Consultation Privacy Policy

Wellness Creative / Stephen Brumwell
ABN: 74 901 057 015
ANTA Member No. 20048
Effective date: 1 July 2026

1. Introduction

SJB Creative trading as Wellness Creative, operated by Stephen Brumwell (“Wellness Creative”, “I”, “me” or “my”), respects your privacy and is committed to protecting your personal and health information.

Stephen Brumwell provides naturopathic and nutritional services and is a member of the Australian Natural Therapists Association Ltd (“ANTA”), Member No. 20048.

This Privacy Policy explains how I collect, hold, use and disclose personal information when you:

    • visit stephenbrumwell.com;

    • contact me through my website, email, telephone or social media;

    • book or participate in a naturopathic or nutrition consultation;

    • complete a health questionnaire, intake form or consent form;

    • provide pathology results, medical records or other health information;

    • purchase or enquire about my services; or

    • otherwise interact with Wellness Creative.

I handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, applicable health-record requirements and relevant professional obligations.

2. Personal information I collect

The information I collect depends on the nature of your interaction with Wellness Creative.

General personal information

I may collect:

    • your full name;

    • date of birth;

    • pronouns or gender where relevant to your care;

    • residential or postal address;

    • telephone number;

    • email address;

    • emergency contact details;

    • appointment and booking information;

    • payment, invoice and transaction information;

    • correspondence and enquiries;

    • consent records; and

    • technical information relating to your use of my website.

Health and sensitive information

When you enquire about or receive naturopathic or nutrition services, I may collect sensitive health information including:

    • your symptoms, health concerns and treatment goals;

    • medical, surgical and family history;

    • current or previous medical diagnoses;

    • medications, supplements and herbal products you use;

    • allergies, intolerances and adverse reactions;

    • dietary habits and nutritional information;

    • sleep, stress, exercise and lifestyle information;

    • alcohol, smoking or substance-use history where relevant;

    • mental and emotional wellbeing information where relevant to your care;

    • reproductive, hormonal or sexual health information where clinically relevant;

    • pathology reports, test results and medical correspondence;

    • information provided by your doctor or another healthcare practitioner;

    • consultation notes, clinical assessments and observations;

    • treatment plans, recommendations and progress notes; and

    • other information reasonably required to provide safe and appropriate care.

I only collect information that is reasonably necessary to provide my services and generally obtain your consent before collecting sensitive health information.

3. How I collect your information

I usually collect information directly from you when you:

    • create or update a client record in Cliniko;

    • make an online booking through Cliniko;

    • complete an intake, consent or health-history form;

    • submit an enquiry through my website;

    • communicate with me by email, telephone, video call or social media;

    • participate in a telehealth consultation;

    • provide pathology reports or other health records;

    • make a payment through Square; or

    • complete a feedback form or questionnaire.

With your permission, I may also collect information from:

    • your general practitioner;

    • another health practitioner;

    • a pathology or testing provider;

    • your parent, guardian, carer or authorised representative; or

    • another person involved in your healthcare.

In limited circumstances, information may be collected without your direct consent where collection is required or authorised by law or reasonably necessary to address a serious threat to health or safety.

4. Why I collect and use your information

I may collect, hold and use personal information to:

    • respond to enquiries;

    • assess whether my services are suitable for you;

    • schedule, confirm and manage appointments;

    • provide naturopathic and nutrition consultations;

    • understand your health history, symptoms and treatment goals;

    • prepare personalised nutrition, lifestyle, herbal or supplement recommendations;

    • monitor your progress and adjust recommendations;

    • maintain appropriate clinical and business records;

    • communicate with you about your care;

    • send appointment confirmations and reminders;

    • process payments and issue invoices or receipts;

    • communicate with other practitioners involved in your care, where authorised;

    • manage and improve my website and services;

    • meet ANTA membership, professional, insurance and record-keeping obligations;

    • comply with taxation, legal and regulatory requirements;

    • manage complaints, disputes or legal claims;

    • protect the health or safety of you or another person; and

    • send educational or promotional communications where you have consented or where otherwise permitted by law.

Your health information will not be used for unrelated marketing without your express consent.

5. Cliniko bookings and clinical records

Wellness Creative uses Cliniko, operated by Red Guava Pty Ltd, to manage:

    • online bookings;

    • client contact details;

    • appointment information;

    • intake and consent forms;

    • clinical and consultation notes;

    • treatment plans;

    • health documents and attachments;

    • appointment confirmations and reminders;

    • invoices and payment records; and

    • telehealth consultations.

The primary Cliniko account data for Australian accounts is hosted in Australia.

Cliniko may use carefully selected third-party service providers, including providers located outside Australia, to support functions such as cloud infrastructure, email delivery, customer support, monitoring, SMS notifications and video consultations.

These providers may process limited information where reasonably necessary to provide their services. Cliniko maintains its own privacy, security and data-processing policies regarding how information is protected.

By booking a consultation or using the Cliniko patient portal, you acknowledge that your information will be handled through Cliniko for the purposes described above.

6. Telehealth consultations

Telehealth consultations are provided through Cliniko’s telehealth functionality.

Telehealth involves the electronic transmission of personal and health information. I take reasonable steps to:

    • use secure and reputable systems;

    • conduct consultations in a private environment;

    • protect access to client records;

    • use appropriate passwords and account security; and

    • avoid unnecessary disclosure of health information.

You are responsible for selecting a private location and taking reasonable steps to prevent others from overhearing or viewing your consultation.

Telehealth consultations are not ordinarily audio-recorded, video-recorded or transcribed.

If I propose using any recording, transcription or artificial-intelligence note-taking service, I will explain its purpose and seek your consent beforehand. You may decline such recording or transcription.

Although reasonable safeguards are used, no internet, email, telephone or video-conferencing system can be guaranteed to be completely secure or uninterrupted.

7. Disclosure of information

I do not sell or rent personal or health information.

I may disclose information where reasonably necessary to:

    • Cliniko for booking, clinical-record and telehealth services;

    • Square for payment processing;

    • website, email, hosting, accounting or technology providers;

    • healthcare practitioners involved in your care, where authorised;

    • pathology laboratories or testing providers where testing has been requested;

    • your parent, guardian, carer or authorised representative;

    • ANTA, my professional insurer or another professional body where reasonably required to manage a complaint, professional matter or insurance claim;

    • my accountants, legal advisers or other professional advisers;

    • government bodies, regulators, courts or law-enforcement agencies where required or authorised by law; or

    • another person where disclosure is reasonably necessary to prevent or lessen a serious threat to life, health or safety.

Where practical, I will seek your consent before sharing health information with another practitioner.

Service providers are only given access to information reasonably necessary to perform their functions and are expected to handle that information appropriately.

8. Overseas processing and disclosure

Wellness Creative’s primary client and clinical records are maintained through an Australian Cliniko account, with primary account data hosted in Australia.

However, Cliniko and other technology providers may use overseas-based subprocessors to provide limited supporting functions such as:

    • cloud infrastructure;

    • video-call functionality;

    • email and SMS delivery;

    • technical monitoring;

    • customer support;

    • system security; and

    • error reporting.

As a result, limited personal information may be processed or accessed outside Australia, including in the United States or United Kingdom.

Square and other website or communications providers may also process information in accordance with their own infrastructure, privacy policies and international operations.

I take reasonable steps to select reputable providers and limit the information disclosed to what is reasonably necessary for the relevant service.

9. Payments through Stripe

Payments are processed through Stripe.

When you make a payment, Stripe may collect and process information including:

    • your name;

    • contact details;

    • payment-card information;

    • transaction amount;

    • transaction date;

    • payment method;

    • device or technical information; and

    • information required for security, fraud prevention and regulatory compliance.

Wellness Creative does not ordinarily receive or store your complete payment-card number.

Stripe processes payment information in accordance with its own privacy notice, security standards and terms of service.

I may retain limited payment information, including the payment amount, transaction status, invoice, receipt and refund details, for accounting, taxation and business-record purposes.

10. Storage and security

I take reasonable steps to protect personal and health information from:

    • misuse;

    • interference;

    • loss;

    • unauthorised access;

    • unauthorised modification; and

    • unauthorised disclosure.

Safeguards may include:

    • secure Cliniko client records;

    • password-protected devices and accounts;

    • multi-factor authentication;

    • restricted access to clinical information;

    • reputable website, payment and cloud-service providers;

    • software and security updates;

    • appropriate account permissions;

    • secure disposal of records; and

    • appropriate data backups.

Information is primarily stored electronically. Limited information may also be retained in physical form where reasonably necessary.

While reasonable precautions are taken, no storage or communication system can be guaranteed to be entirely secure.

11. Retention of clinical records

Clinical and consultation records are retained for as long as reasonably necessary to:

    • support continuity of care;

    • comply with legal and professional obligations;

    • meet ANTA membership and professional-insurance requirements;

    • satisfy taxation and business-record obligations; and

    • respond to complaints, disputes or legal proceedings.

As a general practice, adult clinical records may be retained for at least seven years from the date of the last consultation.

Where a client was under 18 years of age at the time of treatment, records may be retained until the client reaches 25 years of age, or for at least seven years after the last consultation, whichever results in the longer period.

Records may be retained for a longer period where required by law, ANTA, a professional insurer or the particular circumstances of the client’s care.

Once information is no longer reasonably required, I will take reasonable steps to securely destroy it or permanently de-identify it.

12. Website information, cookies and analytics

When you visit my website, certain technical information may be collected automatically, including:

    • your IP address;

    • browser and device type;

    • operating system;

    • pages viewed;

    • referring website;

    • approximate location;

    • date and time of access; and

    • interactions with the website.

The website may use cookies, analytics services and similar technologies to improve functionality, understand website use and measure the effectiveness of content or advertising.

You may block or delete cookies through your browser settings. Disabling cookies may affect how parts of the website function.

Third-party website and analytics services operate under their own privacy policies and data-handling practices.

13. Contact forms and email

Information submitted through my website contact form is used to respond to your enquiry and, where appropriate, arrange a consultation or provide services.

Ordinary email is not always a secure communication method. Please avoid sending highly sensitive information by email where an alternative secure option is available.

Health documents and detailed clinical information should preferably be provided through Cliniko or another method agreed with me.

Do not use the website contact form, email or Cliniko messaging for medical emergencies or urgent medical concerns.

14. Marketing communications

I may send newsletters, educational material, service announcements or promotional communications where:

    • you have subscribed;

    • you have provided consent; or

    • the communication is otherwise permitted under applicable law.

You may unsubscribe at any time by using the unsubscribe option in the communication or contacting me directly.

Booking confirmations, appointment reminders, payment communications and information relating to your treatment are administrative communications and are not considered marketing.

15. Minors and authorised representatives

Where services are provided to a person under 18, I may collect information from both the young person and their parent or legal guardian.

The involvement of a parent or guardian will depend on:

    • the young person’s age;

    • their maturity and capacity;

    • the nature of the service;

    • applicable legal and professional requirements; and

    • what is reasonably necessary to provide safe and appropriate care.

Where another person communicates on your behalf, I may request evidence that they are authorised to access or discuss your information.

16. Accessing your information

You may request access to personal or health information I hold about you.

Requests should be made in writing using the contact details below. I may ask you to verify your identity before releasing information.

Access may be restricted or refused where permitted by law, including where disclosure would:

    • create a serious threat to someone’s life, health or safety;

    • unreasonably affect another person’s privacy;

    • relate to anticipated or existing legal proceedings; or

    • otherwise be unlawful.

Where access is refused, I will generally explain the reason unless legally prevented from doing so.

A reasonable administrative fee may apply where permitted, particularly for extensive retrieval, printing, copying or transfer requests. You will be advised of any proposed fee beforehand.

17. Correcting your information

You may ask me to correct information that is inaccurate, incomplete, out of date, irrelevant or misleading.

Clinical records generally cannot simply be deleted or rewritten. Where appropriate, a correction, clarification or supplementary note will be added while preserving the integrity of the original clinical record.

You may also update certain contact or booking information through Cliniko.

18. Data breaches

If a suspected privacy or data-security incident occurs, I will take reasonable steps to:

    • contain the incident;

    • assess what information was affected;

    • reduce the risk of harm;

    • investigate the circumstances; and

    • prevent a similar incident from occurring again.

Where an incident is likely to result in serious harm and notification is required under the Notifiable Data Breaches scheme, affected individuals and the Office of the Australian Information Commissioner will be notified as required.

19. Anonymity and pseudonyms

You may interact with me anonymously or through a pseudonym where lawful and practical.

However, accurate identifying and health information will generally be required to:

    • provide safe and personalised consultations;

    • maintain appropriate clinical records;

    • process bookings and payments;

    • issue invoices or other documentation; and

    • communicate with other practitioners where authorised.

I may be unable to provide clinical services if you do not provide information reasonably necessary for your care.

20. Third-party services and websites

My website or client communications may contain links to Cliniko, Square, social-media platforms or other third-party services.

Third parties operate under their own privacy policies, security practices and terms. I am not responsible for the privacy practices, security or content of third-party websites outside my reasonable control.

You should review the relevant provider’s privacy policy before supplying personal information.

21. Privacy complaints

If you have concerns about how your personal or health information has been handled, please contact me using the details below.

Please provide sufficient information for me to understand and investigate your concern. I will endeavour to acknowledge and respond to privacy complaints within a reasonable period.

If you are not satisfied with my response, you may contact:

Office of the Australian Information Commissioner
Website: oaic.gov.au
Telephone: 1300 363 992

Depending on the nature of the matter, you may also be able to contact:

Australian Natural Therapists Association Ltd
Website: anta.com.au

or another relevant healthcare complaints body, professional insurer or regulator.

22. Contact details

Privacy Contact: Stephen Brumwell
Business: SJB Creative (Trading As Wellness Creative)
ABN: 74 901 057 015
ANTA Member No.: 20048
Website: stephenbrumwell.com
Email: stephen@stephenbrumwell.com

23. Changes to this Privacy Policy

I may update this Privacy Policy to reflect changes to:

    • my services;

    • Cliniko, Square or other technology providers;

    • business or clinical practices;

    • professional requirements; or

    • Applicable laws.

© Copyright 2026. Stephen Brumwell. (ABN) 74 901 057 015. Wellness Creative is a Brisbane-based graphic design studio specialising in branding, web and packaging design for health and wellness brands, clinics and practitioners across Australia. All work produced is subject to these Terms & Conditions
Theme: Overlay by Kaira.