Nurturing Connections OT Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website: https://www.nurturingconnectionsot.com.au (Site). In this Privacy Policy we, us or our means Nurturing Connections OT Pty Ltd (ACN 671 978 911, ABN 51 671 978 911).

This Privacy Policy applies to clients of our occupational therapy services, people who access our clinical supervision and mentoring services (supervisees), participants in our professional development programs (including The Aligned Leader Program and OT Reimagined), and visitors to our site.

Personal Information

The types of personal information we may collect about you include:

your name
images of you
your contact details, including email address, mailing address, street address and/or telephone number
your age and/or date of birth
health information such as medical records, clinical history, medications, diagnoses, treatment, file notes, consents, referrals and correspondence, and any other information provided or collected by us relating to your health
If you are a supervisee or program participant: your profession, AHPRA registration number, employer or practice details, role, professional goals, and information you share about your practice and wellbeing during supervision or programs
your credit card details
information you provide to us through customer surveys
information about your access and use of our Site
additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information
any other personal information requested by us and/or provided by you or a third party

We may collect these types of personal information directly from you or from third parties such as GPs, Paediatricians, Allied Health Practitioners, schools, parents or guardians, NDIS plan managers and support coordinators. If you are a supervisee, we may also collect information from your employer, where your employer has arranged supervision for you.

Collection and Use of Personal Information

We may collect, hold, use and disclose personal information for the following purposes:

to provide occupational therapy and related services to you (or to your child), including assessment, intervention, report writing and communicating with your treating team
to provide clinical supervision, mentoring and professional development programs, including keeping supervision records and planning & reviewing your supervision
to provide evidence of your participation in supervision or professional development, such as attendance records or certificates, when you ask us to (for example, for registration, CPD or employment purposes)
to enable you to access and use our Site, associated applications and associated social media platforms
to contact and communicate with you
for internal record keeping and administrative purposes
for analytics, market research and business development
for advertising and marketing
to comply with our legal obligations and resolve any disputes that we may have
to manage bookings, invoicing and payments, and to recover unpaid fees
to consider your employment application

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

third party service providers for the purpose of enabling them to provide their services
our employees and contractors
our existing or potential agents or business partners
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred
with your consent (or the consent of your parent or guardian), the National Disability Insurance Agency (NDIA), plan managers, support coordinators, schools, early childhood services and other members of your treating team, such as GPs, paediatricians and allied health practitioners
with your agreement, your employer, where your employer has arranged and is paying for your supervision. We will only share attendance and any other information you agree to
the Australian Health Practitioner Regulation Agency (Ahpra), where we are required to make a mandatory notification under the Health Practitioner Regulation National Law
OT Reimagined: our program collaborator, Georgia Bellas from Playful Pathways Therapy, to the extent needed to deliver the program
a debt collection agency or legal adviser, if an account remains unpaid after reasonable reminders. We will only disclose the information needed to recover the debt (such as your name, contact details, invoice details and the amount owing). We will not disclose your health information for this purpose
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights
third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia
third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia

We ask clients (or their parent or guardian) to sign a consent form at the start of our services. We will only share your information with the NDIA, plan managers, support coordinators, schools or other members of your treating team in line with that consent, unless we are otherwise required or authorised by law. You can change or withdraw your consent at any time by contacting us.

We store client records, including health information, in our practice management system (Splose), which stores data in Australia. We do not store client records in other cloud storage services. Some of our other service providers, such as Google (Google Analytics), Kit and Anthropic (Claude), may store or process limited personal information overseas, including in the United States. This may include names, email addresses and website usage data, but not client health information. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information outside of Australia. Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles. We also store supervision records in Splose. Video conferencing and online program platforms we use for supervision and professional development such as Zoom and Google (Google Meet and Google Forms), may store or process personal information overseas, including in the United States.

Our Website

Our Site is a set of static web pages hosted by Cloudflare, Inc. and delivered from its global network. Cloudflare receives the technical details any web server receives (such as your IP address, browser type and the pages you request) and may set a cookie to protect the Site from automated abuse. The Site does not use a cookie banner because it sets no advertising or tracking cookies of its own.

Contact form. Our contact form collects your first name, last name, email address, your message and, if you choose, the services you are interested in. Please do not include health or medical details in the form; we will discuss those with you directly. Your enquiry is emailed to us through SMTP2GO, an email delivery service whose Australian accounts are hosted in Sydney, and delivered to our Google Workspace mailbox. The form submission is not stored on the Site or by Cloudflare. We use these details only to respond to your enquiry.

Signup forms (training updates, the free masterclass and the monthly group supervision list) are provided by Kit (see Email Marketing below). When you complete one, your details go directly to Kit.

Third-party code on the Site. The following services load content or code on our pages and may receive your IP address and browser details when they do: Google Analytics 4 (anonymised visitor and page-view statistics; Google may set cookies and store data in the United States); Adobe Fonts (web fonts); Kit (signup forms); Spotify and Apple Podcasts (embedded podcast players on the home and About pages); and Google Maps (the map on the Contact page). Each provider handles that information under its own privacy policy.

Practice Management Software

We use Splose as our practice management system. Splose stores booking information, session records, and relevant health information on your behalf. Splose is a cloud-based platform that stores data in Australia. You can view Splose's privacy policy at splose.com.

Email Marketing

We use Kit to manage our email communications. Kit stores subscriber information including your name and email address on servers that may be located outside Australia. Our newsletters do not contain identifiable client information or sensitive information. You can unsubscribe at any time using the link included in every email, or by contacting us directly. You can view Kit's privacy policy at kit.com.

Use of Artificial Intelligence Tools

We use AI-assisted tools (including but not limited to Claude by Anthropic) to support business operations such as content development, program material creation, and administrative tasks. We do not input identifiable client information into these general-purpose AI platforms. Any information used in conjunction with these tools is de-identified or relates to general business functions only. AI tools we use may process data on servers located outside Australia. AI note-taking in clinical supervision is explained in the Clinical Supervision and Professional Development section below.

AI-assisted clinical documentation

We may use AI-assisted clinical documentation tools designed for health practitioners (such as Splose AI or Everbility) to help draft session notes, reports and other clinical documents. When we do, the tool may process relevant personal and health information, such as session notes, assessment results and goals. These tools may process data on servers located outside Australia.

We will only use these tools with your information if you (or your parent or guardian) have agreed, and you can withdraw that agreement at any time. All AI-generated content is reviewed, edited and approved by your occupational therapist before it is finalised.

Automated decision-making

We do not use computer programs, including AI tools, to make decisions about you, such as decisions about your access to our services, your clinical recommendations or your funding. All clinical decisions and recommendations are made by a qualified occupational therapist. If this changes, we will update this Privacy Policy before those decisions are made, to describe the kinds of decisions involved and the kinds of personal information used.

How We Treat Sensitive Information

Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

We only collect, hold, use and disclose sensitive information for the following purposes:

any purposes you consent to
the primary purpose for which it is collected
secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the above listed third parties as reasonably necessary to provide our services to you
to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent
if otherwise required or authorised by law

Children and Young People

We provide services to children and young people. When a client is under 18, we usually collect personal information from, and seek consent from, their parent or legal guardian.

Where a young person has the maturity and understanding to make their own decisions about their personal information, we may seek their consent directly and involve them in decisions about how their information is shared. We assess this case by case. As a general guide, a young person aged 15 or over may have this capacity unless there is reason to think otherwise.

Where parents are separated, we will generally share information with each parent who has parental responsibility, unless a court order or parenting arrangement says otherwise, or we believe sharing the information would put the child or another person at risk. Please tell us about any court orders or arrangements that affect who can access your child's information.

We will always consider the child's best interests and, where appropriate, their views when handling their personal information. We may disclose information without consent where required by law, including under child protection laws.

Clinical Supervision and Professional Development

Supervision records

We keep records of supervision sessions in Splose. These may include your goals, topics discussed, actions agreed and reflection on your practice and wellbeing. We ask you to de-identify any client information you bring to supervision and we do not record identifiable client information in supervision notes.

AI note-taking in supervision

We may use an AI note-taking feature in our video conferencing platform (Zoom or Google Meet) to help draft supervision notes. We will let you know before we use it and you can ask us not to. All AI-generated notes are reviewed and edited by your supervisor before they are saved to Splose. Once the AI-generated notes are reviewed and edited, your supervisor will delete the transcript from Zoom or Google Meet.

Group supervision and programs

In group supervision, peer mentoring and program sessions, participants share experiences with one another. We ask all participants to keep what others share confidential and not to share identifiable client information. We cannot control what other participants do with information you choose to share in a group. Sessions may be recorded so participants can watch them later. Recordings are stored on YouTube and shared only with participants of that group or current supervisees.

Your Rights and Controlling Your Personal Information

Choice and consent

Please read this Privacy Policy carefully. By providing personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Information from third parties

If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Restrict

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access

You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints

If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. We aim to respond within 30 days. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992. You may also contact the NSW Information and Privacy Commission at www.ipc.nsw.gov.au or on 1800 472 679.

Unsubscribe

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Storage and Security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

We keep health records for the periods required by the Health Records and Information Privacy Act 2002 (NSW): for adults, at least 7 years from the last time we provided a health service; for clients who were under 18 at that time, until they turn 25. After this, we securely destroy or de-identify the records. Other personal information is kept only as long as needed for the purposes set out in this Privacy Policy, or as required by law (for example, tax records). We keep supervision and program records for 7 years after our services to you end, then securely destroy or de-identify them.

Cookies and Web Beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor's behaviour and collect data about the visitor's viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Links to Other Websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.

Contact Us

For any questions or notices, please contact us at:

Nurturing Connections OT Pty Ltd

ACN: 671 978 911 | ABN: 51 671 978 911

Email: rachel@nurturingconnectionsot.com.au

Last update: 10th November 2026