Privacy Policy and Financial Consent

This document sets out how Steps2Life Care Pty Ltd (Steps2Life) handles personal and health information, and the financial terms and consents that apply to all Steps2Life services. It forms part of the Steps2Life Client Service Agreement and Terms and Conditions.

Part A: Privacy Policy

1. Privacy Policy and Collection Notice

Steps2Life respects client privacy and handles personal information and health information carefully. Health information is sensitive information. Steps2Life collects, uses, stores and discloses information so it can provide safe and appropriate services, communicate with authorised people, manage appointments and billing, comply with legal obligations, manage risk and improve service quality. Steps2Life handles personal and health information in line with the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Health Records and Information Privacy Act 2002 (NSW).

2. Information Steps2Life May Collect

Steps2Life may collect names, contact details, addresses, dates of birth, emergency contacts, Medicare details, funding details, payment details, referral information, health information, disability information, developmental history, medical history, medication information, allergies, risk alerts, school information, family information, assessment results, clinical notes, reports, care plans, behaviour information, communications, consent records, billing records, incident records, complaints, photographs, videos, recordings and information from other treating or supporting professionals.

3. How Information Is Collected

Information may be collected from the client, caregiver / authorised personnel, account holder, referrer, GP, specialist, school, childcare, allied health professional, support coordinator, plan manager, insurer, funder, support worker, caregiver or other relevant person where appropriate and lawful. Information may also be collected through phone calls, emails, SMS, intake and referral forms, online forms on the Steps2Life website, the client portal and telehealth.

4. Why Information Is Collected, Used and Held

Steps2Life uses information to assess suitability for services, provide therapy and clinical support, plan appointments, prepare reports, communicate with relevant people, manage safety and risk, coordinate care, manage billing and payments, respond to complaints, comply with legal obligations, maintain records, improve service quality and run the practice.

5. Disclosure of Information

Steps2Life may disclose relevant information to treating clinicians, administrative staff who need access, referrers, GPs, specialists, allied health professionals, schools, childcare providers, support coordinators, plan managers, insurers, funding bodies, emergency services, regulators, complaint bodies, legal advisers, debt recovery providers, IT providers, practice management providers and other people or organisations where consent has been provided, disclosure would be reasonably expected, disclosure is required or authorised by law, or disclosure is necessary to prevent or lessen a serious threat to health, safety or welfare.

6. Limits of Confidentiality

Steps2Life will keep information confidential except where disclosure is consented to, reasonably expected, required or authorised by law, required for billing or service delivery, necessary for professional advice or business operations, or necessary to address a serious threat to health, safety or welfare. Confidential information may also be required by subpoena, court order, regulator request or legal process.

Steps2Life may contact emergency services, police, child protection, regulators, medical practitioners or other authorities where required by law or where reasonably necessary to prevent or lessen a serious threat to health, safety or welfare.

7. Digital Systems, AI Tools, Recordings and Transcription

Steps2Life uses secure practice systems to manage client records, appointments, billing, telehealth, forms and clinical documentation. This may include cloud-based systems, secure communication platforms, AI-enabled note-taking tools, transcription tools, recording tools, summarisation tools or documentation-support software. These tools may be used for practical clinic purposes such as taking or preparing clinical notes, producing session summaries, supporting report writing, keeping accurate records, managing billing, improving service quality and meeting compliance obligations.

Steps2Life will take reasonable steps to use appropriate privacy and security settings and to limit information entered into these systems to what is reasonably necessary for the relevant purpose. If identifiable health information needs to be recorded, transcribed or entered into an AI-enabled or recording tool that requires specific consent, Steps2Life will seek that consent or rely on another lawful basis where available. Clients may ask how these systems are used and may withdraw consent where withdrawal is legally and practically available. Withdrawal may affect documentation, telehealth, communication, note-taking, reporting or support options.

Some of the systems Steps2Life uses may store or process information outside Australia. Where this occurs, Steps2Life will take reasonable steps to make sure the information is protected in line with the Australian Privacy Principles.

8. Photographs, Video and Clinical Media

Steps2Life may use photographs, video or other clinical media where consented to or legally permitted. Clinical media may be used for assessment, therapy planning, reports, training of family, caregivers / authorised personnel, home programs, supervision, quality review or service delivery. Steps2Life will not use identifiable client media for marketing without separate express consent.

9. Security and Storage

Steps2Life will take reasonable steps to protect personal and health information from misuse, interference, loss, unauthorised access, modification or disclosure. Steps may include secure systems, passwords, access controls, staff training, lockable storage, secure disposal, encrypted systems, role-based access and confidentiality obligations.

10. Access and Correction

Clients may request access to or correction of their personal information. Steps2Life may need to verify identity before providing access. Steps2Life may refuse or limit access where the law allows. Reasonable fees may apply for copying, retrieval or transfer where permitted by law. Requests can be made to Steps2Life reception on 1300 009 006 or admin@steps2life.com.au.

11. Record Retention

Steps2Life will retain clinical and business records for the period required by applicable laws, professional obligations, insurance obligations and operational needs. Records may be retained longer where legally, clinically or operationally appropriate.

12. Privacy Complaints

Privacy complaints should be raised with Steps2Life management by phone on 1300 009 006, by email at admin@steps2life.com.au, or using the Steps2Life Feedback Form. Steps2Life will review the concern and respond within a reasonable time. If you are not satisfied with the response, you may contact the Office of the Australian Information Commissioner (oaic.gov.au, 1300 363 992) or the NSW Health Care Complaints Commission (hccc.nsw.gov.au, 1800 043 159).

Part B: Financial Terms

13. Account Holder Responsibility

By attending our services, the client or authorised personnel (the Account Holder) confirms they are the person legally and financially responsible for payment of all fees under the Client Service Agreement. If more than one person signs or accepts responsibility as Account Holder, they are jointly responsible for all amounts owing to Steps2Life, to the extent permitted by law. This includes appointment fees, assessment fees, report writing, non-face-to-face clinical support, travel, cancellation fees, non-attendance fees, payment processing costs where disclosed and legally permitted, and any other amounts payable under the agreement. The Account Holder remains liable for all fees if funding is exhausted, suspended, incorrectly allocated, or cannot be claimed for any reason.

The Account Holder must:

disclose all funding, payment pathways and third-party payment arrangements they want Steps2Life to consider or use;
not arrange services with other providers using the same allocated funding where this may prevent Steps2Life being paid for its services (if this occurs, the Account Holder remains liable for payment);
notify Steps2Life promptly if funding changes, is used elsewhere, becomes insufficient, expires, is suspended, is exhausted or is no longer available; and
monitor available funds, service limits, budgets, approvals, plan dates, claim rules, service categories, invoices and payment status. Steps2Life may assist with information where reasonable, but is not responsible for managing the client’s funding unless expressly agreed in writing.

Steps2Life provides services to the client, not to any funding body or third-party payer. Any funding source is a payment pathway only. If a funding source does not pay the full amount owing for any reason, including because funds have run out, the plan has ended, the budget category is exhausted, a plan manager refuses payment, or an insurer rejects the claim, the Account Holder must pay the outstanding amount.

14. Fees

Fees are set out in the price tables for each funding type in the Client Service Agreement. All fees are exempt from GST. All fees are subject to change in line with updates to the relevant funding scheme rates (such as NDIS, Medicare, DVA and workers compensation fee schedules), business operating requirements and market conditions. Clients will be given reasonable notice of any fee changes by email.

15. Billing Consent

By signing the Client Service Agreement, clients provide ongoing consent for Steps2Life to charge for the services outlined below where required for their care. Separate approval will not be sought for each individual item. All services will be billed in accordance with the NDIS Pricing Arrangements and Price Limits.

Face-to-face service provision, including:

Appointments delivered in the clinic, community or home, or via telehealth.
Formal and informal assessments.

Non-face-to-face clinical support, where directly related to the participant’s care, goals and outcomes. These activities may include:

Time taken to travel to a meeting or appointment, up to 30 minutes of the standard NDIS travel rate, as well as kilometres, parking, tolls, public transport, waiting time, access delays and other reasonable travel-related costs;
Developing individualised client resources and materials;
Report writing and clinical documentation, including documentation outside of formal assessments;
Telephone calls and emails with the participant, family/carers, care team and other relevant stakeholders;
Attendance at stakeholder and multidisciplinary meetings, including meetings with schools, support coordinators and other health professionals;
Family or carer meetings for education, consultation and training;
Session preparation and post-session follow-up;
Researching resources, equipment or treatment approaches specific to the participant’s needs; and
Reviewing reports or clinical information provided by other practitioners.

Other chargeable items, including:

Sessions cancelled under the Cancellation Policy, including where a client attends visibly unwell and the clinician cannot safely proceed.
Leave of 2 weeks or more and up to 2 months, where the client wishes to hold their regular appointment time.
Disengagement when ending services or moving to another service provider, consisting of a 2.5-hour allocation per enrolled service: the first 1 hour and 15 minutes is a session concluding therapy, reviewing progress and providing closure, and the second 1 hour and 15 minutes is non-face-to-face clinician time for file closure, the final progress note, a summary of sessions and progress, and handover where required.
Urgent, priority or expedited services, which may attract an additional reasonable fee where accepted by Steps2Life and disclosed where practicable. Urgent reports (less than 2 weeks’ notice) attract an additional 1.5 hours.

Steps2Life will not charge for:

Administrative telephone calls or emails relating solely to appointment scheduling, rescheduling or confirmation.
Booking enquiries and general administrative correspondence.
Invoicing, payment processing or billing enquiries.
Providing standard practice information, such as fees, clinic locations or clinician availability.
Internal administrative tasks that are not directly related to the participant’s clinical care or outcomes, such as preparing the service agreement.

16. Payment Terms by Funding Type

Funding type	How payment works
Private and self-funded	Payment is due at the time of appointment or by the invoice due date using an approved payment method.
NDIS self-managed	The Account Holder pays Steps2Life directly at the time of appointment or by invoice, then manages any reimbursement claim separately.
NDIS plan-managed	Steps2Life may invoice the plan manager where accepted, but the Account Holder remains responsible for unpaid, rejected, delayed or partly paid invoices.
NDIA agency-managed	Steps2Life claims payment directly from the NDIA through the NDIS portal, and a service booking may be created with the Account Holder’s consent. If a claim is rejected, funding is exhausted, the plan has ended or the NDIA does not pay for any reason, the Account Holder remains responsible for the unpaid amount.
Medicare	The client pays the full fee at the time of appointment. Steps2Life can process the Medicare rebate at the time of the appointment so it can be paid back to the client, if eligible, into their designated account. The Account Holder remains responsible for the full fee and any gap, rejected rebate or unpaid amount.
Private health insurance	Where HICAPS or private health claiming is available, Steps2Life may process an eligible claim at the time of appointment. The Account Holder must pay any gap at the time of appointment, and any amount the insurer rejects, delays or only partly pays. Cover limits and eligibility are the client’s responsibility.
DVA	Steps2Life claims directly from the Department of Veterans’ Affairs where the client holds a valid Gold Card, or a White Card with an accepted condition that covers the service, and a current GP referral is in place. If DVA does not pay for any reason, the Account Holder remains responsible for the unpaid amount.
Workers compensation	Steps2Life invoices the insurer where a claim number, case manager details and any required insurer approval have been provided and accepted. Services beyond approved limits, or after a claim is declined, disputed or closed, remain payable by the Account Holder.
Aged care packages	The Account Holder must provide approval, provider details, available budget and any required authorisation before services are provided. If the provider does not pay, funds are exhausted, approval is missing or the claim is rejected, the Account Holder remains responsible for the unpaid amount.
Other third-party payers	Steps2Life may invoice an approved third-party payer (including schools, employers, organisations and DCJ) only where written approval, claim details or purchase order information is provided and accepted. If the payer does not pay in full, the Account Holder remains responsible for any unpaid amount unless Steps2Life agrees otherwise in writing.
Cash	Cash may be accepted only where Steps2Life permits it for the service or location. A receipt will be issued or recorded. Cash payment does not remove the need to keep an approved payment method on file unless Steps2Life gives a written exemption.

17. Collection Policy

Steps2Life requires a card on file to begin services. All invoices are payable within 7 days of issue, unless otherwise stated on the invoice or agreed in writing. Payment may be collected by EFTPOS, approved card payment, bank transfer or cash. If an invoice remains unpaid 21 days after issue, Steps2Life will automatically charge the outstanding balance to the payment method stored on file.

If the stored payment method cannot be charged and the invoice remains unpaid beyond 21 days, Steps2Life may refer the account to a debt collection agency or recovery process. The Account Holder is responsible for all reasonable debt collection and legal recovery costs, to the extent those costs are legally recoverable. Where a third-party payer, such as a plan manager, insurer or funding body, does not pay within these timeframes, the Account Holder remains responsible for the outstanding amount.

18. Stored Payment Method and Automatic Payment Authority

The Account Holder must provide and maintain a valid credit card, debit card or other approved payment method securely on file through Steps2Life’s payment provider, merchant facility or practice management system, unless Steps2Life gives a written exemption. Stored payment details will be handled using the systems and security controls of the relevant third-party payment processor and in accordance with applicable privacy, payment, card scheme and merchant facility requirements.

The Account Holder authorises Steps2Life to automatically charge the stored payment method for missed payments, failed payments, overdue invoices, cancellation fees, no-show fees, gap payments, funding shortfalls, rejected third-party invoices, urgent or priority service fees, and any other amounts owing under the Client Service Agreement. Steps2Life may process the payment without seeking separate approval each time, provided the amount is payable under the agreement. Steps2Life will keep records of invoices, due dates, failed payments, overdue amounts, third-party non-payment and amounts charged to the stored payment method, and will provide invoices or receipts in the ordinary course of billing. Where practicable, Steps2Life may provide notice before or after processing an automatic payment, but failure to provide separate notice does not prevent Steps2Life from charging an amount that is payable.

The Account Holder must not initiate a chargeback, payment reversal or payment dispute for a validly issued invoice or authorised charge without first contacting Steps2Life and giving Steps2Life a reasonable opportunity to review and resolve the issue.

19. Failed Payments, Overdue Accounts and Suspension of Services

If a payment fails, is dishonoured, reversed or charged back, the Account Holder remains liable for the debt and must provide an alternative payment method promptly. Steps2Life may charge reasonable bank dishonour fees, card surcharges, transaction fees or payment processing costs where those amounts have been disclosed and are legally permitted.

If an invoice is not paid by the due date, Steps2Life may send a reminder, contact the Account Holder or third-party payer, request updated payment details, require payment before further bookings, review the service arrangement, suspend non-urgent services, or refer the matter for debt recovery where legally permitted. If the Account Holder has three missed, failed, dishonoured or overdue payments, Steps2Life may stop, pause, suspend or decline further services until the account is brought back into good standing. Stopping or pausing services does not cancel the debt, and the Account Holder must continue making weekly catch-up payments until the overdue balance is paid in full.

Steps2Life may require payment in advance before booking, continuing or resuming services where funding is low or uncertain, invoices are overdue, a payment has failed, there has been repeated late cancellation or non-attendance, a third-party payer has not paid, or Steps2Life reasonably considers there is a payment risk. Steps2Life does not need to wait for a third-party payer to formally reject an invoice before requiring payment from the Account Holder in these circumstances.

The Account Holder must not withhold payment or set off amounts owing because of a complaint, dispute, funding delay or third-party payer issue, except for amounts Steps2Life agrees in writing are genuinely disputed. Any undisputed amount remains payable by the due date.

20. Debt Recovery

If amounts remain unpaid, Steps2Life may refer the overdue account to a debt collection agency, solicitor, court, tribunal or other lawful recovery process. The Account Holder agrees to pay all reasonable debt collection costs, legal fees, court fees, enforcement costs and other recovery expenses that Steps2Life incurs in recovering overdue amounts, to the extent those costs are legally recoverable. Steps2Life may provide relevant account, invoice, contact and service information to its debt recovery providers, insurers, professional advisers or legal representatives for this purpose.

21. Your Consent

This document is for information only and does not need to be signed. Clients and Account Holders give their privacy and financial consents when they sign the Steps2Life Client Service Agreement. If you have any questions about this document, please contact Steps2Life reception on 1300 009 006 or admin@steps2life.com.au.