Privacy Policy

Privacy

Good Game Counselling is committed to providing quality, person-centred services, and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. We also comply with the relevant privacy provisions of the National Disability Insurance Scheme Act 2013 (Cth) (NDIS Act) and the NDIS Code of Conduct.

A copy of the Australian Privacy Principles is available from the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au

What is Personal Information and why do we collect it?

Personal Information is information that identifies an individual. Examples of Personal Information we collect include: your name, address, email address, phone number, date of birth, and emergency contact details.

As a counselling service working primarily with NDIS participants, we also collect sensitive information including health and disability-related information, mental health history, NDIS plan details (including plan numbers and funding categories), and information relevant to your support goals.

This Personal Information is obtained through intake forms, assessments, correspondence, telephone, email, and via our website. We do not guarantee the website links or policies of authorised third parties.

We collect your Personal Information for the primary purpose of providing counselling and therapeutic services to you. This includes developing and reviewing your support goals, writing progress notes and reports, and communicating with others involved in your care where you have given consent.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. We will use plain language and, where needed, offer accessible formats to ensure you understand.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal record, health information, and disability-related information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law

NDIS Participant Information

As an NDIS service provider, we are subject to specific obligations under the NDIS Act 2013 and NDIS Practice Standards regarding how we handle participant information. These obligations are in addition to our obligations under the Privacy Act.

Information We May Hold

In the course of providing supports, we may hold information including:

• Your NDIS participant number and plan details
• Funding categories and budget information relevant to the supports we provide
• Progress notes, session records, and reports
• Goals, outcomes, and support plans
• Communication with your support network (with your consent)

Sharing Information with Support Coordinators and Plan Managers

If you have a Support Coordinator or Plan Manager, we may need to share information with them for the purpose of coordinating your supports and managing your NDIS funding. This may include:

• Confirmation of service delivery dates and hours
• Service Agreements and invoicing information
• Progress reports or updates relevant to your plan goals

We will only share information with your Support Coordinator or Plan Manager with your consent, or where necessary for the delivery or administration of your supports. You can withdraw or adjust this consent at any time by contacting us.

Information Shared with the NDIA

In some circumstances we may be required to share information with the National Disability Insurance Agency (NDIA), for example in relation to plan reviews, audits, or where required by law. We will inform you if this occurs, unless we are legally prevented from doing so.

Confidentiality and Its Limits

Everything you share with us is treated as strictly confidential. We will not disclose your information to anyone without your written consent, except in the following circumstances:

• Risk of harm - If we believe there is a serious and imminent risk to your life or the life of another person, we may need to take action to keep you or others safe. This may include contacting emergency services.
• Mandatory reporting - We are mandatory reporters under child protection legislation. If we have reasonable grounds to suspect a child is being, or is at risk of being, abused or neglected, we are legally required to report this to the relevant state authority.
• NDIS reportable incidents - As an NDIS provider, we are required to report certain incidents to the NDIS Quality and Safeguards Commission. This is a legal obligation and does not require your consent, though we will inform you if a report is made unless doing so would create a risk.
• Court orders and subpoenas - We may be required by law to disclose information in response to a court order, subpoena, or other legal obligation.
• Your consent - If you give us written permission to share information with another person or organisation, we will do so only to the extent you have authorised.

Where possible, we will discuss any disclosure with you before it occurs.

Clinical Supervision

All counsellors at Good Game Counselling engage in regular clinical supervision as part of their professional obligations. De-identified information about our work together may be discussed in supervision to support the quality of your care. Your identifying details will not be disclosed in supervision.

Subcontractors and Staff

Good Game Counselling may engage subcontractors to deliver services. Any subcontractor engaged by us is required to comply with the same privacy obligations set out in this policy, the Australian Privacy Principles, the NDIS Act, and the NDIS Code of Conduct.

We take reasonable steps to ensure that subcontractors handle your Personal Information in a manner consistent with our obligations, and we remain responsible for ensuring your information is protected.

Third Parties

Where reasonable and practicable, we will collect your Personal Information only from you. However, in some circumstances we may receive information from third parties such as referring organisations, EAP providers, Support Coordinators, or Plan Managers. In such cases we will take reasonable steps to ensure you are made aware of the information provided to us.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances, including:

• Third parties where you consent to the use or disclosure
• Where required or authorised by law, including under the NDIS Act 2013
• To the NDIS Quality and Safeguards Commission in relation to a reportable incident
• Where necessary to prevent or lessen a serious and imminent threat to a person's life, health, or safety
• To Support Coordinators or Plan Managers for the administration of your NDIS supports (with your consent)

Online Sessions and Platform Privacy

For online therapy sessions, we use a secure telehealth platform. We take reasonable steps to ensure any platform we use meets appropriate security and privacy standards. The platform provider has its own privacy policy, which we encourage you to read.

We recommend using a private device and secure internet connection for online sessions. If you have questions about which platform we use or how your data is handled, please ask us.

Notifiable Data Breaches

In the event of a data breach that is likely to result in serious harm to you, we are required under the Notifiable Data Breaches scheme (Privacy Act 1988, Cth, as amended by the Privacy and Other Legislation Amendment Act 2024) to:

• Notify the Office of the Australian Information Commissioner (OAIC)
• Notify affected individuals as soon as practicable

We will take all reasonable steps to prevent data breaches. If a breach occurs, we will act promptly in accordance with our legal obligations.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse, loss, and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify it. Client files will be retained as follows:

• For adult clients: at least 7 years from the date of last service
• For clients who were under 18 at the time of service: until the client turns 25, or for 7 years from the date of last service, whichever is longer

Access to your Personal Information

You may access the Personal Information we hold about you and request that it be updated or corrected, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. We may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is accurate and up to date. We will take reasonable steps to ensure your Personal Information is accurate, complete and current. If you find that the information we hold is not up to date or is inaccurate, please let us know as soon as practicable.

Policy Updates

This Privacy Policy may change from time to time and is available on our website at goodgamecounselling.com.au. We will notify you of any significant changes.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about this Privacy Policy or how we handle your Personal Information, please contact us:

If you are not satisfied with our response, you may escalate your complaint to: