Privacy Policy

As of: 20th Feb 2026

Calming The Circle Therapy

Practitioner: Amy Primrose

Services: Counselling, couples counselling, child and adolescent counselling, and telehealth

services

1. Purpose of this policy

Calming The Circle Therapy is committed to protecting the privacy, confidentiality, and

security of personal information collected while providing counselling and related services.

This policy explains how personal information is collected, used, disclosed, stored, and

accessed in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy

Principles (APPs). APP entities must have a clearly expressed and up-to-date privacy policy

and make it available free of charge.

2. What information we collect

We may collect the following types of information:

Full name, date of birth, address, contact details, and emergency contact details
Health information, including mental health history, presenting concerns,

treatment notes, risk information, and relevant family or relationship details

Information provided by referral sources, treating practitioners, or other support

providers

Billing and payment information

Telehealth-related technical information necessary to provide the service

Health and sensitive information may be collected where it is reasonably necessary to provide

counselling services and with consent, unless an exception applies.

3. How we collect information

We collect information directly from you where practical, including through:

Intake forms
Consent forms
Session discussions
Phone, email, text, and telehealth communication
Referrals from other health professionals or support services

We may also receive information from:

General practitioners
Psychiatrists or psychologists
Allied health professionals
Schools
Family violence, legal, or child protection services where relevant and lawful

4. Why we collect, use, and disclose information

We collect, use, and disclose personal information to:

Provide counselling and related therapeutic services
Assess suitability for counselling, including couples counselling, individual therapy,

child therapy, and telehealth

Maintain accurate clinical records
Manage appointments, billing, reminders, and cancellations
Communicate with you about your care
Coordinate care with other providers where appropriate and consented
Respond to legal, ethical, and safety obligations
Support risk assessment, safety planning, and referrals when required

5. Disclosure of information
We may disclose information:

To other health professionals involved in your care, with your consent where

required

Where there is a serious risk of harm to you or another person
Where there is suspected or disclosed child abuse or neglect
Where required by law, subpoena, court order, or other legal obligation

• Where necessary to respond to a serious threat to public health or safety

• Where current domestic violence, abuse, coercive control, or safety concerns

require action to protect wellbeing

This is consistent with the confidentiality limits already described in your consent materials.

6. Couples counselling confidentiality

Couples counselling is provided on the understanding that the therapeutic process focuses

on the relationship. There is no guarantee of relationship success or any specific outcome.

For couples counselling:

Individual sessions will not proceed unless both partners give explicit consent
If couples counselling ends and one person wishes to continue individually, that

transition must be mutually agreed

Once the transition to individual therapy occurs, information shared in later

individual sessions is treated under individual therapy confidentiality rules

Couples counselling may be discontinued if there is current abuse, domestic

violence, coercive control, or safety risk

7. Children and adolescents under 16

Calming The Circle Therapy recognises that children and adolescents have a right to privacy in

therapy, while parents or guardians may also have rights and responsibilities in relation to

care and welfare.

For clients under 16:

Confidentiality is respected as far as legally and clinically appropriate
Information may be shared with parents or guardians where necessary for safety,

risk management, or significant treatment issues

Confidentiality may be limited if there is risk of harm, abuse, neglect, or a legal

requirement to disclose

The therapist will use professional judgment to balance the child’s privacy with the

child’s best interests and family involvement

Capacity to consent may depend on the child’s maturity and understanding, and parental

consent may be required depending on age, legal requirements, and clinical circumstances.

8. Telehealth privacy

Telehealth sessions may be conducted using Cliniko or Zoom, or another approved secure

platform.

Telehealth risks may include:

Internet or software interruptions
Technical failure
Privacy risks if the client is not in a private environment

Clients are responsible for:

Choosing a private, quiet location
Using a secure internet connection
Providing emergency contact information
Informing the therapist of any safety concerns during telehealth sessions

We take reasonable steps to protect telehealth confidentiality and security. Cliniko states

that its telehealth service is designed to support GDPR, APP, HIPAA, and PIPEDA-related

security expectations, including encrypted transmission and minimisation of PHI/PII in logs.

Clients should note that no electronic service can guarantee absolute security.

9. AI note-taking and clinical records

Calming The Circle Therapy uses approved digital tool NOVONOTE to support clinical notetaking

and documentation. These tools are used to assist the therapist in focusing on care and

communication. Clinicians at our clinic are using NovoNote, an automated tool designed to

assist clinicians with taking session notes. Below is an explanatory statement about the

technology and a consent form.

Purpose of the Automated Note Taker:

The use of an AI-enhanced note taker was adopted to enable us to focus more on

communication and your care during sessions, rather than being distracted by manual notetaking.

What We Save:

As a healthcare provider, we keep notes of our contact with you to help us serve you better.

Our AI note taker, NovoNote, helps by transcribing the session and then providing a summary

of that session. The transcript of the session will be deleted and will not make up part of your

patient file, while the summary is saved as part of your file. Audio of the session is never

saved.

Compliance and Security:

NovoNote complies with the Australian Privacy Principles and is compliant with AHPRA and

HIPAA standards. It adheres to industry encryption and security protocols. NovoNote

operates on a secure server in Australia and your data does not contribute to training AI

models. For more detailed information on the security measures and protocols of NovoNote,

please visit the security page: [NovoPsych.com.au/NovoNote Security]

(https://NovoPsych.com.au/NovoNote_Security).

Any note-taking or transcription technology:

Is used only for therapeutic and administrative purposes
Must comply with confidentiality and privacy obligations
Will not be used to share information unlawfully or without appropriate consent
Will be restricted to information necessary for treatment documentation and care

10. Storage and security of information

We take reasonable steps to protect personal information from misuse, interference, loss,

unauthorised access, modification, or disclosure. This may include:

Password-protected systems
Access restrictions
Secure record storage
Encrypted or privacy-compliant digital platforms
Confidential record-keeping procedures

Cliniko also states that its telehealth security model is designed so that PHI/PII is not

transmitted unnecessarily and logs do not contain PHI/PII.

11. Accessing and correcting your information

You may request access to the personal information we hold about you and request

corrections if the information is inaccurate, incomplete, or out of date. Requests will be

handled in accordance with the APPs and applicable legal requirements.

12. Use of pseudonyms and anonymity

Where lawful and practicable, you may choose not to identify yourself or use a pseudonym for

a particular matter, consistent with Australian privacy law.

13. Consent to sharing information

By signing the consent form, you agree that necessary information may be shared between

healthcare providers involved in your care where appropriate for continuity of treatment. If

consent is required for a particular disclosure, we will seek it before sharing information

unless an exception applies.

14. Complaints

If you have concerns about how your personal information is handled, you may contact

Calming The Circle Therapy in writing. We will respond to privacy concerns promptly and work

to resolve any issue in a fair and respectful manner.

If you are not satisfied with the outcome, you may lodge a complaint with the Office of the

Australian Information Commissioner.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in law, technology,

clinical practice, or service delivery. The most current version will apply to your care.