Privacy Policy
Our commitment to your privacy
Centred Ground Pty Ltd trading as Centred Ground (“Centred Ground”, “we”, “us” or “our”) is committed to protecting privacy and handling personal information, including health information, responsibly and in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and other applicable laws.
This Privacy Policy explains:
- the kinds of personal information we collect and hold
- how we collect and hold personal information
- why we collect, use and disclose personal information
- how we protect and retain information
- how you can access or correct information we hold about you
- how you can raise a privacy concern or complaint
- how third-party and online services may process information, including outside Australia.
This policy applies to personal information handled by Centred Ground Pty Ltd. Independent practitioners who operate their own businesses from Centred Ground are responsible for their own client records and privacy practices, as explained below.
What personal information do we collect?
The information we collect depends on your relationship with Centred Ground and the services you use. We may collect:
- your name, address, date of birth, telephone number and email address
- emergency contact details and, where relevant, information about family members, carers or other people involved in your care
- information about other healthcare professionals involved in your care
- Medicare, DVA and health fund details where required for claiming or billing
- appointment, attendance, payment and billing information
- referral information and professional correspondence
- information supplied through website forms, telephone calls, SMS, email or other correspondence
- newsletter preferences and marketing consent
- information provided when enquiring about consulting rooms or joining the Centred Ground collective.
Health and other sensitive information
When we provide healthcare or other services where health information is relevant, we may collect sensitive information that is reasonably necessary for the service. This can include:
- symptoms and reasons for seeking care
- relevant medical and health history
- assessment findings, clinical observations, diagnoses or clinical impressions
- treatment provided, treatment plans and clinical progress
• exercise and rehabilitation programs
- specialist reports, investigation results and correspondence
- relevant pregnancy, postpartum, pelvic health or other health information
- outcome measures, questionnaires and information relevant to suitability for a service
- other information reasonably necessary to provide safe and appropriate care.
We aim to collect only information that is reasonably necessary for our functions and services.
Government-related identifiers
Where relevant, Centred Ground may collect government-related identifiers such as Medicare or DVA details for lawful claiming and administrative purposes. We do not use these identifiers as our own internal identifier for you except where permitted by law.
How do we collect personal information?
We usually collect information directly from you, including when you:
- attend an appointment or participate in a program
- complete a registration, intake, consent, assessment or suitability form
- submit a form through our website
- book or manage an appointment
- speak with us in person or by telephone
- communicate with us by SMS or email
- subscribe to a newsletter or other communication
- enquire about Coaching & Hypnotherapy, Strong Seniors, physiotherapy, or another Centred Ground service
- enquire about consulting rooms or joining the collective.
Where permitted and appropriate, we may also collect information from a parent, guardian or person responsible for you; a referring GP, specialist or other health practitioner; diagnostic imaging or pathology providers; Medicare, DVA, health funds or insurers; My Health Record; or another organisation involved in your healthcare or funding arrangements.
My Health Record
Where clinically relevant, Centred Ground may occasionally access health information available through My Health Record in connection with providing healthcare to you. Access to and use of information from My Health Record is subject to the My Health Records Act 2012 (Cth), the My Health Records Rules and other applicable requirements.
Why do we collect, hold, use and disclose information?
We primarily collect, hold, use and disclose personal information to provide and administer our services. Purposes may include:
- providing physiotherapy and related healthcare, including Women’s Health Physiotherapy
- managing participation in Strong Seniors
- providing Coaching & Hypnotherapy
- assessing suitability for a service and planning safe care
- communicating with you about appointments, services and care
- preparing and maintaining clinical records
- developing exercise and rehabilitation programs
- communicating with other health practitioners involved in your care where appropriate
- processing payments, Medicare rebates, DVA claims and health fund claims
• managing accounts and outstanding invoices
- responding to enquiries and managing practitioner or consulting-room enquiries
- operating, securing and improving our business, systems and website
- meeting professional, insurance, legal, regulatory and quality-assurance obligations
- handling complaints, incidents and risk-management matters.
We use personal information for newsletters or other direct marketing only where we have appropriate consent. You may withdraw that consent or unsubscribe from marketing communications at any time.
Clinical records and Cliniko
Centred Ground uses Cliniko practice management software as its primary system for managing appointments and clinical records. Clinical records may include health information collected during your care, correspondence, investigation results, exercise information, billing details and other information relevant to the services provided. Access is restricted to people who require it for legitimate clinical or administrative purposes.
AI-assisted clinical documentation
Centred Ground may occasionally use AI-assisted clinical documentation tools, such as Heidi Health or Clinical Notes, to assist with drafting clinical notes.
Where an AI scribe records, transcribes or otherwise processes a consultation, its use will be explained before it is activated and your informed consent will be sought. You may decline the use of an AI scribe without affecting your care. Where recording of a private conversation is involved, consent will be obtained in accordance with applicable South Australian law.
AI-generated documentation is reviewed by the treating practitioner, who remains responsible for the accuracy and appropriateness of the clinical record. We do not rely on an AI scribe to make clinical decisions about your care.
The privacy and data-location arrangements of AI providers vary. Depending on the tool used, information may be processed in Australia or overseas, including in the United States. We take reasonable steps to use services appropriate for handling health information and to understand their privacy and security arrangements.
Exercise programs and Physitrack
Centred Ground may use Physitrack to provide home exercise or rehabilitation programs and, where relevant, communicate with clients about progress. Features such as exercise-adherence tracking may be used where appropriate. We limit information shared through the platform to what is reasonably necessary for the relevant service.
Investigation reports and external healthcare platforms
At times, Centred Ground may access reports or investigation results through diagnostic imaging, pathology or other healthcare-provider platforms. A report may temporarily be downloaded to a clinic computer so that it can be added to the client’s clinical record in Cliniko. Where this occurs, the temporary local copy is deleted after it has been appropriately filed.
Payments, Medicare, DVA and health fund claims
Centred Ground may collect and use billing, Medicare, DVA, health fund and related information where necessary to process payments, rebates or claims. Payments and claims may be processed through third-party systems such as HICAPS, Medipass and Tyro. Centred Ground does not store your credit or debit card details.
Third-party payment and claiming providers handle information under their own privacy and security arrangements.
Website forms and online enquiries
When you submit information through the Centred Ground website, the information you enter may be stored in the website database and then delivered to our business inbox or a connected service, such as Mailchimp, where relevant to the form you have used.
Website forms may collect your name, contact details, enquiry information and, in some circumstances, health or other sensitive information relevant to determining suitability for a service. If required information is not provided, we may be unable to respond fully, assess suitability, or provide the requested service.
Please avoid including unnecessary health or sensitive information in a general enquiry form. More specific privacy collection notices may be provided at the point where information is collected.
Website analytics, cookies and spam protection
The Centred Ground website uses Google Analytics to help us understand how visitors use the website and improve site performance. Analytics information may include browser and device information, city-level or approximate location, pages viewed, referral source and interactions with the website. Google Analytics 4 uses IP addresses at collection time to derive location information and discards the IP address before it is logged in Analytics.
The website uses Cloudflare Turnstile to help protect forms from spam, automated submissions and misuse. Turnstile may process technical signals such as IP address, browser or device information and other security-related data for bot detection and security purposes.
These services operate under their own privacy arrangements and may process technical information using infrastructure located outside Australia.
Newsletter and marketing communications
Centred Ground uses Mailchimp to manage newsletters and marketing communications. Information such as your name, email address, subscription preferences, areas of interest and source of signup may be processed through Mailchimp. Information may also be transferred between connected systems, including Cliniko and Mailchimp, where those systems are integrated.
We send newsletters and other direct marketing only where we have appropriate consent. Marketing messages identify Centred Ground and include an unsubscribe facility. You may withdraw consent, unsubscribe or change your preferences at any time. Unsubscribing from marketing does not affect communications reasonably necessary to provide healthcare or administer an existing service.
Google Workspace and general business systems
Centred Ground uses Google Workspace for business email and general administration. Google Drive is not intentionally used as the primary storage location for confidential clinical records. Clinical records are ordinarily maintained in designated clinical systems, principally Cliniko.
Independent practitioners working from Centred Ground
Some practitioners working from Centred Ground operate their own independent businesses. These practitioners manage their own appointments, enquiries, fees, payments, client and clinical records, and privacy obligations.
Centred Ground does not routinely access or manage the clinical records or other client information held by independent practitioners. If you contact Centred Ground with an enquiry about an independent practitioner, we may use the information you provide for the limited purpose of responding to your enquiry or directing you to that practitioner.
Information is not routinely shared between Centred Ground and an independent practitioner merely because that practitioner works from the Centred Ground premises. Where communication about your healthcare between practitioners is appropriate, this will occur with your knowledge and consent or where otherwise authorised or required by law.
When might we disclose information?
We may disclose personal information where reasonably necessary for providing services or where permitted or required by law. This may include disclosure:
- to healthcare professionals involved in your care
- to Medicare, DVA, health funds or insurers for claiming or funding purposes
- to diagnostic imaging, pathology or other healthcare providers where relevant
- to technology, practice-management, communications, payment, website or other service providers supporting our operations
- to professional advisers, insurers or legal representatives where reasonably necessary
- where required by a court order, subpoena, mandatory reporting obligation or other law
- where reasonably necessary to lessen or prevent a serious threat to life, health or safety
- to establish, exercise or defend a legal or equitable claim or fulfil insurance-notification obligations. We do not sell personal information.
Overseas processing and disclosure
Some technology and cloud-based providers used by Centred Ground operate internationally or use overseas subprocessors. Personal information may therefore be processed, stored or disclosed outside Australia in some circumstances.
Likely overseas recipient or processing locations include the United States, particularly in connection with Mailchimp, some AI-assisted documentation services and some technology-provider subprocessors. Other providers may use globally distributed infrastructure or subprocessors in additional jurisdictions, and those locations may change over time.
Where the Australian Privacy Principles require us to take steps before disclosing personal information overseas, we will take reasonable steps in the circumstances to ensure the information is handled consistently with applicable privacy obligations. Information about relevant providers and their privacy arrangements can be requested from Centred Ground.
How do we protect personal information?
Centred Ground takes reasonable technical and organisational steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include:
- use of secure practice-management and cloud-based systems
- password, account and access controls
- limiting access according to legitimate clinical or administrative need
- confidentiality requirements and privacy-aware work practices
- appropriate security settings, software updates and safeguards
- maintaining clinical records in designated clinical systems rather than general file-storage locations
• secure disposal or deletion of information when appropriate and legally permitted.
No electronic system can be guaranteed to be completely secure. We review our privacy and information-security practices as appropriate to our size, services and the sensitivity of the information we hold.
Data breaches
Centred Ground maintains processes for responding to suspected privacy or data-security incidents. Where an eligible data breach occurs, or is reasonably suspected, we will assess and respond to the incident in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.
Automated decision-making
Centred Ground does not currently use computer programs to make, or substantially and directly inform, decisions that could reasonably be expected to significantly affect an individual’s rights or interests. AI-assisted clinical documentation is used to support note preparation only; clinical decisions remain subject to practitioner judgment and review. If our use of automated decision-making changes, this Privacy Policy will be updated as required.
Can you remain anonymous or use a pseudonym?
Where it is lawful and practicable, you may have the option of dealing with Centred Ground anonymously or by using a pseudonym. For healthcare services, however, it will often be impracticable to provide appropriate care, process claims, maintain accurate health records or meet professional and legal obligations without knowing your identity.
Accuracy and correction of information
We take reasonable steps to ensure personal information we use or disclose is accurate, up to date, complete and relevant for its purpose. Please let us know if your contact details or other relevant information change.
You may ask us to correct personal information you believe is inaccurate, out of date, incomplete, irrelevant or misleading. We will deal with correction requests in accordance with applicable privacy law.
Accessing your personal information
You may request access to personal information Centred Ground holds about you. There is no charge for making an access request. Where permitted by law, we may charge a reasonable amount reflecting the administrative costs of providing access, such as locating, collating or copying records. If a charge is proposed, we will let you know beforehand.
We will respond within a reasonable period and in accordance with applicable privacy law. In limited circumstances, the law may permit or require us to refuse access to some or all requested information. Where required, we will explain the reason for refusal and available complaint mechanisms.
Retention and destruction
Centred Ground retains health and other personal information for as long as reasonably necessary to provide services and meet professional, insurance, legal and record-keeping obligations. Where information is no longer required and there is no lawful reason to retain it, we take reasonable steps to securely destroy or de-identify it.
Privacy concerns and complaints
If you have a question or concern about how Centred Ground has handled your personal information, please contact our Privacy Contact. We will take the matter seriously, investigate as appropriate and aim to respond within 30 days.
Privacy Contact
Director / Privacy Contact, Centred Ground Pty Ltd 54 Gibson Street, Bowden SA 5007
Phone: 0423 858 209
Online: Contact form on the Centred Ground website
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). Current complaint information and contact details are available at www.oaic.gov.au.
Updating this Privacy Policy
We review this Privacy Policy periodically and when there are material changes to our services, information-handling practices, technology providers or applicable legal requirements. The current version will be published on the Centred Ground website and will show the date it was last updated.
If you would like a copy of this Privacy Policy in another reasonably available format, please contact us.