On the Line Australia Ltd (trading as On the Line) collects and holds personal and sensitive information according to the requirements of the Privacy Amendment (Enhancing Privacy Protection) Act 2012. It also manages personal and sensitive information according to the requirements of the Health Records Act 2001 (Vic), the Information Privacy Act 2000 (Vic) and the Family Law Act (1975).
The kinds of personal and sensitive Information that On the Line collects and holds
On the Line collects and holds personal and sensitive information for the purpose of providing remote professional counselling services.
With telephone counselling services On the Line requests, but does not require, minimal personal and sensitive information (such as a client’s first name) allowing engagement with the client and the provision of a professional counselling service. While On the Line would prefer that clients use their real name, clients can choose to use a pseudonym.
Depending on the needs of the client, further personal and sensitive information (i.e. nature of their relationship, current issues) may be requested enabling professional counselling to take place within the context of the client’s reason for seeking assistance according to the level of client need and safety issues, this material may be noted and maintained by the counsellor to manage any safety issue.
With online and video counselling services, On the Line requires identifying material (i.e. name, email and/or IP addresses, geographic location) to ensure that electronic connection with clients can be achieved and maintained and to manage any safety issues.
At various times, On the Line may request (but not require) non-identifying demographic information to meet funding obligations. This material is collated in a de-identified form. Clients are not obliged to provide this material to receive services. On the Line may request identifying information and afterwards contact the client in order to evaluate the services. Clients are not obliged to provide their contact details for service evaluations or participate in these evaluations to receive services.
All clients on every modality (telephone, online and video) are informed prior to engaging in counselling that sessions are digitally recorded and electronically stored at the time of service. These digital and electronic records are retained as Health Records and may contain personal and sensitive information.
Recording software automatically retains specific data (i.e. telephone numbers) that enables client identification, queuing, priority access, workforce allocation and the safe management of client presenting issues. This data is collected and retained by On the Line for professional and operational purpose.
How On the Line collects and holds personal and sensitive information
On the Line collects and holds personal and sensitive information through the professional interaction between counsellor and client and through software and client registration requirements (telephone, online and video).
On the Line does not solicit personal and sensitive information that is not relevant to the provision of professional services. However it may receive such personal and sensitive information in the course of professional counselling.
All personal and sensitive information is collected and maintained according to the provisions of the relevant Acts, as well as On the Line’s Policy and Procedure for Recording and storing Health Records. Health Records are stored by On the Line in a secure password-protected database for a period of ten years from the date of contact and then destroyed. Health Records may be retained for a longer period when it is determined that there is a requirement to retain this material for organisational, contractual or legal purposes.
The purpose for which On the Line collects, holds, uses and discloses personal and sensitive information
On the Line collects, holds and uses personal and sensitive information for the purpose of providing remote professional counselling services.
On the Line discloses personal and sensitive information under the following circumstances:
- In de-identified form, for the purposes of meeting funding obligations
- In order to discharge its professional duty of care to a client, another person or the community to relevant emergency services or other agencies enabling safety issues to be addressed in a timely manner
- Where obliged by legislation (i.e. Family Law Act 1975)
- In response to a request from a court or properly constituted legal agency
- Where requested by the client or a properly appointed legal representative.
How a person may access their personal and sensitive information held by On the Line and seek the correction of such information
A person may access or seek the correction of their personal and sensitive information by following On the Line’s Policy and Procedure for the External provision of client information and requesting a copy of their Health Records.
A request for a copy of a client’s Health Records or correction of information must be in writing (mail or email) addressed to
Manager of Clinical Services
On the Line
PO Box 2335
Footscray, Vic 3011
The request will be acknowledged in writing, and the Manager of Clinical Services may require further information that confirms the identity of the client and general dates of service to allow identification and provision of relevant material.
How a person may complain about a breach of the Australian Privacy Principles or a registered APP code binding On the Line, and how On the Line will deal with such a complaint
Clients are made aware of information on their rights and obligations when receiving services from On the Line.
Complaints are managed by On the Line through its Procedure for Handling Service Complaints, which provides a clear process for the timely management of issues regarding the provision of services including matters relating to collecting and holding personal and sensitive information.
On the Line’s complaints procedure ensures that:
- All complaints are responded to in a sensitive, prompt and efficient manner.
- The complainant has the right to be informed about the complaints process and outcome.
- Lodgement of a complaint in no way compromises the right of the complainant to access On the Line services.
- The processes for resolving complaints are, and are seen to be, fair, transparent, accountable and without prejudice.
- At all times, a complainant’s details are kept confidential unless the complainant provides written permission for On the Line to use their details.
- A client can register a complaint via phone, email or in writing.
Call the number of the service relevant to the complaint. Register the complaint with a counsellor or ask to speak to the Supervisor on duty.
Service numbers are:
- Suicide Call Back Service 1300 659 467
- MensLine Australia 1300 789 978
- SuicideLine Victoria 1300 651 251
- Veterans Line 1800 011 046
- The All Hours Suicide Support Service (AHS) 1800 859 585
- Department of Defence All-Hours Support Line 1800 628 036
- Changing for Good 1300 015 120
Send the complaint to PO Box 2335, Footscray 3011.
On the Line will endeavour to respond to a complaint via the original contact method, unless otherwise requested.
Individuals whose personal information is held by On the Line may also make a complaint to the Privacy Commissioner. The Privacy Commissioner may investigate complaints about acts or practices that breach the Australian Privacy Principles.
On the Line’s disclosure of personal and sensitive information to overseas recipients
On the Line does not disclose personal and sensitive information to overseas recipients.