This Security Statement applies to the products, services, websites and apps offered by Practice Framework Pty Ltd ABN 91 601 954 536 and their affiliates (collectively “PracticeFramework”), which are branded as “The Psychotherapy Workshop”, “PracticeFive”, SurveyMaster and SurveyMaster360 except where otherwise noted. We refer to those products, services, websites and apps collectively as the “services” in this Statement. This Privacy Statement also forms part of the user agreements for The Psychotherapy Workshop, PracticeFive and SurveyMaster customers.
The Psychotherapy Workshop values the trust that our customers place in us by letting us act as custodians of their data. We take our responsibility to protect and secure your information seriously and strive for complete transparency around our security practices detailed below. Our Security Policy also further details the ways we handle your data.
The Psychotherapy Workshop provides open access to online courses and related services. In providing these services, we collect, use and disclose personal information. Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable.
We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate how personal information is handled.
We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation, the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
2.1 Personal Information
The type of personal information that we collect and hold about you depends on the type of dealings that you have with us. If we need to identify you or verify your identity, we may collect your name, username, password, security question and answer. If we need to communicate with you, we may collect your email, residential and postal addresses and telephone numbers. If you apply to enrol in an online learning program or otherwise access our services, we may collect details of your banking and payment details.
To help us improve our services, we may collect your responses to surveys and details about how, when and why you access our services.
2.2 Sensitive information
We only collect sensitive information where it is reasonably necessary for our business functions, and you have consented, or we are required to do so by law.
2.3 Information other than personal information (“non-personal information”)
When you visit our website, some of the information that is collected about your visit is not personal information, because it does not reveal your identity. We use this information to help us improve our services and for marketing purposes. We may aggregate this information for our own statistical purposes. Provided that it remains anonymous, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
Site visit information
We may record your server address, the date, time and duration of your visit, search terms you used, the pages you viewed, any documents you downloaded and the type of device, browser and operating system you used.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our websites.
Read more information about cookies.
3.1 Methods of collection
We will collect personal information by lawful and fair means as required by the Privacy Act. We will also collect personal information directly from you, where this is reasonable and practicable.
We collect personal information in several ways, including:
3.2 Collection notices
Where we collect personal information directly from you, we will take reasonable steps to notify you of certain matters in a collection notice. We will do this at or before the time of collection, or as soon as practicable afterwards.
Where we collect information about you on behalf of the Australian Government, the collection notice may explain how the Australian Government will use and disclose your personal information. You should note that the Australian Government may use and disclose your personal information in ways that are different from how we use and disclose your personal information.
Where we collect information about you from your authorised representative, we will take reasonable steps to make sure that you are made aware of the collection.
If you provide to us personal information about someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.
The main purposes for which we collect, hold, use and disclose personal information are:
4.2 Direct marketing
Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your personal information to send you information about the services we offer, as well as other information. We may send this information by mail, email, SMS and telephone.
You can opt out of receiving these communications at any time, in the following ways:
We may disclose your personal information to any of the organisations that we deal with in the ordinary administration of our business for the purposes set out in section 4 above, including:
In each case, we may disclose personal information to the service provider, and the service provider may, in turn, provide us with personal information collected from you.
We may de-identify and aggregate the personal information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
If you have an online account via our website, you can access and change your privacy settings by logging in to your account and following the instructions on our website. Depending on the privacy settings that you chose, some of the personal information in your user profile may be disclosed to other users.
If you post comments or otherwise communicate publicly with other users via our website, any information about yourself that you include in the communication may be stored on the website and accessed by other users. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you.
It is our policy not to disclose personal information to third parties located overseas.
We hold personal information in several ways, including in electronic databases, email contact lists, and in paper files held in secure premises. Paper files may also be archived offsite in secure facilities. We take reasonable steps to:
The steps we take to secure the personal information we hold including ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
We process payments using online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
While we strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (see section 10 below).
You can also help to protect the privacy of your personal information by maintaining the confidentiality of your account (including your password), and by ensuring that you log out of your account on our website when you have finished using it. Also, if you become aware of any security breach, please let us know as soon as possible.
You can request access to the personal information that we hold about you and request corrections by contacting us (see section 10 below).
If you have an online account via our website, you can access and change some of your personal information by logging in to your account and following the instructions on our website.
If you have a complaint about how we have handled your personal information, please contact us (see section 10 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.
We will endeavour to acknowledge receipt of your complaint within five business days of receiving it and to complete our investigation into your complaint in a timely manner.
If you are unhappy with our response, you can refer your complaint to the Office of Fair Trading or, in some instances, other regulatory bodies, such as the Australian Competition and Consumer Commission.
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for queries are set out below.
Practice Five Pty Ltd
Mail: PO Box 690, Samford, Queensland, 4520, Australia
Telephone: +61 7 3123 5577