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Privacy Policy

Introduction

This website, https://smithandconaturopathic.com/ is owned and operated by Smith & Co Naturopathic Medicine ABN:14071180765. If you have any questions or need further information, please contact:

Samantha Smith

9 Rosslyn Street

West Leederville WA 6007

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Phone: 0412 760 329

Email: sam@smithandconaturoapthic.com

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This document sets out my Privacy Policy. It describes how I collect and manage your personal information when you interact with this site. Smith & Co Naturopathic Medicine takes this responsibility very seriously. If you have any questions or concerns about how your personal information is being handled, please do not hesitate to contact me.

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I comply with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

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Personal Information – what, when, why, how

If you engage with me via this website, or choose to become my client, I may ask to collect the following kinds of personal information from you, including:

• Your name and email address

• Your opinion about future topics, products or services that may interest you

• Information that allows me to tailor my content to your needs

• Your IP address, and information about your browsing history to help me improve the usability and appeal of my website

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I may collect your personal information via various means including:

• Through my website contact form

• When you email or call me

• In a zoom, phone or face to face consultation

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I may use this information to:

• Respond to your enquiries

• Provide you with relevant news and updates about my services

• Improve this website and the services I provide

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I will only collect your personal information:

• With your full awareness and consent, such as when you email or call me or fill in a form to provide me with information

• If I need it to provide you with information or services that you request

• If I am legally required to collect it

• For necessary administrative processes if you become my client

• If I believe that I can demonstrate a legitimate interest in using your data for marketing purposes, although I will always give you a choice to opt out

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Sensitive Information

I understand that personal information, particularly in relation to health, is especially sensitive, and that you are trusting me to keep this information confidential.

I will only collect sensitive information by methods that are reasonably secure, such as:

• Through an emailed intake form which is then uploaded to Halaxy when you book an appointment

• In a zoom consultation, via telephone or face to face

• When you send me information in an email

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This information is collected:

• To establish an accurate, clear and comprehensive record of each consultation; advice on treatment options; account keeping and billing purposes; referral to a medical or other health professional

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The sensitive information I ask you to provide for this purpose may include:

• Name, address, date of birth, contact details and occupation

• Presenting complaint including duration

• Past and family history

• Relevant lifestyle history, dietary information

• Details of previous treatments and current medications and findings and/or copies of pathology tests or other investigations

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I am committed to securely storing and handling your sensitive information.

Only I or an authorised team member may access sensitive material.

Sensitive information is stored in a locked filing cabinet and on a password protected computer.

You are entitled to access your own health records at a time convenient to both yourself and the practice. To initiate this process, please email Samantha Smith: sam@smithandconaturopathic.com

Some sensitive information may be stored securely online, or in the cloud through Halaxy. You can find out more about their security provisions here: https://www.halaxy.com/article/privacy

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Sensitive information may be collected from children under the age of 18 under the following circumstances:

• In the presence of their parents

• With their parent or guardian’s full consent

All information collected from minors is securely stored in accordance with this privacy policy.

All archived sensitive information is securely destroyed after 7 years.

You may choose not to provide me with your sensitive information. However, if you choose not to be completely honest with me, I may not be able to provide you with the services that you request.

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Disclosure of Information

Reasons why I may disclose your information include:

• To provide you with the services you have requested

• To send you products that you have purchased

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In order to do this, I may share some relevant information – on a strictly need to know basis – with:

• Accounting, bookkeeping, legal services

• Australia Post or courier companies

• Legal  Disclosure

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I will also disclose your information if required by law to do so or in circumstances permitted by the Privacy Act – for example, where I have reasonable grounds to suspect that unlawful activity, or misconduct of a serious nature, that relates to my functions or activities has been, is being or may be engaged in, and in response to a subpoena, discovery request or a court order.

If you have any concerns regarding the disclosure of your information in this context, please do not hesitate to get in touch with me to discuss this personally.

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Disclosure Overseas

I will use all reasonable means to protect the confidentiality of your information while in my possession or control. I will not knowingly share any of your information with any third party, other than the service providers who assist me in providing the information and/or services I am providing to you. To the extent that I do share your information with a service provider, I would only do so if that party has agreed to comply with our privacy standards or I am satisfied that the service provider has a suitably protective policy of their own. Some of my service providers may be overseas and may not be subject to Australian Privacy Laws or compliant with GDPR. Please contact me if you have any concerns about the potential disclosure of your information. Please also see the section on Security below.

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Security

The protection of  your personal information from misuse and loss and from unauthorised access, modification or disclosure is of utmost importance to our therapeutic relationship.

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I manage risks to your information by:

• Storing files securely

• Ensuring that only I or key personnel have access to sensitive information

• Releasing information to service providers on a strictly need-to-know basis

• Conducting regular audits of my security systems

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As mentioned above, your information may also be stored with a third-party provider, where it will be managed under their security policy:

• Halaxy – https://support.halaxy.com/hc/en-au/articles/360044013354-Data-Security-in-Halaxy

• Reckon One – https://www.reckon.com/au/policies/data-security/

• Zoom – https://zoom.us/docs/en-us/privacy-and-security.html

• Square – https://squareup.com/au/en/legal/general/privacy-no-account

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Cookies and Google Analytics

Cookies are small text files that are commonly used by websites to improve a user’s experience, collect statistics or marketing information and provide access to secure areas.

You can choose to configure your browser settings not to accept cookies but this may interfere with the functioning of this website. The cookies used on this website are solely related to Google analytics and are used to calculate visitor numbers, their source and the pages visited in an anonymous form. You can find out more about the information Google collects and how it is used here:

https://support.google.com/analytics/answer/6004245

Google also provides an add-on for your browser that you can use to opt-out and prevent your data being used by Google Analytics. You can access that add-on here: https://tools.google.com/dlpage/gaoptout

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Access to Information

You can contact me to access, correct or update your personal information at any time. Unless I am subject to a confidentiality obligation or some other restriction on giving access to the information which permits me to refuse you access under the Privacy Act, and I believe there is a valid reason for doing so, I will endeavour to make your information available to you within 30 days.

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Complaints

If a breach of this Privacy Policy occurs, or if you wish to a request a change to your personal information, you may contact me by sending an email outlining your concerns to me at: sam@smithandconaturopathic.com

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If you are not satisfied with my response to your complaint, you may seek a review by contacting:

• The Office of the Australian Information Commissioner using the information available at http://www.oaic.gov.au/privacy/privacy-complaints.

• The Health and Health and Disability Services Complaints Office (HaDSCO) – https://www.hadsco.wa.gov.au/complaints/health.cfm

• Notification of Change

• If I decide to change my Privacy Policy, I will post a copy of the revised policy on my website.

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Notification of Breach

If I have reason to suspect that a serious data breach has occurred and that this may result in harm or loss to you, I will immediately assess the situation and take appropriate remedial action. If I still believe that you are at risk, I will notify the Office of the Information Commissioner and either notify you directly, or if that is not possible, publicise a notification of the breach on this website.

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I acknowledge the Wadjuk Noongar people, traditional custodians of the unceded land on which I practice from and express my gratitude to their elders past and present and emerging for their continued stewardship.

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