcare, treatment plans and recommendations •maintaining clinical records •arranging naturopathic prescriptions, nutritional supplements and herbal medicines •arranging pathology, functional testing or other investigations •communicating and collaborating with other care providers •managing appointments and providing clinical and administrative communications •processing payments, deposits, invoices and refunds •practice administration, accounting and related business activities •responding to enquiries, feedback and complaints •quality assurance and improvement of practice services •providing educational or marketing communications where consent has been provided •administering resources, downloads, competitions, quizzes and other services in which a person chooses to participate. Where appropriate, information used for quality assurance or practice improvement may be aggregated or de-identified. For example, discussing a case with qualified mentors for training purposes. A person may withdraw consent for an optional use or disclosure of their information. This may affect Amy Simpson’s ability to provide some services. Information may also be used or disclosed without consent where required or authorised by law or otherwise permitted under applicable privacy legislation. If information reasonably necessary for naturopathic care is not provided, Amy Simpson may be unable to provide some or all naturopathic services. 3. What personal information does Amy Simpson collect? Depending on the circumstances, Amy Simpson may collect information including: •name, date of birth, address and contact details •emergency contact details •occupation and relevant demographic information •payment and transaction information •pronouns, gender, sex assigned at birth and information about anatomy where relevant to naturopathic care •presenting concerns and health goals •medical and family history •current and previous medications, supplements and treatments •allergies, adverse reactions and immunisation history •dietary, lifestyle, sleep, exercise and other relevant health information •reproductive, menstrual, pregnancy and postpartum information where relevant •pathology results, diagnostic reports and other investigations •information supplied by other healthcare professionals •consultation notes, clinical observations, treatment plans and prescriptions •appointment and service information •communications with the practice •information voluntarily provided through the website, forms, mailing lists, competitions, quizzes, downloads or social media •information about naturopathic care topics or services a person has chosen to receive information about. 4. How is personal information collected? Where practicable, Amy Simpson collects personal information directly from the person to whom it relates. Information may be collected when a person: •makes an appointment •completes an intake, consent or other clinical form •attends an in-person or telehealth consultation •communicates by telephone, email or SMS •uses the website or submits an online form •subscribes to a mailing list •downloads or purchases a resource •participates in a competition, quiz or promotion •interacts with Amy Simpson Naturopath through social media. •Where it is not practical or reasonable to collect information directly, relevant information may also be received from a parent, guardian, carer or authorised representative; another healthcare provider; hospital or health service; pathology, diagnostic imaging, laboratory or functional testing provider; or another authorised source. Children and young people: Where naturopathic care is provided to a child or young person, information may be collected from their parent, guardian or authorised representative and, where appropriate, directly from the child or young person. Consent, confidentiality and access to information will be managed according to the child’s or young person’s age, circumstances and decision-making capacity, together with applicable legal and professional requirements. Anonymity and pseudonyms: A person may deal with Amy Simpson anonymously or using a pseudonym where this is lawful and practicable. However, providing naturopathic health care may require accurate identification, clinical history, pathology information, prescriptions, referrals, payments and ongoing naturopathic health care records. In these circumstances, it may not be practicable to provide the relevant service anonymously. 5. When and with whom may information be shared? Where reasonably necessary for naturopathic health care or operation of the practice, relevant information may be disclosed to: •medical practitioners, specialists or other healthcare providers involved in a person’s care •pathology, diagnostic imaging, laboratory or functional testing providers •professional dispensaries and suppliers used to fulfil prescriptions •clinical practice-management and health-record providers •payment processors, accounting or administrative service providers •website, email, information technology and communications providers •professional advisers where reasonably necessary •insurers, employers or compensation bodies where relevant, authorised and lawful. Where practicable and required, Amy Simpson will obtain consent before sharing health information with another healthcare provider or service. Only information reasonably necessary for the relevant purpose will be disclosed. With consent or where otherwise appropriately authorised, relevant information may be provided to professional dispensaries, laboratories, or other clinical services for purposes such as fulfilling prescriptions, arranging testing, receiving results and coordinating naturopathic health care. Information may also be disclosed without consent where required or authorised by law or otherwise permitted under applicable privacy legislation. 6. Third-party services and overseas processing Amy Simpson uses third-party technology and services to operate the practice. These may include: •Simple Clinic for clinical practice management and health records •Vital.ly, Ariya, and other professional dispensaries where appropriate •Wix for website hosting, online forms and website functionality •MailerLite for email communications and mailing lists •Square and AfterPay payment processing and accounting services •Zoom telehealth and appointment-management services •Instagram and Meta for social media •ManyChat for messaging and marketing automation through Instagram •website analytics and advertising technologies where enabled. These providers may process information on behalf of Amy Simpson and have their own privacy, security and data-processing arrangements. Some third-party technology and service providers may store or process information outside Australia or use infrastructure located in other jurisdictions. These may include cloud-based business, practice-management, website, email and communications services. 7. Website, cookies, email and social media When a person uses the Amy Simpson Naturopath website, Wix or other technologies enabled on the website may automatically collect information such as IP address, browser, and device information, pages viewed, website interactions, referring source, cookie identifiers and website analytics information. The website may use cookies and similar technologies to provide website functionality, remember preferences, understand how the website is used, measure performance and, where enabled, support analytics, advertising or retargeting. Cookies can generally be managed or disabled through browser settings, although disabling some cookies may affect website functionality. Amy Simpson does not use social media to provide individualised health advice or discuss personal health information and will direct personal or clinical enquiries to an appropriate private communication channel. Email and direct marketing: A person may choose to receive newsletters, educational information, resources, clinic updates, offers or other marketing communications. Amy Simpson will not use personal or health information for direct marketing without an appropriate basis or consent where required. Information about selected interests and engagement with communications may be used to provide more relevant content. A person may unsubscribe from marketing communications at any time using the unsubscribe function provided or by contacting Amy Simpson Naturopath. Opting out of marketing does not prevent Amy Simpson from sending communications reasonably necessary to provide requested naturopathic healthcare or services, including appointment information, invoices, treatment information or other clinical and administrative communications. Competitions, resources and social media: Where a person participates in a competition, giveaway, quiz, download or other online activity, Amy Simpson may collect information voluntarily provided for the purposes explained when it is collected. Where tools such as ManyChat are used to facilitate social media messaging or collect information, relevant information may also be processed through that service. Amy Simpson Naturopath will not ask for personal information or discuss personal healthcare on social media. Third-party social media platforms may independently collect and process information in accordance with their own privacy practices. 8. How is information stored and protected? Personal and health information may be stored electronically. Clinical information is primarily stored using secure clinical practice-management and related information systems. Amy Simpson takes reasonable steps to protect information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include password-protected systems and devices, multi-factor authentication, appropriate access controls, secure clinical information systems, appropriate handling of physical and electronic records, and use of reputable third-party service providers. Amy Simpson consults from Bloom Natural Health Co. Where shared clinic facilities or equipment are used, reasonable steps are taken to maintain the privacy and confidentiality of information. Amy Simpson’s clinical records remain subject to Amy Simpson’s own privacy, professional and health-record obligations. If a privacy or data-security incident occurs, Amy Simpson will take reasonable steps to contain, investigate and respond to the incident and will make notifications where required by applicable law. 9. How long are health records kept? Amy Simpson retains health records in accordance with applicable Victorian legislation and professional record-keeping requirements. Naturopathic health records for adults will generally be retained for at least seven years after the last occasion on which a service was provided. Where the person was under 18 years of age when the naturopathic health information was collected, the information will generally be retained until that person reaches 25 years of age, subject to any applicable requirement to retain the information for longer. Information that is no longer required to be retained will be securely destroyed or de-identified where required and appropriate. 10. Accessing, correcting and transferring health information Amy Simpson takes reasonable steps to ensure personal and naturopathic health information is accurate, complete, current and relevant for its intended purpose. A person may request access to personal or naturopathic health information held about them and may request correction of information that is inaccurate, incomplete or out of date. Requests should be made in writing to: hello@amy-simpson.com Requests will be handled within a reasonable period and in accordance with applicable privacy and health-record legislation. Any fees associated with providing access will comply with applicable Victorian requirements. Where access is refused or restricted in circumstances permitted by law, the reason will be explained where required. A person may also request that relevant health information be made available to another healthcare provider. Such requests will be managed in accordance with applicable privacy, consent and record-keeping requirements. 11. Privacy enquiries and complaints Amy Simpson Naturopath takes privacy complaints and concerns seriously. A person who has a concern about how their personal or health information has been collected, used, stored or disclosed should contact: •Amy Simpson Naturopath •Email: hello@amy-simpson.com •Website: www.amy-simpson.com •Telephone: 0493 384 569 •Postal address: 151 Queen Street, Bendigo VIC 3550 Amy Simpson will acknowledge privacy complaints as soon as reasonably practicable, investigate the matter and work with the person to resolve the concern where possible. If a privacy concern cannot be resolved directly, a person may contact the Office of the Australian Information Commissioner (OAIC) or, for matters relating to health information in Victoria, the Health Complaints Commissioner Victoria.