Holding Space Counselling Privacy Policy

At Holding Space Counselling, we prioritize the quality of our services and respect your right to privacy. This policy outlines our commitment to protecting your personal information and how we handle it in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We are also guided by the Code of Conduct for Certain Health Care Workers (Community Services Complaints Regulations 2019).

Personal Information We Collect and Why

"Personal Information" includes any information or opinion that identifies an individual, as well as "Health Information," which encompasses physical or mental health details or disabilities. We may collect the following types of personal information:

  • Name

  • Contact information (phone, email, address)

  • Date of birth

  • Religious affiliation (if relevant)

  • Relevant health information and psychological history

  • Goals or reasons for seeking counselling

  • Emergency contacts

We collect this information through intake forms, interviews, correspondence, phone calls, emails, our website, and Client Relationship Management systems (e.g., Splose). With your consent, we may also receive information from other parties involved in your care. We only request the information necessary to provide our services, and we will inform you of its purpose at the time of collection.

Information from Third Parties

Whenever feasible, we collect personal information directly from you. However, in certain circumstances, we may receive information from third parties, such as healthcare providers. When this occurs, we take reasonable steps to ensure that you are aware of the information we have received and the purposes for which it will be used.

Website Privacy and Cookies

Our website is hosted on an Australian-based server to meet national data storage guidelines. However, our hosting provider (Squarespace) is based in the United States. While we take steps to protect your information, please note that no online storage system is entirely secure.

Our website may use cookies—small files stored on your device—to enhance your browsing experience by remembering your preferences. You can refuse cookies through your browser settings, though this may impact some website functionality. Holding Space Counselling’s website is GDPR-compliant, and we request your consent to use cookies.

Links to External Sites

Our website may include links to third-party sites. These external sites operate independently and are not governed by our privacy policy. We encourage you to review the privacy policies of any external sites you visit.

Disclosure of Personal Information

We only disclose your personal information in the following situations:

  • To prevent or reduce serious and imminent threats to your life or health, or that of others;

  • With your consent or the consent of your authorized representative;

  • When legally required, including to comply with obligations such as mandatory reporting or court orders.

Securing and Disposing of Personal Information

We take reasonable steps to ensure your personal and health information is secure, safeguarding it from unauthorized access, misuse, and loss. Once your information is no longer needed for its original purpose, we will securely destroy or de-identify it, in accordance with APP 11.

Accessing and Updating Your Personal Information

You have the right to access and correct the personal information we hold about you, subject to certain exceptions. If you wish to access or update this information, please contact us directly. For security reasons, we may need to verify your identity before providing access.

You are entitled to:

  • Request access to your personal information;

  • Access information we hold about you; and

  • Request corrections if the information is inaccurate, incomplete, or outdated.

Access may be restricted if:

  • The request is frivolous or vexatious;

  • Granting access would infringe on the privacy of others;

  • Access may compromise the investigation of suspected unlawful activity;

  • Providing access would pose a serious threat to someone’s health or life; or

  • Denial is required or permitted by law.

We strive to process access or correction requests within 14 days. We do not charge for access requests.

Keeping Your Information Current

To provide the highest quality of service, we are committed to maintaining accurate, up-to-date information. If our records are incomplete or outdated, please notify us so we can make the necessary updates.

Cancellation & Rescheduling Policy

At Holding Space Counselling, we request that all sessions be paid in full prior to your appointment unless other arrangements have been made.

  • At Holding Space Counselling, payment is required before your appointment, unless prior arrangements have been made.

  • An invoice will be emailed to you once your booking has been confirmed.

  • You can cancel or reschedule your appointment up to 48 hours in advance.

  • Changes made between 48 and 24 hours before the session will incur a 50% late cancellation fee.

  • Cancellations within 24 hours or no-shows will be charged the full fee.

  • We understand that unforeseen circumstances can occur, and we’re open to discussing these on a case-by-case basis, so please reach out if you need to do so.

NDIS

At Holding Space Counselling, we are committed to providing quality support to NDIS participants. Our services are available to individuals who are either self-managed or plan-managed, with billing conducted in accordance with the NDIS Pricing Arrangements and Price Limits.

  • Our cancellation policy aligns with the NDIS guidelines to ensure clarity and fairness.

  • Payment is invoiced after the service is provided, either to the designated plan manager or directly to the self-managed participant.

  • Short Notice Cancellations: A cancellation is considered short notice if you provide less than seven clear days' notice before the scheduled service. In such cases, we may charge up to 100% of the agreed support price, as permitted by the NDIS.

  • No-Shows: If you do not attend a scheduled support within a reasonable time or are not present at the agreed location, it is treated as a short notice cancellation, and the same charges may apply.

Refunds

  • Please note that we do not provide refunds for sessions that have already taken place.

  • Cancellations made according to our cancellation policy will be refunded.

  • Refunds may take up to 7 working days to process.

Holding Space Counselling Privacy Policy v1. Updated October 2024