Privacy & Personal Information

Privacy Policy

Your privacy matters.

Shifting Lives provides counselling, coaching, education and related services. In doing so, we may handle personal information and, where relevant to providing counselling or another health service, sensitive information including health information.

We recognise that this information deserves a high level of confidentiality, security and care.

Our privacy practices are designed to operate in accordance with applicable Australian privacy and health-information requirements, including the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Notifiable Data Breaches scheme, and applicable State and Territory privacy and health-record legislation.

Last updated: 24 October 2026

In plain language

We aim to collect only what we reasonably need, protect the information you give us, keep counselling information appropriately confidential and be transparent about how personal information is handled.

On this page

1. Our privacy principles

Shifting Lives is committed to responsible, transparent and proportionate handling of personal information. Our approach is to:

  • collect only information reasonably necessary for our services;

  • treat health and other sensitive information with particular care;

  • explain why information is collected and how it may be used;

  • use personal information only for appropriate and lawful purposes;

  • maintain reasonable technical and organisational security measures;

  • limit access to people who reasonably require the information;

  • provide mechanisms for people to request access to or correction of their information;

  • respond appropriately to privacy concerns and suspected data breaches; and

  • regularly review our privacy practices as the organisation develops.

2. Information we may collect

Depending on how a person interacts with Shifting Lives, we may collect information including:

  • name and contact details;

  • correspondence and enquiries;

  • information required to establish or maintain a counselling or professional relationship;

  • information about why a person is seeking counselling or support;

  • relevant health and wellbeing information;

  • disability information where relevant;

  • relationship or family information where relevant;

  • information provided during counselling;

  • appropriate professional or counselling records;

  • information reasonably required to manage safety, legal or professional obligations; and

  • basic technical website information such as IP address, browser, device and website security information.

Shifting Lives seeks to collect only information that is reasonably necessary for the relevant purpose.

3. Health and sensitive information

Health information is treated as sensitive information under Australian privacy law. Where Shifting Lives provides counselling or another health-related service, relevant health information may need to be collected so the service can be provided appropriately.

Sensitive information will generally be collected directly from the person concerned and with consent, unless Australian law permits or requires otherwise.

Before sending sensitive information online

The public Shifting Lives website is not intended to act as a repository for extensive clinical records or detailed health information.

Please avoid including unnecessary sensitive or clinical information in a general website enquiry.

Where more detailed information is required, it can be discussed directly with David or collected through an appropriate professional intake process.

4. How we collect information

Personal information may be collected when a person:

  • contacts Shifting Lives;

  • submits a website enquiry;

  • communicates with Shifting Lives by email, telephone or another method;

  • becomes a counselling or coaching client;

  • provides information during a professional session;

  • provides information reasonably required for administration of the service; or

  • otherwise chooses to provide information.

Where reasonable and practicable, information is collected directly from the person concerned.

In appropriate circumstances, information may also be provided by an authorised representative, family member, partner, guardian, referring practitioner or another person legitimately involved in the relevant service.

5. Why we use personal information

Shifting Lives may use personal information to:

  • respond to enquiries;

  • communicate with current and prospective clients;

  • provide counselling and related services;

  • understand why a person is seeking support;

  • maintain appropriate professional records;

  • administer the professional relationship;

  • manage safety, professional and legal obligations;

  • respond to privacy requests, concerns or complaints; and

  • maintain the operation and security of the Shifting Lives website and business systems.

Personal information will not ordinarily be used for an unrelated purpose without consent unless that use is otherwise permitted or required by Australian law.

6. Confidentiality and disclosure

Confidentiality is an important part of the counselling relationship. Information disclosed during counselling will generally be treated as confidential. However, confidentiality is not necessarily absolute.

Information may be used or disclosed where:

  • the person has consented;

  • the use or disclosure is permitted in connection with the purpose for which the information was collected;

  • disclosure is required or authorised by Australian law or a court or tribunal;

  • disclosure is reasonably necessary to lessen or prevent a serious threat to life, health or safety and the requirements of applicable Australian law are satisfied; or

  • another permitted circumstance under applicable privacy or health legislation applies.

Where disclosure is necessary, Shifting Lives seeks to limit the information disclosed to what is reasonably necessary in the circumstances.

7. Marketing and health information

Shifting Lives does not use identifiable counselling records or health information for advertising or audience targeting.

Sensitive information, including health information, will not simply be treated as a general marketing database. Any future marketing and advertising infrastructure must be appropriately separated from counselling and clinical information.

8. Current website systems

What the Shifting Lives website does today

The current website provides information about:

  • David Chittenden;

  • counselling;

  • Evolutionary Therapy;

  • coaching;

  • educational resources;

  • videos;

  • articles;

  • accessibility;

  • crisis and external support resources; and

  • ways to contact Shifting Lives.

At the date of this Privacy Policy, the Shifting Lives website does not provide an integrated automated appointment-booking system, online payment system, AI counselling system, automated client-matching system or member/community platform.

These capabilities may be considered during later stages of development. Before introducing a system that materially changes how personal or health information is collected, stored, used or disclosed, Shifting Lives will review the relevant privacy, security and professional requirements and update this policy and any relevant collection notices.

9. Website hosting and overseas processing

The current public Shifting Lives website is built using Framer. Modern website infrastructure can involve service providers operating internationally. Framer B.V. is based in the Netherlands, and its cloud infrastructure may involve processing in the United States.

As a result, some website-related personal or technical information may be processed outside Australia. Shifting Lives takes reasonable steps to use reputable technology providers and considers applicable Australian privacy requirements when personal information may be handled outside Australia.

Public website infrastructure

General website hosting, uptime and technical delivery via Framer.

Sensitive counselling and clinical information

Not intentionally stored within the public website platform.

Appointment booking

Cal.com — appointment booking. When you use Cal.com to book an accessibility consultation or audit walkthrough, Cal.com processes the information needed to make and manage your booking, such as your name, email address, selected time and any information you enter in the booking form. Cal.com is based in the United States and processes booking data there. Some of its service providers may process data in other countries.

10. Security

Shifting Lives takes reasonable technical and organisational steps to protect personal information from:

  • misuse;

  • interference;

  • loss;

  • unauthorised access;

  • unauthorised modification; and

  • unauthorised disclosure.

The appropriate safeguards depend on the type and sensitivity of the information involved. Sensitive counselling and health information requires a higher level of protection than ordinary public website information. Access to personal information should be limited to people who reasonably require it for an authorised purpose.

11. Retention and disposal

Personal information is retained only for as long as reasonably required for the purpose for which it is held or as required by applicable:

  • legal obligations;

  • professional obligations;

  • health-record requirements; or

  • other legitimate record-retention requirements.

Professional counselling records may have different retention requirements from ordinary website enquiries or administrative information.

Where personal information is no longer required and there is no lawful reason to retain it, Shifting Lives will take reasonable steps to securely destroy or de-identify it.

12. Access to your information

People may ask Shifting Lives for access to personal information held about them. Shifting Lives may need to verify the person’s identity before providing access.

Access may be limited or refused in circumstances permitted by applicable Australian law. Where appropriate and legally permitted, the reason for refusing access will be explained.

13. Correction of information

People may ask Shifting Lives to correct information they believe is:

  • inaccurate;

  • out of date;

  • incomplete;

  • irrelevant; or

  • misleading.

Shifting Lives will take reasonable steps to consider and respond to correction requests in accordance with applicable Australian privacy requirements.

14. Data breaches

Shifting Lives maintains processes for responding to suspected:

  • loss of personal information;

  • unauthorised access; or

  • unauthorised disclosure.

Where required, suspected data breaches will be investigated and assessed in accordance with Australia’s Notifiable Data Breaches scheme. Where the applicable notification threshold is met, Shifting Lives will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

15. Automated systems and artificial intelligence

Shifting Lives does not currently use automated decision-making systems to determine a person’s access to counselling or make significant clinical decisions about them.

Shifting Lives may explore AI-assisted or automated services during future development phases. Before introducing any future system involving personal or health information, appropriate consideration must be given to:

  • privacy;

  • security;

  • consent;

  • professional responsibilities;

  • clinical governance where relevant;

  • access controls;

  • data storage and retention;

  • human oversight;

  • overseas processing; and

  • applicable Australian law.

This Privacy Policy will be updated where required before materially different AI or automated information-handling practices are introduced.

16. Australian privacy requirements

Australian privacy framework

Shifting Lives’ privacy practices are designed to operate in accordance with applicable Australian privacy and health-information requirements, including:

  • Privacy Act 1988 (Cth)

  • Australian Privacy Principles (APPs)

  • Notifiable Data Breaches scheme

  • applicable State and Territory privacy and health-record legislation

As a provider of counselling and health-related services, Shifting Lives recognises the particular responsibilities associated with handling sensitive health information.

Additional State or Territory requirements may apply depending on where and how a service is provided. Where those requirements apply, Shifting Lives will seek to handle information consistently with those obligations.

17. Privacy complaints

A person who believes their personal information has not been handled appropriately may contact Shifting Lives. Please provide enough information for the issue to be understood and investigated.

Shifting Lives will take privacy concerns seriously and seek to respond within a reasonable period. If you are not satisfied with the response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Visit the OAIC website

An appropriate State or Territory privacy, health privacy or complaints authority may also have jurisdiction in some circumstances.

18. Contacting Shifting Lives about privacy

Privacy enquiries

You can contact Shifting Lives about:

  • accessing your personal information;

  • correcting your personal information;

  • a privacy concern;

  • a privacy complaint; or

  • a question about this Privacy Policy.

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19. Changes to this policy

Privacy compliance is an ongoing responsibility. Shifting Lives will review this Privacy Policy as:

  • services change;

  • technology changes;

  • information-handling practices change;

  • new third-party systems are introduced; or

  • applicable Australian privacy requirements change.

This policy will specifically be reviewed before introducing integrated:

  • appointment booking;

  • online payments;

  • digital intake systems;

  • advertising or advanced analytics involving personal information;

  • member/community functionality;

  • multi-practitioner systems;

  • clinical record systems; or

  • AI-assisted services.

This policy was most recently updated on 24 October 2026.

20. Counselling enquiries and bookings

What we collect when you enquire.

  • Your first name and (optionally) last name, email address, and (optionally) phone number.

  • How you'd like us to contact you (email or phone).

  • The kind of counselling you're asking about (individual, couples, family or not sure).

  • The website page you sent the enquiry from.

  • That you agreed to our service consent, with the time we recorded it and the version of this notice you were shown.

  • When you submitted the form.

  • That the enquiry is for our counselling service.

  • A marketing-consent value, which is always "no".

The form does not ask for, and cannot send, any information about your health, history or circumstances.

The safety question. When you contact us about counselling, we first ask whether your enquiry involves an immediate safety concern, crisis, or domestic or family violence.

  • Your answer only changes what the page shows you, such as urgent support services and options for safe contact. It is never sent to us or stored.

  • Your answer to this question does not prevent you from asking Shifting Lives to contact you. If you later tell us that no contact method is safe, we will not send a contact request. If you answer "Yes / I'm not sure" or "Prefer not to say", or you ask for discreet contact, you can send a restricted contact request instead of the standard enquiry (see "Discreet or restricted contact requests" below).

Why we collect it. To respond to your enquiry, follow it up using the contact method you chose, and help you book.

Booking. You can book a session directly on HotDoc, an external online booking service, either straight away or after you send an enquiry. HotDoc passes your booking to our clinical record and appointment system, Cliniko. HotDoc may also send you its own booking confirmations and reminders, and HotDoc's own privacy policy applies to the information you give HotDoc. If you need discreet contact, please use our Contact page and ask for discreet contact instead.

Discreet or restricted contact requests. If you ask for discreet contact, or the page offers you a restricted contact request, we collect only what we need to contact you safely:

  • a name we can use;

  • the email address and/or phone number you want us to use;

  • your preferred contact method (email, phone call or SMS);

  • an optional time and the time zone it refers to;

  • whether we may leave a voicemail or use the word "counselling" in messages;

  • an optional short note about how to contact you safely.

Please don't tell us about your health, a crisis or a family-violence situation in that note.

How we handle a restricted request:

  • It is sent to our staff as an email to our business mailbox, support@shiftinglives.com.au. That email, and any messages we exchange with you about it, stay in that mailbox only. They are not forwarded to anyone's personal email.

  • It is not added to our customer-relationship, booking or mailing tools.

  • It is never used for marketing or advertising.

  • We don't send you any automatic email or text message. We contact you only by the method and at the time you choose.

  • When we've finished following up, we close the request. After we close the request, we keep the messages only while they are reasonably needed for follow-up. We review them for deletion no later than 90 days after closure, and may delete them sooner when they are no longer needed. We may retain them for longer if required by law, or where reasonably necessary to deal with a complaint, dispute, consent question or another documented operational or legal matter.

  • We also keep a short record that the request was received and closed. It holds no name or contact details.

Service messages (not marketing). We send you service messages only about your own enquiry or booking. They all come from support@shiftinglives.com.au:

  1. an automatic acknowledgement that we received your enquiry;

  2. a personal follow-up from our staff, by the contact method you chose;

  3. if you book an online session, an email from our staff with your session time and joining link.

Staff create each online session by hand and send the link themselves. The link is not kept in our enquiry or contact systems.

Our staff may also get an internal reminder to follow up. That reminder contains a reference number only, not your name or contact details, and nothing is sent to you because of it.

Marketing. We do not send marketing to counselling enquirers. Making an enquiry never adds you to a mailing list, and our records show your counselling marketing consent as "no".

Stopping contact and withdrawing consent.

  • You can withdraw your consent for us to contact you about your enquiry at any time by emailing support@shiftinglives.com.au. We will then stop following it up.

  • If you already have a booking, we may still need to contact you about that booking until it is cancelled.

  • Withdrawing consent does not delete records we must keep.

Access, correction and deletion.

  • To ask for a copy of the personal information we hold about you, to ask us to correct it, or to ask us to delete your enquiry record, email support@shiftinglives.com.au.

  • We may need to confirm who you are before we act.

  • We will respond within a reasonable time, and usually within 30 days. There is no charge for making a request.

  • Clinical records held in Cliniko are subject to separate professional record-keeping obligations and may not be deletable on request.

Health and sensitive information.

  • The fact that someone asks about counselling, and the kind of counselling they ask about, may itself be sensitive. We treat enquiry records accordingly: staff access only, and no copies into marketing tools.

  • Our standard enquiry form has no free-text box. A restricted contact request has one optional short note (up to 200 characters), for instructions on how to contact you safely only.

  • Details about your health, your circumstances and your sessions are held only in our clinical record system, Cliniko. They are never entered into our enquiry or contact systems.

  • Our internal staff dashboard shows enquiry references, enquiry status, the kind of counselling asked about, and appointment times, types and set-up status. It shows no names, contact details or clinical information.

Online sessions. Online sessions are arranged by our staff by hand. A staff member creates the session and emails you the joining link from support@shiftinglives.com.au. The calendar entry used to run the session has a neutral title and does not include your name.

Who handles your information.

  • Framer: Hosts our website and the enquiry form. The form sends your enquiry straight to n8n; Framer does not store it. Where your information is stored: United States (Amazon Web Services), with additional hosting infrastructure in Europe and Asia-Pacific and a worldwide content-delivery network

  • n8n: Our form service: checks each enquiry, records it in ActiveCampaign and sends our service emails. A restricted contact request is not recorded in ActiveCampaign: n8n emails it to our staff and keeps only a status record without your name or contact details. Holds appointment times and types (no names) for our staff task list. Where your information is stored: European Union (Germany), on Microsoft Azure

  • ActiveCampaign: Our contact system for enquiries (service only; no counselling marketing). Where your information is stored: United States

  • Google Workspace (Gmail): Our email (support@shiftinglives.com.au) and staff sign-in; the calendar our staff use to run online sessions. Where your information is stored: Google data centres in more than one country, which may include the United States. Our Google plan does not let us choose a storage region

  • HotDoc: Online booking. Where your information is stored: Australia. HotDoc says some of its own service providers are in the United States and the United Kingdom

  • Cliniko: Our clinical record and appointment system. Where your information is stored: Australia. Cliniko says some of its own service providers are located overseas, mainly in the United States

Overseas disclosure. Some of your information is stored or processed outside Australia: in the United States (ActiveCampaign, Framer, and possibly Google), in Germany (n8n), and by overseas service providers that HotDoc and Cliniko use (United States and United Kingdom).

Security.

  • Our enquiry form sends only a fixed list of fields and rejects anything else.

  • Our staff dashboard requires a verified staff Google sign-in, and does not show client names, email addresses or phone numbers.

How long we keep it.

  • Pre-booking enquiry records are reviewed for deletion 90 days after your enquiry is closed. An enquiry is closed when you book, when you tell us you are not going ahead, or when we close it because we have not heard back from you.

  • Restricted contact requests are kept and reviewed as described under "Discreet or restricted contact requests" above.

  • Deletion is subject to any legal, consent-evidence, dispute or legitimate operational reason to keep a record. Two examples: to respect an unsubscribe request, or because you also use another Shifting Lives service.

  • Records are not deleted automatically. A staff member reviews each one before anything is deleted.

  • Where we keep a contact record, we keep the record of the consent you gave and the notice you were shown.

  • This applies only to enquiry records. Clinical records, notes and appointments in Cliniko are kept separately, under health record-keeping obligations.

Questions and complaints. Email support@shiftinglives.com.au. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC).

Urgent support. Our enquiry form and email are not monitored for emergencies. Call 000, or Lifeline on 13 11 14. See our urgent-support page.

Your information matters

Have a question about your privacy?

If you would like to understand how Shifting Lives handles your personal information, request access or correction, or raise a privacy concern, you are welcome to contact us.

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