Occupational Therapy Services

Privacy Policy

The Training Club Pty Ltd
Last updated: 5 November 2026

1. About this policy

The Training Club Pty Ltd (we, us, our) respects your privacy and is committed to protecting your personal and health information.

This policy explains how we collect, use, store and share information when you enquire about or receive occupational therapy services.

We handle your information in accordance with applicable Australian privacy legislation, including:

• Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

• Health Records and Information Privacy Act 2002 (NSW) and the Health Privacy Principles (HPPs).

This policy applies to our occupational therapy services, including assessments, therapy, reports and related clinical administration.

Our education, consulting and other business activities are covered by our separate general Privacy Policy.

2. What information we collect

We collect information reasonably necessary to provide safe, appropriate and effective occupational therapy services.

Depending on your circumstances, this may include:

• Personal details: Your name, date of birth, contact information and relevant personal circumstances.

• Health information: Medical history, diagnoses, disability-related information, medications and other relevant health information.

• Functional information: Information about your daily activities, participation, environment, support needs and preferences.

• Clinical records: Assessment findings, therapy notes, reports, recommendations and relevant correspondence.

• NDIS information: Your NDIS plan details, funding arrangements, support needs and relevant goals.

• Administrative information: Appointment details, invoices, payment information and service agreements.

We may also collect relevant information from healthcare professionals, support coordinators, family members or others involved in your care, with your consent or where otherwise permitted by law.

You can choose not to provide certain information. However, if we don't have information necessary to provide a service safely or appropriately, we may be unable to provide that service.

3. How we collect your information

We generally collect information directly from you through:

• Referral and intake forms.

• Conversations during appointments.

• Assessments and therapy sessions.

• Phone, email and other communications.

• Service agreements and administrative processes.

We may also receive information from people or organisations involved in your care, where you have agreed or where collection is otherwise permitted by law.

You may make a general enquiry without providing detailed health information. However, we need sufficient identifying and clinical information to provide occupational therapy services.

4. How we use your information

We use your information to:

• Review referrals and determine whether our services are appropriate.

• Provide occupational therapy assessments and interventions.

• Prepare clinical notes, reports and recommendations.

• Communicate with you and coordinate your supports.

• Manage appointments, service agreements, invoicing and payments.

• Meet professional, legal and regulatory obligations.

• Maintain and improve the safety and quality of our clinical services.

We do not use your clinical information for unrelated marketing purposes or sell your personal or health information.

5. How we store and protect your information

Your clinical information is stored in our practice management system and other approved systems used to deliver occupational therapy services.

We take reasonable steps to protect your information from loss, misuse, unauthorised access, modification or disclosure.

These measures include appropriate access controls, secure systems and technical safeguards such as encryption where applicable.

Access to your information is limited to people who need it to provide or administer your services, or where access is otherwise authorised or required by law.

We also assess the privacy and security arrangements of technology providers that handle clinical information on our behalf.

While we take reasonable precautions, no electronic system can be guaranteed completely secure.

How long we keep your records

In accordance with NSW legislation, we retain adult health records for at least seven years after the last occasion on which a health service was provided.

Different retention requirements apply to information collected from people under 18.

When records are no longer required, we securely destroy or de-identify them, unless we are legally required or authorised to retain them.

6. Sharing your information

We respect your choices about who is involved in your care.

With your consent, we may share relevant information with people you nominate, such as:

• Your GP or other healthcare professionals.

• Your NDIS support coordinator or plan manager.

• Family members, carers or other support people.

• Other professionals involved in your care.

We only share information relevant to the purpose of the disclosure.

Your information may also be processed by approved service providers supporting our clinical and administrative systems, such as practice management, secure communications and payment services.

These providers are subject to relevant privacy, security and contractual requirements.

When information may be shared without consent

Sometimes we may be required or authorised by law to share information without your consent.

For example:

• Where necessary to address a serious threat to someone's life, health or safety, in circumstances permitted by law.

• Where mandatory reporting obligations apply.

• Where disclosure is required by a valid court order or other legal requirement.

• In other circumstances authorised under applicable privacy legislation.

Where appropriate and legally permissible, we will inform you about these disclosures.

7. Clinical supervision and quality improvement

We may discuss clinical situations during professional supervision or peer consultation to support safe, effective practice.

Where practical, these discussions use de-identified information so that you cannot reasonably be identified.

If identifiable information needs to be shared, we will obtain appropriate consent or ensure another lawful basis applies.

We may also review clinical records and service processes for quality improvement, using appropriate privacy safeguards.

8. Artificial intelligence and automated tools

We use selected technology tools, including artificial intelligence (AI), to support clinical documentation and administrative activities.

We take particular care when using these tools because health information is sensitive.

AI-assisted clinical note-taking

With your consent, we may use a healthcare AI scribe during appointments.

The AI scribe processes session audio and prepares a draft clinical note.

Your occupational therapist reviews, corrects and approves the note before it becomes part of your clinical record.

The AI scribe does not independently make clinical decisions or recommendations about your care.

When using an AI scribe:

• We ask for your informed consent before recording begins.

• You can decline AI note-taking without affecting your access to care.

• You can withdraw consent for future use at any time.

• Your therapist remains responsible for the accuracy and content of your clinical records.

• We use approved tools with appropriate privacy and security safeguards.

Information is handled according to the arrangements of the approved AI scribe, including applicable data storage, processing and retention controls.

We can provide further information about the tool and its data-handling arrangements on request.

AI-assisted reports and documents

We may use approved AI tools to assist with drafting, editing or organising clinical documents, including reports and letters.

Where possible, information is de-identified before being entered into these tools.

If identifiable information is required, we use tools with appropriate privacy and security safeguards and ensure that the use is permitted by law and any applicable consent arrangements.

Your occupational therapist reviews, edits and takes professional responsibility for all final clinical documents.

We do not intentionally provide identifiable clinical information for the purpose of training general-purpose AI models.

Automated administration

We use automated systems for routine administrative tasks, including:

• Appointment reminders and confirmations.

• Sending forms and service communications.

• Invoicing and payment administration.

• Other routine practice management activities.

These systems operate according to processes we configure and do not independently determine your clinical care or support recommendations.

9. Automated decision-making

We are committed to being transparent about how computer programs and automated systems are used in our occupational therapy services.

Australian privacy legislation includes specific transparency requirements for certain automated processes that use personal information to make, or substantially and directly inform, decisions that could significantly affect a person's rights or interests.

How decisions are made

We do not currently use automated systems to independently make significant decisions about your clinical care.

Your occupational therapist is responsible for clinical decisions, including:

• Assessment findings and clinical conclusions.

• Therapy planning and recommendations.

• Functional capacity assessments and reports.

• Recommendations about supports and services.

• Decisions about whether our services are clinically appropriate.

AI tools may assist with preparing or organising information, but clinical decisions are made by your therapist.

Routine administrative automation does not independently determine your eligibility for services, clinical recommendations or disability support needs.

If we introduce automated systems that make or substantially and directly inform significant decisions about individuals, we will review our privacy obligations and update this policy to explain the relevant decisions and types of personal information used.

You can contact us if you have questions about our use of AI or automated decision-making.

10. Your choices and consent

You have choices about how your personal information is collected, used and shared.

You can:

• Ask questions about how your information is handled.

• Change which people you authorise us to share information with.

• Decline or withdraw consent for AI-assisted note-taking.

• Request access to your records.

• Ask us to correct inaccurate information.

You can change or withdraw consent, in full or in part, by contacting us.

Withdrawing consent does not affect information already lawfully collected, used or shared before you withdrew it.

We may still need to retain or use certain information to meet professional, legal or regulatory obligations.

11. Accessing or correcting your records

You have the right to request access to personal and health information we hold about you, subject to applicable legal exceptions.

You can also ask us to correct information that is inaccurate, incomplete, outdated or misleading.

To make a request, contact us at:

[email protected]

We may need to verify your identity before providing access to sensitive information.

We will respond within a reasonable timeframe and explain if any legal restrictions or applicable fees affect your request.

You may also request deletion of information. However, we may be unable to delete clinical records that we are legally required to retain.

12. Overseas storage and processing

Some technology services may involve personal information being processed or stored outside Australia.

We assess the privacy and security arrangements of providers that handle clinical information and take reasonable steps to comply with applicable Australian privacy obligations.

Where overseas disclosures are likely, information about the relevant countries or regions will be provided in this policy.

13. Privacy breaches and complaints

If you have concerns about how we have handled your personal or health information, please contact us.

We will review your concerns, investigate where appropriate and respond within a reasonable timeframe.

If you are dissatisfied with our response, you can contact:

Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992

Information and Privacy Commission NSW
Website: www.ipc.nsw.gov.au

We manage suspected privacy and data breaches in accordance with applicable privacy and data breach notification requirements.

14. Changes to this policy

We may update this Privacy Policy when our services, technology, information-handling practices or legal obligations change.

The latest version will be available on our website.

Where changes materially affect how we handle your information, we will take appropriate steps to notify affected individuals.

15. Contact us

If you have any questions about this policy or how your information is handled, please contact:

The Training Club Pty Ltd
Email: [email protected]