TMRG Pty Ltd (ACN 697 921 574) trading as The Modern Recovery Group
Privacy Policy
Version 9.0 | Effective Date: June 2026
Governed by the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
1. About This Policy
TMRG Pty Ltd (ACN 697 921 574), trading as The Modern Recovery Group (TMRG, we, us, our), is committed to protecting your privacy and handling your personal and sensitive information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and applicable professional and ethical standards of the Australian Counselling Association (ACA).
This Privacy Policy explains how we collect, use, store, disclose and protect your information when you access our website, enquire about our services, or engage with us as a client.
Our Founder and Director, Jodi Lee Gordon, is an ACA Level 2 Registered Counsellor and Qualified Peer Support Practitioner and is bound by the ACA Code of Ethics and Practice in all client interactions.
2. Information We Collect
2.1 Personal Information
We collect personal information necessary to provide our services, including:
Full name, date of birth and contact details
Emergency contact details
General practitioner (GP) name and contact information
How you heard about TMRG
Service enquiries and correspondence
2.2 Sensitive Information (Health Information)
As a health service provider, we collect sensitive information including:
Mental health history and current presentation
Substance use history where relevant to counselling
Current medications
Previous counselling or therapeutic history
Session notes and clinical records
Goals, progress and outcomes within your program
We only collect the minimum amount of sensitive information reasonably necessary to provide our services with your express written consent. You will be asked to provide this consent through your intake form prior to your first appointment.
2.3 Website and Technical Information
When you visit our website, we may collect:
IP address and browser type
Pages visited and time spent on the website
Device and operating system information
Referral source (how you arrived at our website)
This information is collected via cookies and analytics tools. See Section 10 (Cookies) for full details.
3. How We Collect Your Information
We collect your information through the following means:
Website enquiry forms
Client intake forms (provided to you following initial assessment of your enquiry)
Direct correspondence via email or telephone
Cliniko, our practice management platform, through which appointments are booked and clinical records are maintained
Session notes created by your practitioner during or following appointments
4. Express Consent for Sensitive Health Information
In accordance with APP 3 and APP 6, we are required to obtain your express consent before collecting, using or disclosing sensitive information, including health information.
By completing and signing your intake form, you expressly consent to:
The collection of your sensitive health information for the purpose of providing counselling, peer support and related services
The storage of your information within Cliniko, a secure, healthcare-compliant practice management platform
The use of your information by your TMRG practitioner to plan, deliver and review your care
Disclosure of your information to third parties where required by law or where necessary to protect your safety or the safety of others
You have the right to withdraw consent at any time. Requests to withdraw consent should be made in writing. Withdrawal of consent may affect our ability to continue providing services to you.
5. Purpose of Collection
We collect and use your information to:
Assess your suitability for our services
Provide counselling, peer support and related services
Maintain accurate clinical records
Manage appointments and billing
Meet our legal, ethical and professional obligations
Contact you regarding your appointments or care
Respond to complaints or enquiries
6. Consequence of Non-Disclosure
If you choose not to provide the personal or health information requested by TMRG, we may be unable to:
Provide services to you
Assess your suitability for counselling or peer support
Manage risk appropriately
Meet our legal and ethical obligations as a registered health service provider
We will inform you if non-disclosure prevents us from providing all or part of our services.
7. Storage and Security
Your information is stored securely within Cliniko, a healthcare-compliant practice management platform. Cliniko maintains industry-standard security measures including encryption, access controls and regular security audits. In the event of a data breach involving personal information, TMRG will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act where applicable.
Clinical records and associated documentation are retained for a minimum of seven (7) years from the date of last service, in accordance with applicable health records legislation. Records relating to clients who were minors at the time of service are retained until the client turns 25, or for seven years from the date of last service, whichever is longer.
Access to your records is restricted to your TMRG practitioner and, where applicable, authorised personnel directly involved in your care.
8. Disclosure of Your Information
8.1 When We May Disclose
We may disclose your personal or health information in the following circumstances:
Where you have provided express written consent
Where disclosure is required by law (including mandatory reporting obligations)
Where there is a serious and imminent threat to your life or safety, or the life or safety of another person
To your nominated emergency contact or GP where clinically necessary and appropriate
To our clinical supervisor for the purposes of professional supervision (de-identified where possible)
8.2 Third-Party Platforms
We use third-party platforms in the delivery of our services, including:
Cliniko (practice management and secure client communications) cliniko.com
Zoom Workplace Pro (secure telehealth session delivery) zoom.us
Stripe (payment processing) stripe.com
Ventra IP (email and domain hosting) ventraip.com.au
Microsoft 365 (business email and document management) microsoft.com
Flodesk (email marketing and Community subscriber list management) flodesk.com
Squarespace (website and landing page hosting) squarespace.com
We may disclose your personal information to third-party platforms.
Email communication is not end-to-end encrypted. All sensitive clinical communications should be conducted through the Cliniko client portal. By engaging our services, you acknowledge the inherent security limitations of general email correspondence.
9. Cross-Border Disclosure
Some of the third-party platforms we use may store or process data on servers located outside Australia. By engaging our services, you expressly consent to the collection, use, storage and cross-border disclosure of your personal and sensitive health information in accordance with this Privacy Policy. By consenting, you acknowledge that the protections under APP 8.1 of the Privacy Act will not apply to those overseas recipients, and that you will not be able to seek redress under the Privacy Act in relation to the handling of your information by those recipients.
We take reasonable steps to ensure that any overseas recipients handle your information in a manner consistent with the Australian Privacy Principles.
10. Cookie Policy
10.1 What Are Cookies
Cookies are small text files placed on your device when you visit our website. They allow us to recognise your browser and collect information about how you use our website.
10.2 What Cookies We Use
We use the following types of cookies on our website:
Essential cookies required for the website to function
Analytics cookies to understand how visitors use our website
Functional cookies to remember your preferences and improve your experience
Marketing cookies if and when we run advertising campaigns (you will be notified if this changes)
10.3 Who Collects This Data
TMRG Pty Ltd collects cookie data. Analytics data may be processed by third-party tools. This data is used to improve our website and services and is not used to identify you personally without your consent.
10.4 Your Cookie Consent
When you first visit our website, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. Essential cookies cannot be disabled as they are required for the website to function. You may withdraw or change your cookie consent at any time through your browser settings.
11. Direct Marketing
We do not use your health information for direct marketing purposes.
We may use your personal information to send you direct marketing communications from time to time where you have given express consent to receive such communications. Direct marketing means promotional or advertising content about our services, offers or any other health-related content which is sent electronically to you. Any such direct marketing communications will be sent by email, SMS, push notification, or other electronic means. You may withdraw your consent to receive direct marketing at any time by following the unsubscribe instructions in the relevant communication. Your choice to opt in or out of direct marketing will not affect the provision of our services or any transactional communications you receive.
TMRG operates The Modern Recovery Community, a free subscriber list through which we send updates, news and communications to people who have opted in through our website. By subscribing to The Modern Recovery Community, you expressly consent to receiving email communications from TMRG. You may unsubscribe at any time using the unsubscribe link provided in any communication. Subscriber information is managed through Flodesk and is kept separate from clinical client records. Subscribing to The Modern Recovery Community does not constitute a service enquiry, establish a therapeutic relationship or create a duty of care.
12. Access and Correction
You have the right to access personal information we hold about you and to request correction of any information that is inaccurate, incomplete or out of date.
To make an access or correction request, please contact us using the details in Section 15. We will respond to your request within 30 days. In some circumstances, we may be unable to provide access to certain information. We will explain any such refusal in writing.
13. Privacy Complaints
13.1 Internal Complaints
If you have a concern or complaint about the way we have handled your personal information, please contact us in writing at privacy@themodernrecoverygroup.com. We will acknowledge your complaint within five (5) business days and respond substantively within 30 days.
13.2 External Complaints OAIC
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
Website: oaic.gov.au
Phone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001
14. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology or legal obligations. The current version will always be available at www.themodernrecoverygroup.com/privacy-policy. We encourage you to review this policy periodically.
15. Contact Us
For all privacy-related enquiries, access requests or complaints, please contact:
Privacy Officer
TMRG Pty Ltd, trading as The Modern Recovery Group
Email: privacy@themodernrecoverygroup.com
General enquiries: info@themodernrecoverygroup.com
Website: www.themodernrecoverygroup.com
This Privacy Policy is governed by the laws of New South Wales, Australia.
TMRG Pty Ltd | ACN 697 921 574 | info@themodernrecoverygroup.com | www.themodernrecoverygroup.com