Privacy Policy


Our Commitment to Your Privacy

At Pathways to Performance, we hold your personal privacy in the highest regard. Protecting the confidentiality of your data is not just a legal requirement for us; it is a core component of the professional service we provide.

"Personal information" refers to any data or opinions we maintain, whether in digital databases or physical files, that could reasonably identify you. This typically includes details like your name, contact information and demographics, which we use to ensure our services are delivered accurately and efficiently.

We recognise that when you share your information with us, you are placing your trust in our team. We take that responsibility seriously and are committed to transparency regarding how that data is managed and shared.


Data Collection Methods

Pathways to Performance generally collects information directly from you. We only gather what is strictly necessary to provide our products, deliver our services or manage our internal business operations.

Common ways we collect data include:

  • Digital or physical application and intake forms.
  • Telephone consultations and inquiries.
  • Website contact requests.
  • In-person interactions.

We ensure all data collection is performed through lawful, fair and non-intrusive means.


Use and Disclosure of Information

Our primary goal in collecting your data is to provide you with seamless access to Pathways to Performance services. This information helps us refine our customer support and build a stronger professional relationship with you.

Beyond our primary services, we may use your information for essential business functions, such as:

  • Internal administration and accounting.
  • Meeting regulatory and legal compliance standards.
  • Fraud prevention and security monitoring.
  • Identifying new Pathways to Performance services or updates that may specifically benefit you.

On occasion, we partner with external service providers to handle specific business functions (such as IT support or logistics). In these instances, our contracts strictly forbid these providers from using your data for any purpose other than the specific task they were hired to perform.

Occasionally, we may also collect, use or disclose your personal information for the secondary purpose of facilitating the distribution of marketing materials to you by Pathways to Performance. We will not do this if you ask us not to do so.

There are other situations where we are compelled by law to disclose your personal information. For instance, under certain circumstances we may be compelled to provide your personal information to law enforcement agencies.


Consent and Legal Obligations

Your privacy is protected by a duty of confidentiality. We will only disclose your information outside of Pathways to Performance if:

  1. Required by Law: Such as responding to a subpoena or reporting to the Australian Taxation Office.
  2. Public Interest: Where a crime, fraud or misdemeanour is committed or suspected and disclosure against the client’s rights to confidentiality is justified.
  3. With Your Consent: This may be explicit (written/verbal) or implied (based on your actions, such as signing up for a service).


Data Security and Accuracy

We strive to keep your records precise. If you notice that the information we hold is outdated or incorrect, please notify us so we can update it immediately.

To protect your data from unauthorised access, loss or misuse, Pathways to Performance employs industry-standard security protocols and operational safeguards. While the internet allows us to serve you more conveniently, we treat your online security with the same rigor as our face-to-face interactions.


Storage of Personal Information

All client personal and health information is securely stored using industry-standard clinical systems to ensure confidentiality, integrity, and protection of your data.

Client records, including contact details, appointment history, clinical notes, and billing information, are stored within Halaxy, a secure, cloud-based practice management system designed for healthcare providers. Halaxy utilises strong encryption protocols, secure data storage, and controlled access permissions. The system is compliant with applicable Australian privacy legislation, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Halaxy also aligns with international security standards, including ISO 27001-aligned practices for information security management.

Clinical notes may be created using Heidi Health, a secure clinical documentation support system that assists with dictation and note-taking. Heidi Health is designed specifically for healthcare environments and implements robust security measures including end-to-end encryption, secure data handling, and strict access controls. Heidi Health complies with relevant privacy and health data protection laws, including the Privacy Act 1988 (Cth) and Australian Privacy Principles, and adheres to internationally recognised standards such as HIPAA (Health Insurance Portability and Accountability Act) compliance for handling sensitive health information.

Both systems are selected to ensure that your personal and health information is managed in accordance with best-practice privacy, confidentiality, and cybersecurity standards.


Your Rights: Accessing Your Information

You have the right to request access to the personal information we hold about you. To help us process this efficiently, please be as specific as possible about the records you require. We aim to respond to all access requests within 30 days.

While we do not charge for the request itself, we may charge a reasonable fee to cover the administrative costs of retrieving and providing the data. In rare cases, such as when access would infringe on the privacy of others or pose a legal risk, we may decline a request as permitted by law.


Contact Us

For specific questions regarding our privacy practices, please contact the Pathways to Performance team directly.

For broader information on privacy rights in Australia, you can contact the Office of the Australian Information Commissioner (OAIC):

  • Web: www.oaic.gov.au
  • Phone: 1300 363 992