Privacy Policy

This privacy policy is to provide you with information about how your personal information is collected, stored and used in my clinic, and how it may be shared with third parties. This policy has been formulated to accordance with the Australian Privacy Principles and the Privacy Act 1988.

Person collecting information: Anita Kilby

Contact: anita.kilby@bigpond.com

or phone 0411 494 680 (or from outside Australia +61 411 494 680)

As I do not collect any personal information directly from my website, my Privacy Policy mainly relates to information collected by email, text, phone, Facebook, on paper and during consultations (face to face or via phone, Zoom or Skype).

As I do not have full control of third-party provided electronic communication services, how they store, record, transmit the information, or if they disclose any such information, I accept no responsibility for the disclosure or loss of information by third-party providers. By using electronic forms of communication with me you agree to accept the risk of disclosure or loss of information that is inherently involved.

That said, I do take the responsibility of safeguarding your personal information very seriously and take every reasonable precaution to maintain your privacy.

Security and storage of personal information

• Hard copy information is stored in a locked filing cabinet in my secure office/clinic which is located adjacent to my residence
• Electronic information is stored on password protected computers and back up devices. Up-to-date security software is maintained on all computers. Electronic equipment is stored at my office/clinic and/or my residence
• My practice management software is password protected and includes dated and locked consultation notes
• To maintain control of your information and reduce the risk of unauthorised access, I do NOT use cloud storage
• If I am transporting your hard file or my computers, eg to your home for a home visit, the vehicle will be locked whilst it is not attended, and hard files will be securely bagged (ie not visible to passers-by, loose pages not able to scatter if the bag is dropped)
• Text messages are sent via an encryption protected mobile phone, which has pattern protected screen-lock access
• Client records will be stored for a minimum of 7 years from the date of the last entry into the client’s records. For clients seen when they were under 18 years of age, records will be stored until the client is at least 25 years of age
• If I become aware of a breach of security and believe your personal information may have been compromised, I will notify you promptly.

Why I collect personal information

• To provide naturopathic health services
• To provide health education services
• To inform clients and potential clients about the services I offer. If you do not wish to receive any marketing or educational information, just let me know and I will remove you from any such list.

Information collected

The information I collect to be able to provide you with the best naturopathic health services includes:

• Personal information – name, address, phone numbers, email address, date of birth, gender
• Current symptoms, lifestyle, health history, social history, family history, occupations
• Health information including diagnoses, medications, immunisations, medical and other health test results
• Information of a sensitive nature which may impact your health such as genetic information, racial/ethnic origins, religious beliefs, sexual orientation or practices
• Your medical or other health care providers details
• Health fund details
• Information about how you heard about my services

If you’d prefer any particular information not be recorded, you must advise me so at the time you disclose that information. Once I have completed my notes after each consultation my practice management software locks the notes and I am unable to alter them.

I will not knowingly collect personal information about persons under the age of 18 without the consent of their parent/guardian. If a parent/guardian believes their child under 18 has provided me with their personal information without their consent, please contact me.

You have the right to interact with me anonymously or under a pseudonym except where it is impracticable to do so, eg accessing blood tests through a pathology provider who requires identification (not generally required for functional testing), or if your identity is required by law.

How your information is collected

• If you phone, text or email me prior to your first appointment, I will record the information you provide
• Prior to your first appointment I will send you some forms which collect your personal information and some health and lifestyle information. Those forms can either be printed out by you, completed and brought to your appointment, or completed as e-forms and emailed back to me
• From questionnaire forms provided by me or other sources
• Information you provide to me during consultations will be recorded in your records (hard copy and computer)
• Any medical results you supply will be recorded in your records unless you request otherwise
• My preferred ongoing communication method with you is via email. Any information you supply by email will be collected electronically and may be printed out for your hard copy file
• From a direct referral from another health practitioner or service who you have authorised to disclose your information to me
• If you correspond with me on a social media platform
• If it is not practical or reasonable to collect information directly from you, I may also collect information from other sources such as your guardian or responsible person, other healthcare providers including pathology and diagnostic imaging services, and other sources you may provide access to.

Disclosure of information

Whenever practicable I will obtain your consent prior to disclosing any of your personal information to any third party. Other than in the course of providing health services or as outlined below, your personal information will not be shared with any third party without your consent.

I may sometimes provide your personal information:

• To third parties who work with me to provide my health care services, provide services to deliver components of my recommended treatments, provide testing services (eg pathology service providers), providers of health programs/services I utilise, suppliers of supplements, technology providers
• To other healthcare providers including medical practitioners, allied health professionals, and complementary therapists
• To your health fund
• When it is required to be disclosed by law (eg court subpoenas) or there is a statutory requirement to share certain personal information (eg child abuse and neglect)
• When it is necessary to lessen/prevent a serious threat to a client’s or other person’s life, health and safety, or public health or safety
• For account keeping and billing purposes, including debt recovery
• To establish, exercise or defend an equitable claim
• For the purpose of confidential dispute resolution processes

Only the minimum required information will be disclosed when it is necessary to do so. Only those who need to know or need to have access to your information will be able to have access. Email lists will not be sold to any third party, ever.

De-identified case information may be disclosed for discussion with other health practitioners/services or product suppliers in order to enhance my understanding of the case, or as examples for other clients. Such discussions will occur in a manner which prevents the client’s identity from being discerned.

Your personal information will not be knowingly shared with anyone outside of Australia without your consent. If you enrol in a dementia program (PreCODE or ReCODE) provided by Apollo Health (AHNP, LLC), they are located in the United States of America and your enrolment in their program requires sharing of your personal information outside of Australia. As such, they may not be subject to Australian Privacy Principles and the Privacy Act 1988. Personal information is entered into their secure online password protected practitioner website in order to generate health reports. Your enrolment into these programs implies consent to their Terms of Service and Privacy Policy. Please refer to their website https://www.apollohealthco.com for those policy details. Please note that Apollo Health may share information that has been de-identified or aggregated without limitation.

Accessing and correcting your information

You have the right to access and correct personal information which I hold. However, once consultation notes have been finalised, they are dated and locked by the practice management software and I am unable to change them. I can make a note in the software of any corrections you advise.

If you would like to access your information, please contact me and we can arrange a convenient time to do so within 30 days of my receiving your request. Any corrections you request should be made in writing.

Notification of policy changes

This privacy policy may change from time to time. The current version of my privacy policy will be posted on my website.

Complaints relating to privacy

If you have any complaints about any privacy concerns, please advise me in writing as soon as possible. I will confirm receipt of your complaint and seek to arrange to discuss your concerns with you within 30 days of receipt of your complaint.

The Office of the Australian Information Commissioner outlines how to make a complaint.

If you are not satisfied with my response to your complaint you may wish to contact the Office of the Australian Information Commissioner to lodge a complaint, by completing their online Privacy Complaint Form or other methods as outlined on their website.