Black Swan Health
THRIVEkit Privacy Policy


In complying with the Commonwealth of Australia Privacy Act 1988 as amended, Black Swan Health Limited (Black Swan Health) provides the following advice to members, stakeholders and consumers about the collection, use, disclosure and storage of personal information.
Black Swan Health’s Privacy Policy governs:

  • What personal information is collected;
  • Who collects personal information;
  • How personal information is used;
  • To whom and under what circumstances personal information is disclosed; and
  • How personal information is stored.

What personal information is being collected?

In most circumstances, Black Swan Health will:

  • Only collect personal information about members, stakeholders and consumers with their consent (unless legally required or authorised to do otherwise);
  • Collect personal information directly from the members, stakeholders or consumers (where possible and practicable);
  • Only collect personal information about the members, stakeholders or consumers that is necessary and relevant to the functions and / or Programs of Black Swan Health;
  • Ensure information is collected by staff who are appropriately trained and have a specific role in the purpose for which your personal information is being collected;
  • Use personal information for the purpose for which it is collected or for a directly related secondary purpose that one would expect their personal information to be used for (unless legally required or authorised to do otherwise);
  • Provide the members, stakeholder or consumer with access to their personal information (unless legally required or authorised to do otherwise). A small but reasonable administration fee may be levied to provide such access;
  • Only disclose personal information to a third party with the members, stakeholders or consumers’ consent, or where you expect such disclosure (unlesslegally required or authorised to do so);
  • Take reasonable steps to keep personal information complete, current and accurate;
  • Destroy or permanently de-identify personal information that is no longer required in accordance with the applicable policies and guidelines; and
  • Take reasonable steps to ensure personal information is kept secure.

Collection of Personal and Sensitive Information

As part of providing counselling and other related services, Black Swan Health clinicians obtain from you, with your consent, personal information that is relevant to your current situation and which is of assistance in providing a professional service.

At or before the time Black Swan Health collects personal information about you, Black Swan Health will take reasonable steps to ensure that you are aware of:

  • the identity of Black Swan Health and how to make contact;
  • the purposes for which the information is collected;
  • any law that requires the particular information to be collected; and;
  • the main consequences (if any) for you if all or part of the information is not provided.


This information is used to assist in the provision of psychological services and is intended to satisfy our legal and professional obligations as mental health clinicians.

When the services are being accessed as part of an Employee Assistance Program (the program), some of the information collected will also be used to compile non-identifying statistical reports to the relevant host organisation regarding usage of the program. All reasonable steps will be taken by us to ensure that this information does not allow for the identification of any persons.


Information obtained by us will remain confidential and will only be released when:

  • You have provided written approval of informed consent for access to your own case notes.
  • The information is health information and the use or disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety, and:
    • it is impractical for Black Swan Health to seek your consent before the use or disclosure;
    • the use or disclosure is conducted in accordance with guidelines approved by the Privacy Commission under section 95A of the Privacy Act;
    • in the case of disclosure, Black Swan Health reasonably believes that the recipient of the health information will not disclose any such personal information.
  • The use or disclosure is required or authorised by law.
  • Black Swan Health reasonably believes that the use or disclosure is necessary to lessen or prevent a serious and/or imminent threat to any person.

Other people’s information which you provide to us.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described above. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this policy as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our information disclosures practices, the individual’s right to obtain access to the information and the consequences for the individual if the information is not provided.


Black Swan Health will take all reasonable steps to ensure that the information obtained and stored is accurate. If any of the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to correct this information or, if necessary, we will discuss alternative access with you.

Data Security

Black Swan Health takes all reasonable steps to ensure that client data is secure. All personal information is kept in secure systems and on a secure computer server. Only authorised personnel have access to both systems.


Black Swan Health is open about its management of personal information. This document and all other relevant documents are available on request.

On request by you, Black Swan Health will take reasonable steps to inform you of the information it holds, the purpose of obtaining such information, how it collects, uses and discloses that information.

Access & Correction

You have the right to access your personal information.

All requests to access information should be in writing to the Privacy Officer. Such requests will be responded to promptly (typically within 5 working days).

Access may be denied in the circumstances set out in the Australian Privacy Principles, including:

  • where providing access will pose a serious threat to life or health of any individual or pose an unreasonable impact on the privacy or an individual;
  • your request for access is frivolous or vexatious;
  • where the information relates to existing legal proceedings between Black Swan Health and you and the information would not be discoverable in the process of those legal proceedings;
  • where providing access would be unlawful, may prejudice an investigation of possible unlawful activity, may prejudice enforcement of laws, or denying access is specifically authorised by law.


Black Swan Health will use a Client Identification Numbering System which allows for privacy and security of your information and which is not related to any other identifier system.


You have the option to use our services without identifying yourself. This protection is subject to any legal and professional responsibilities.

Transborder Data Flow

Black Swan Health does not store any personal data or individual’s information outside of Australia.

Where an individual requests us to provide services through Associates located outside of Australia, the individuals information will be provided to that Associate, located outside of Australia, In that circumstance, security of information is covered by Australian Privacy Principle 8.2.a.i.


Black Swan Health is pleased to discuss any concerns or complaints regarding the management of personal information.

Please note: Any information accessed for accreditation or reporting purposes will be de-identified.

For further information about Black Swan Health’s Privacy Policy, contact our Privacy Officer at or phone 08 9201 0044.