Informed consent + privacy.

At Comma + Co, your autonomy, dignity, privacy and safety are central to our work together.

We begin every counselling or coaching relationship with transparency. You should understand how we work, what you can expect, the choices available to you and how your personal information will be handled.

Informed consent is not a one-off formality. It is an ongoing conversation that supports trust, clarity and your right to make informed decisions about the services you receive.

1. Why informed consent matters

Your autonomy matters
You have the right to make informed decisions about your counselling or coaching at every stage.

Your safety matters
Ethical practice includes clear professional boundaries, appropriate confidentiality and responsible handling of your information.

Your consent matters
You may ask questions, revisit your consent or withdraw consent at any time. If withdrawing consent affects our ability to provide a service safely or lawfully, we will explain this to you.

2. Understanding informed consent

Informed consent means that you understand and agree to the nature of the counselling or coaching services being offered before those services begin and as the work continues.

This includes information about:

• The purpose and scope of the service

• Whether you are receiving counselling or executive coaching

• The approaches that may be used

• Potential benefits, limitations and reasonably foreseeable risks

• Available session formats

• Fees, payment arrangements and cancellation terms

• Professional boundaries and responsibilities

• Confidentiality and its limits

• How your information and records are managed

• Your rights, choices and responsibilities.

Counselling and executive coaching are distinct services. The purpose, scope and boundaries of your particular service will be explained before you begin.

Consent is collaborative and ongoing. You are encouraged to ask questions, raise concerns or tell us when something does not feel right for you.

3. Before services begin

Before commencing counselling or coaching, you will receive information about:

• The nature and scope of the service

• The practitioner’s role, qualifications and scope of practice

• The approaches that may be used

• Session arrangements and communication between sessions

• Fees, billing and cancellation policies

• Confidentiality and its limits

• Record-keeping and privacy practices

• How to raise a question or concern.

You will also receive an informed consent form to review and accept before services commence.

Depending on your needs and the agreed scope of the work, counselling may draw on approaches such as Cognitive Behavioural Therapy, Acceptance and Commitment Therapy, Internal Family Systems-informed work and other evidence-informed or professionally recognised approaches.

No particular approach will be imposed on you. You may ask why an approach is being suggested, decline an activity or request that we pause and discuss another way forward.

4. Confidentiality and its limits

Information you share during counselling or coaching is treated as confidential. Confidentiality is not absolute, and information may be used or disclosed without your consent where this is required or authorised by law, or where another recognised legal or ethical exception applies.

This may include circumstances involving:

• A serious threat to your life, health or safety, or to another person

• Concerns about the safety or wellbeing of a child or young person

• Information-sharing or reporting obligations that apply under Victorian or Commonwealth law

• A court or tribunal order, subpoena or other lawful requirement

• The investigation of a complaint or the defence of a legal claim

• Another circumstance in which disclosure is permitted or required by law.

Any disclosure will be limited to the information reasonably necessary for its purpose.

Where it is safe, lawful and practicable to do so, we will discuss the situation with you before disclosing information. There may be circumstances in which prior discussion is not possible or appropriate.

5. Professional supervision

Professional supervision is an essential part of ethical counselling practice. A practitioner may discuss aspects of their work with a qualified supervisor to support safe, reflective and accountable practice.

Only information reasonably necessary for supervision will be discussed, and identifying details will be removed or minimised wherever practicable. Professional supervisors are also required to maintain confidentiality.

6. Working with other people or services

With your consent, we may collaborate with another professional, support person or organisation involved in your care or wellbeing.

Where separate authorisation is appropriate, we will explain:

• Who the information will be shared with

• What information may be shared

• Why the information is being shared

• How long the authorisation will remain in effect.

You may amend or withdraw this authorisation. Withdrawal applies to future use or disclosure and cannot reverse information sharing that has already lawfully occurred.

We may also use carefully selected service providers to operate the practice, including practice-management, appointment, communication, payment and technology providers. These providers may process or store information on our behalf and are expected to handle it in accordance with applicable privacy and security requirements.

7. Privacy and data protection

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

• The Privacy Act 1988 (Cth)

• The Australian Privacy Principles

• The Health Records Act 2001 (Vic)

• The Victorian Health Privacy Principles.

Our practices are also informed by the ethical and professional standards applying to counselling practice.

Information we collect

We collect information reasonably necessary to provide services and operate the practice. Depending on your relationship with us, this may include:

• Your name and contact details

• Identity and emergency-contact information

• Appointment and billing information

• Intake and assessment information

• Relevant health, personal and relationship information

• Session and clinical notes

• Correspondence, referrals and reports

• Information required to respond to a safety concern, complaint or legal obligation.

Where practicable, information will be collected directly from you. If information is received from another person or organisation, we will take reasonable steps to ensure you are aware of this where required.

How we use information

Your information may be used to:

• Provide and manage counselling or coaching services

Communicate with you about appointments or services

• Maintain appropriate professional records

• Process accounts and payments

• Support professional supervision and quality of practice

• Manage safety, legal, insurance and professional obligations

• Respond to requests, concerns or complaints

• Administer and securely operate the practice.

We do not sell client information.

8. Storage and security

Comma + Co uses Halaxy as its principal practice-management system. Halaxy states that its Australian client data is stored in Australia and provides security and access-control features for health practices.

Electronic records are protected using reasonable administrative, technical and physical safeguards. Access is restricted to practitioners and other authorised people who require it for their role.

Where paper records are created, they are stored securely and protected from unauthorised access.

No electronic system can be guaranteed to be completely secure. If an eligible data breach occurs, we will respond in accordance with applicable legal requirements, including the Notifiable Data Breaches scheme where it applies.

9. Accessing or correcting your information

You may request access to the personal or health information we hold about you. You may also ask us to correct information you believe is inaccurate, incomplete, out of date, irrelevant or misleading.

Access or correction may be limited in circumstances permitted by law, including where providing access would create a serious threat to someone’s safety or unreasonably affect another person’s privacy.

We may need to verify your identity before responding. If access or correction cannot be provided in the form requested, we will explain the decision and consider whether another form of access or an appropriate notation can be provided.

Requests will be handled within the timeframes required by applicable law.

10. Retention and disposal

Client records are retained for the periods required by applicable legislation, professional standards and insurance obligations.

Withdrawing consent or ending services does not generally require Comma + Co to delete records that must be retained for legal, ethical, clinical or insurance purposes.

When information is no longer required and there is no obligation to retain it, it will be securely destroyed or de-identified in accordance with applicable requirements.

11. Your choices and rights

At any time, you may:

• Ask questions about your service, consent or privacy

• Ask why particular information is being collected

• Revisit or update your consent

• Decline a proposed counselling activity or approach

• Request access to or correction of your information

• Withdraw an authorisation for future information sharing

• Withdraw consent to continue counselling or coaching

• Raise a concern or make a complaint

• End services.

Choosing to pause or end counselling or coaching will not affect your right to respectful and ethical treatment.

12. Questions, requests or concerns

If you have a question about informed consent, privacy or how your information is handled, please speak with your practitioner or contact:

Email:kr@commandco.com.au

We aim to acknowledge enquiries and complaints within five business days.

If you are not satisfied with our response, you may also contact:

• The Office of the Australian Information Commissioner

• The Victorian Health Complaints Commissioner

• The practitioner’s relevant professional association, where applicable.