1. INTRODUCTION

This privacy policy provides you with details of how I collect and process your personal data through your use of my site susandalby.com

By providing me with your data, you warrant to me that you are over 13 years of age.

Susan Dalby is the data controller and I am responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

Contact Details

Our full details are:

Full name of legal entity: Susan Dalby

Email address: susan.dalby@iinet.net.au

Postal address: It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at susan.dalby@iinet.net.au

2. WHAT DATA DO I COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND I PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

I may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to me whether that be through the contact form on my website, through email, text, social media messaging, social media posting or any other communication that you send me. I process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. My lawful ground for this processing is my legitimate interests which in this case are to reply to communications sent to me, to keep records and to establish, pursue or defend legal claims.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. I process this data to supply the goods and/or services you have purchased and to keep records of such transactions. My lawful ground for this processing is the performance of a contract between you and me and/or taking steps at your request to enter into such a contract.
  • User Data that includes data about how you use my website and any online services together with any data that you post for publication on my website or through other online services. I process this data to operate my website and ensure relevant content is provided to you, to ensure the security of my website, to maintain back- ups of my website and/or databases and to enable publication and administration of my website, other online services and business. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business.
  • Technical Data that includes data about your use of my website and online services such as your IP address, your login data, details about your browser, length of visit to pages on my website, page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website. The source of this data is from my analytics tracking system. I process this data to analyse your use of my website and other online services, to administer and protect my business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of my advertising. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business and to grow my business and to decide my marketing strategy.
  • Marketing Data that includes data about your preferences in receiving marketing from me and my third parties and your communication preferences. I process this data to enable you to partake in my promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. My lawful ground for this processing is my legitimate interests which in this case are to study how customers use my products/services, to develop them, to grow my business and to decide my marketing strategy.
  • I may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising I serve you. My lawful ground for this processing is legitimate interests which is to grow my business. I may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). [NOTE SEE SECTION 4 BELOW]

Sensitive Data

Psychological service

I collect information for assessment, diagnosis and treatment of your condition. You choose what you are willing to share and when to share it, however, your total honesty will enable me to have the most complete understanding of your situation. 

Collecting and storing information

Both a paper file and a summary computer record on a secure system for each appointment is kept. I am the only person with access to your files. Your information is securely archived for a period of seven (7) years from the date of your last appointment.  

Access to client information

If you want me to share your information with someone else (such as a family member, workplace or other health provider) I will ask you to sign a Release of Information approval. You can indicate limits around what is shared.

Confidentiality

All information recorded in your file remains confidential and secure except when:

  1. It is subpoenaed by a court or disclosure is otherwise required or authorised by law.
  2. You or another person is at serious and imminent risk.
  3. A child is at risk of serious harm – I am mandated to report this.

I may discuss your case with a senior colleague for supervision purposes.  In this situation, your anonymity is preserved.

Release of information to your referrer.

If you have been referred by an agency that is fully or partially funding your appointments including Medicare rebated GP referrals, you give permission for information to be exchanged with the referrer.

3. HOW WE COLLECT YOUR PERSONAL DATA

I may collect data about you by you providing the data directly to me (for example by filling in forms on my site or by sending me emails).

I may receive data from third parties such as analytics providers such as Google Analytics, advertising networks such as Facebook, search information providers such as Google , providers of technical, payment and delivery services, such as data brokers or aggregators.

I may also receive data from publicly availably sources.

4. MARKETING COMMUNICATIONS  

My lawful ground of processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business). 

Before I share your personal data with any third party for their own marketing purposes I will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing me at susan.dalby@iinet.net.au any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

I may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require me to report processing activities.
  • Third parties to whom I sell, transfer, or merge parts of my business or my assets.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

6. INTERNATIONAL TRANSFERS

Some of my service providers are overseas and may not be subject to Australian Privacy Laws.  Sensitive information is not shared with these providers. 

7. DATA SECURITY

I have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. I also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on my instructions and they must keep it confidential.

8. DATA RETENTION

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for seven years after they stop being customers.

In some circumstances I may anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email me at susan.dalby@iinet.net.au

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy policy of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

12. CHANGES

As I plan to ensure my privacy policy remains current, this policy is subject to change. I may modify this policy at any time, in my sole discretion and all modifications will be effective immediately upon our posting of the modifications on this website. Please return periodically to review my privacy policy.

If you have any questions or concerns at any time about or privacy policy or the use of your personal information, please contact us at susan.dalby@iinet.net.au and we will respond within 48 hours.

July 2018