The use of AI
assisted documentation

At Comma + Co, we use Halaxy AI Scribe in place of manual in-session note-taking.

This allows your practitioner to remain present and attentive during counselling and executive coaching sessions while supporting accurate clinical documentation, timely reflection and a written recap after your appointment.

This page explains how the technology works, how your information is handled and what using AI-assisted documentation means when choosing to work with Comma + Co.

1. How AI is used at Comma + Co

Halaxy AI Scribe is integrated into our secure practice-management system.

During a session, it processes the conversation in real time and produces:

• A written transcription

• An AI-generated draft of the practitioner’s session notes

• Information used to prepare your post-session reflection and recap email.

The AI-generated material does not become part of your final record without human review.

Your practitioner reviews, corrects and edits the output before authorising the final notes. Your practitioner remains professionally responsible for the accuracy, relevance and appropriateness of your record.

AI does not make clinical decisions, diagnose you, determine treatment or replace the professional judgement of your practitioner.

• 2. An integral part of our practice model

AI-assisted documentation is a standard and integral part of how Comma + Co provides counselling and executive coaching.

We use it in place of writing or typing extensive notes during your appointment. This helps us give greater attention to the conversation while also providing accurate records and timely follow-up.

You will be given information about the use of Halaxy AI Scribe and asked to provide express consent before it is used.

If you do not consent to AI-assisted documentation, Comma + Co may not be the right service for you. We encourage you to raise any concerns before your first appointment so that we can discuss them openly.

Where AI-assisted documentation cannot be used, we will assess whether manual documentation is reasonably practicable in the circumstances. We cannot guarantee that a manual alternative will be available. If we are unable to offer or continue services without the AI scribe, we will explain this and, where appropriate, provide information about alternative practitioners or services.

• 3. What information is processed

Halaxy AI Scribe may process:

• The content of your counselling or coaching session

• Your name and other identifying information mentioned during the session

• Personal, professional, relationship or health information you choose to discuss

• Contextual information selected by your practitioner from your existing record

• The real-time transcription

• Generated draft notes and summaries

• Corrections and final notes authorised by your practitioner.

Payment-card details, account passwords, Medicare numbers and other unnecessary identifiers should not be stated during a session or included in the AI-generated notes.

If unnecessary sensitive information is captured, your practitioner will take reasonable steps to remove it from the final notes and manage it appropriately.

• 4. Audio and transcription

Halaxy states that its AI Scribe streams audio in real time to produce the transcription and does not save an audio recording.

A written transcription is created and stored within the relevant Halaxy appointment note. The transcription is used to generate structured notes and summaries.

Comma + Co configures transcriptions to be automatically deleted seven days after the transcription date. This period allows your practitioner to review the transcription, correct inaccuracies, finalise the session record and prepare your recap.

The reviewed clinical note and any final client recap form part of the practice record and are retained in accordance with applicable legal, ethical, professional and insurance requirements.

• 5. Human review and accuracy

AI-generated transcripts and summaries may contain errors, omit context or misinterpret what was said.

For this reason:

• Your practitioner reviews and edits the AI output

• AI-generated material is not treated as inherently accurate

• Only information considered relevant and appropriate is included in the final record

• Your practitioner remains responsible for the final clinical or coaching notes

• You may request correction of personal information you believe is inaccurate, incomplete, out of date, irrelevant or misleading.

The human-review safeguard refers to review by your practitioner. It does not mean that Halaxy personnel routinely read or review your session content.

• 6. Session reflection and recap emails

A timely written recap is included as part of the Comma + Co service.

Following your session, your practitioner uses the reviewed notes to prepare a plain-language email that may include:

• The main themes discussed

• Agreed reflections or observations

• Strategies or exercises considered during the session

• Actions you intend to take

• Resources or matters to revisit

• Relevant arrangements for your next appointment.

The recap is not intended to be a complete transcript or a substitute for the practitioner’s formal record.

Recaps are routinely prepared, but your practitioner may modify, delay or withhold a recap where sending one would be clinically inappropriate, unsafe, misleading or inconsistent with professional obligations.

The recap will be sent to the email address recorded for you. Email carries some residual privacy and security risk, particularly if other people can access your email account or device. You are responsible for providing an appropriate email address and taking reasonable steps to protect access to it.

• 7. How Halaxy handles information

According to Halaxy’s current published information:

• Australian client data is stored in Australia

• Information is encrypted in transit and at rest

• Session audio is streamed and is not stored by Halaxy AI Scribe

• AI-generated notes follow the access controls applied to the Halaxy account

• Information is accessible only to the practitioner and authorised practice users

• Patient information is not used to train Halaxy AI

• Halaxy AI data is not shared with third parties for AI processing

• Halaxy AI is integrated into the existing clinical-record system rather than requiring a separate external scribe account.

Comma + Co periodically reviews Halaxy’s privacy, security and AI documentation because technology, features and provider terms may change.

• 8. How information is used

Information processed through Halaxy AI Scribe is used to:

• Create and maintain accurate session records

• Reduce manual note-taking during appointments

• Support continuity between sessions

• Prepare your post-session reflection and recap

• Support professional supervision where appropriate

• Respond to safety, legal, professional or insurance obligations

• Manage requests for access, correction or complaints.

Your session content will not be used by Comma + Co for advertising or marketing.

Comma + Co will not use identifiable session information to train a public or general-purpose AI model.

• 9. Access and sharing

Access to your transcription, generated summaries and notes is controlled through Halaxy.

Information may be accessed by:

• Your practitioner

• Another authorised Comma + Co practitioner or practice user where access is reasonably required for their role

• A professional supervisor, using de-identified or minimally identifying information wherever practicable

• Another person or organisation where you have consented to the disclosure

• A person or authority where access or disclosure is required or authorised by law or is otherwise permitted under our confidentiality and privacy obligations.

Information will not be shared merely because another person requests it.

Where disclosure is necessary, Comma + Co will limit it to the information reasonably required for its purpose.

• 10. Privacy obligations and your rights

Comma + Co handles personal and health information in accordance with applicable privacy requirements, including:

• The Privacy Act 1988 (Cth)

• The Australian Privacy Principles

• The Health Records Act 2001 (Vic)

• Other state or territory privacy requirements where they apply.

You may:

• Ask questions about how AI-assisted documentation is used

• Request access to personal or health information held about you, subject to lawful exceptions

• Request correction of inaccurate, incomplete, out-of-date, irrelevant or misleading information

• Raise a concern or make a privacy complaint

• Withdraw consent to future use of the AI scribe.

Withdrawal of consent applies prospectively. It does not reverse processing that has already occurred or require the deletion of records that Comma + Co is legally, ethically or professionally required to retain.

If you withdraw consent, we will discuss whether manual documentation is reasonably practicable and whether Comma + Co can continue to provide the service appropriately.

• 11. Retention and deletion

Different parts of the record are handled differently:

Audio
Halaxy states that live audio is streamed for transcription and is not stored.

Transcription
The written transcription is temporarily retained in Halaxy and configured for automatic deletion seven days after it is created.

AI-generated drafts and summaries
Draft material may be regenerated, edited or deleted during the review process. It is retained only for as long as reasonably necessary to prepare and verify the final record and client recap.

Final notes and client recaps
Final notes and relevant communications are retained as part of the client record for the periods required by applicable law, professional standards and insurance obligations.

Ending services or withdrawing consent to future AI use does not automatically require Comma + Co to delete an existing health record.

• 12. Data breaches and security incidents

No digital system can be guaranteed to be completely secure.

If a suspected data breach occurs, Comma + Co will take reasonable steps to contain and assess it. If the breach meets the legal threshold for notification, affected individuals and the Office of the Australian Information Commissioner will be notified in accordance with the Notifiable Data Breaches scheme.

Where relevant, Comma + Co will also work with Halaxy and other appropriate parties to investigate and respond to the incident.

• 13. Benefits and limitations

Potential benefits include:

• Greater practitioner attention during the session

• Less interruption from manual note-taking

• More consistent documentation

• Timely recap emails

• Improved continuity between appointments

• Reduced risk of relevant information being omitted

• An opportunity to identify and correct inaccuracies.

Limitations and risks include:

• Transcription errors

• Loss of tone, nuance or context

• Inaccurate or incomplete AI-generated summaries

• Potential cultural or linguistic bias

• Residual privacy and cybersecurity risks

• The possibility that a client may feel less comfortable knowing the session is being transcribed.

These risks are managed through express consent, practitioner review, data minimisation, access controls, limited transcription retention and ongoing review of the technology.

• 14. Fees

There is no separate client fee for the use of Halaxy AI Scribe, practitioner review or the routine post-session recap.

Standard counselling or executive-coaching session fees apply.

• Questions or concerns

If you have questions or concerns about AI-assisted documentation, privacy or your session records, please contact:

Email:kr@commaandco.com.au
Text: 0468 030 092