Privacy policy

This Policy applies as between you, the User of this Website and Kaptain Creative Pty Ltd (ABN 23 660 505 411, ACN 660 505 411) trading as Australian Trauma Education Centre (ATEC), the owner and provider of this Website. This Policy applies to our use of any and all Data collected by us in relation to your use of the Website and any Services or Systems therein.

1. Definitions and Interpretation

"Account": means collectively the personal information, Payment Information and credentials used by Users to access Material and / or any communications System on the Website;

"Content": means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on or forms part of this Website;

"Cookie": means a small text file placed on your computer by ATEC when you visit certain parts of this Website. This allows us to identify recurring visitors and to analyse their browsing habits within the Website.

"Data": means collectively all information that you submit to the Website. This includes, but is not limited to, Account details and information submitted using any of our Services or Systems;

"ATEC": means Kaptain Creative Pty Ltd (ABN 23 660 505 411, ACN 660 505 411) trading as Australian Trauma Education Centre (ATEC), PO Box 1024, Berwick VIC 3806;

"Service": means collectively any online facilities, tools, services or information that ATEC makes available through the Website either now or in the future;

"System": means any online communications infrastructure that ATEC makes available through the Website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

"User" / "Users": means any third party that accesses the Website and is not employed by ATEC and acting in the course of their employment; and

"Website": means the website that you are currently using (www.atec.vic.edu.au) and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. Data Collected

2.1 name;

2.2 date of birth;

2.3 job title and profession;

2.4 contact information such as email addresses and telephone numbers;

2.5 demographic information such as post code, preferences and interests;

2.6 financial information such as credit / debit card numbers;

2.7 IP address (automatically collected);

2.8 web browser type and version (automatically collected);

2.9 operating system (automatically collected);

2.10 a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

2.11 Cookie information (see our Cookie Policy);

2.12 health information you give us when you use our counselling or NDIS services, such as information about your health, wellbeing and history, and the notes your practitioner makes about your sessions; and

2.13 if you agree, audio and a written transcript of your counselling sessions made by an AI note-taking tool (see clause 3A).

3. Our Use of Data

3.1 Except for counselling and health records (see clause 3.5), any personal Data you submit will be retained by ATEC for as long as you use the Services and Systems provided on the Website. Data that you may submit through any communications System that we may provide may be retained for a longer period of up to one year.

3.2 Unless we are obliged or permitted by law to do so, and subject to clauses 3A, 4 and 4A, and any consent you give us, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.

3.3 All personal Data is stored securely in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Health Records Act 2001 (Vic). For more details on security, see Clause 9 below.

3.4 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

3.4.1 internal record keeping;

3.4.2 improvement of our products / services;

3.4.3 transmission by email of promotional materials that may be of interest to you, unless you opt out;

3.4.4 contact for market research purposes which may be done using email, telephone, fax or mail, unless you opt out. Such information may be used to customise or update the Website.

3.4.5 providing counselling, NDIS and other health services to you, including writing clinical notes;

3.5 Retention of counselling records

We keep counselling records for at least 7 years after your last session or, if you were under 18 when the information was collected, until you turn 25, as required by the Health Records Act 2001 (Vic). After this period, your records will be securely destroyed and will not be recoverable by us or anyone affiliated with ATEC.

3A. AI-assisted note-taking and session recording

3A.1 With your permission, your ATEC practitioner may use an AI note-taking tool to help write the notes about your counselling sessions. We use NovoNote, provided by NovoPsych Pty Ltd, an Australian company.

3A.2 There are two ways the tool may be used. With your consent, it can listen during a session (in person or by telehealth), turn the conversation into a written transcript, and draft a note. Or, after a session, your practitioner can speak or type a summary into the tool, which then drafts a note. Your voice is not recorded when your practitioner uses dictation after the session.

3A.2A We do not use the tool to record sessions with clients under 18. For clients under 18, the tool may only be used for dictation after the session, with the consent of a parent or guardian and the young person's agreement, or with the consent of a young person who is mature enough to make their own decisions. We do not record telehealth sessions when you are outside Victoria.

3A.3 We only record a session if you have given written consent, and we check again that you agree at the start of each session. Everyone taking part in the session must agree. You can say no, ask us to pause or stop the tool, or withdraw your consent at any time, by telling your practitioner or emailing enquiries@atec.vic.edu.au. Saying no will not affect your counselling, your fees or your bookings.

3A.4 Your practitioner checks and corrects every draft note before it is saved. The final note is kept in your counselling record in NovoPsych, our clinical records system, which stores client information in Australia, and kept as set out in clause 3.5. Our booking system, Acuity Scheduling, is used for bookings only and does not hold your counselling notes. The AI tool does not make decisions about you.

3A.5 The audio is deleted by the tool as soon as it has been transcribed. Transcripts and draft notes are deleted from the tool once your practitioner has saved the final note. We keep a record of the date they were deleted.

3A.6 NovoPsych stores client information in Australia. Before the AI drafts a note, names and other identifying details are removed by default. NovoPsych uses other AI service providers to draft notes. These providers may process the de-identified information outside Australia; see clause 4A. NovoPsych has told us it does not use your information, and does not allow its AI providers to use your information, to train AI models.

3A.7 We use the tool only to help write your clinical notes. We do not use recordings, transcripts or notes for any other purpose, such as training, research or marketing, without your separate consent.

3A.8 We do not use client information in free or public AI tools.

4. Service providers we use

4.1 We use trusted service providers to run our business. They may store or process your Data for us, but only so they can provide their service to us. They are not allowed to use your Data for their own purposes. They include:

4.1.1 Acuity Scheduling (online bookings, appointment reminders and booking forms);

4.1.2 Xero (invoicing and payments);

4.1.3 Microsoft 365 and OneDrive (email and secure file storage);

4.1.4 Zoom (telehealth and online training);

4.1.5 LearnWorlds (online courses);

4.1.6 NovoPsych (our clinical records system) and NovoNote by NovoPsych (AI note-taking, only if you agree, see clause 3A);

4.1.7 payment processors, and providers of website, search and marketing services.

4.2 We choose service providers that protect Data securely and we review them regularly. Any Data they process must be handled in line with this Policy, the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Health Records Act 2001 (Vic).

4.3 This Website may link to other websites. We are not responsible for their privacy practices.

4A. Data stored or processed outside Australia

4A.1 Some of our service providers store or process Data outside Australia. Based on what they tell us:

4A.1.1 Acuity Scheduling stores booking information, including your answers to booking forms, in the United States;

4A.1.2 Xero stores invoicing information in the United States;

4A.1.3 LearnWorlds stores online course information in Europe and the United States;

4A.1.4 NovoPsych and NovoNote store client information in Australia. De-identified text may be processed by its AI providers outside Australia;

4A.1.5 other providers we use, such as Microsoft 365 and Zoom, may store limited Data (such as contact details and meeting details) in Australia, the United States and other countries where those providers operate.

4A.2 Before we disclose personal information to a provider overseas, we take reasonable steps to make sure it is protected in a way that meets the Australian Privacy Principles. We keep your counselling notes in NovoPsych, in Australia.

5. Changes of Business Ownership and Control

5.1 ATEC may, from time to time, expand or reduce its business and this may involve the sale of certain divisions or the transfer of control of certain divisions to other parties. Data provided by Users will, where it is relevant to any division so transferred, be transferred along with that division and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the Data for the purposes for which it was supplied by you.

5.2 In the event that any Data submitted by Users will be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your Data deleted or withheld from the new owner or controller.

6. Controlling Access to your Data

6.1 Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

6.1.1 use of Data for direct marketing purposes; and

6.1.2 sharing Data with third parties.

6.1.3 No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

7. Your Right to Withhold Information

7.1 You may access certain areas of the Website without providing any Data at all. However, to use all Services and Systems available on the Website you may be required to submit Account information or other Data.

7.2 You may restrict your internet browser's use of Cookies. For more information see our Cookie Policy.

8. Accessing your own Data

8.1 You may access your Account at any time to view or amend the Data. You may need to modify or update your Data if your circumstances change. Additional Data as to your marketing preferences may also be stored and you may change this at any time.

8.2 You have the right to ask for a copy of your personal Data on payment of a small fee.

8.3 You can also ask us to correct your Data. We will respond within 30 days. Any fee for access will not be excessive, and there is no fee to make a request.

9. Security

Data security is of great importance to ATEC and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected online.

10. Changes to this Policy

ATEC reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.

11. Contacting Us

If there are any questions regarding this privacy policy you may contact us at:

• Email: enquiries@atec.vic.edu.au
• Post: PO Box 1024, Berwick VIC 3806
• Business: Kaptain Creative Pty Ltd (ABN 23 660 505 411, ACN 660 505 411) trading as Australian Trauma Education Centre (ATEC)

Our Privacy Officer is Samuel Tan, enquiries@atec.vic.edu.au.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (www.oaic.gov.au, 1300 363 992) or the Health Complaints Commissioner Victoria (hcc.vic.gov.au, 1300 582 113).

12. Automated decisions

12.1 We do not use computer programs or AI to make decisions about you that could significantly affect your rights or interests. AI tools may help our practitioners draft notes (clause 3A), but a person always checks the notes and makes every decision about your care.

Last updated: 26 October 2026