Privacy Policy
Last updated 4 September 2026
Introduction
This is the Privacy Policy of Jennifer Cochran, trading as Harnessing Health, ABN 92 854 310 112. If you have any questions or need further information, please reach out to me: https://harnessinghealth.com.au/contact
I do not provide an office address, as I work from home in Perth, WA and wish to protect my family’s privacy.
I am committed to protecting your privacy, whether you are a contact, client, supplier or contractor of mine.
This document describes how I collect and manage your personal and sensitive information when you interact with my business. I take this responsibility very seriously. If you have any questions or concerns about how your personal or sensitive information is being handled, please do not hesitate to contact me.
I comply with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
Where applicable, I also aim to comply with the General Data Protection Regulations (GDPR).
Personal Information
If you engage with me via this website, or choose to become my client, I may ask to collect the following kinds of personal information from you, including:
your name, email address, mobile and/or phone number
the country that you live in or your home address
your opinion about future topics, products or services that may interest you
information that allows me to tailor my content to your needs when you sign up for one of my webinars or promotional events
your IP address, and information about your browsing history to help me improve the usability and appeal of my website (more information about this is found in the section on Cookies below)
if you are an employee or contractor, or propose working with me in that capacity, information about your qualifications, skills and work experience
if you are a supplier or prospective supplier, information about your business skills, services, products and prices
Collection & Use of Personal Information
Where practicable, I will only collect personal information about you directly from you or sources managed by you. However, in some circumstances I may obtain personal information from a third party. If this information is obtained contrary to this Privacy Policy and the Privacy Act, I will destroy or de-identify such information within a reasonable period.
I may collect your personal information by various means including when:
you contact me with a question, comment or inquiry
you subscribe to my newsletter
you attend a webinar, seminar or event where I am hosting or presenting
you correspond with me on a social media platform such as Facebook, LinkedIn, Instagram or similar sites
you opt in to receive a free resource from me or sign up for my newsletter
you book a consultation or purchase a product or service from me
you share general information relating to your business or personal life
you provide me with a testimonial
my website automatically collects information about you and your activities on my site (including cookies – more information on this is set out below)
a third-party supplies information to me, such as when you are referred or introduced to me by a mutual acquaintance
I may collect and use your personal information to:
respond to your enquiries
provide you with my products or services at your request
monitor or improve the use of and satisfaction with my website, products or services
share the latest news and developments relevant to my work
let you know about my expertise, and products or services that may be of interest to you
Unsubscribe
I may, from time to time, send you newsletters, invitations and updates about my services. I will only do so if you have requested to receive such communications through a double opt-in process. You can opt out of receiving any further such communications by replying to the message you received, or by clicking the “unsubscribe” option at the bottom of any marketing e-mail received from me.
I will only collect your information:
with your full awareness and consent, such as when you email me, tick a checkbox or fill in a form to provide me with information
if I need it to provide you with information or services that you request
if I am legally required to collect it
if collecting the information is necessary to preserve life or keep someone safe from harm
for necessary administrative processes if you become my client
if I believe that I can demonstrate a legitimate interest in using your data for marketing purposes, although I will always give you a choice to opt out
If you choose not to provide me with the information I need when requested to do so, it will impact my ability to provide you with the services that you request.
Sensitive Information
I understand that some information is particularly sensitive, and that you are trusting me to keep this information confidential.
The sensitive information I collect from you may include:
your date of birth and gender (with non-binary options)
your personal circumstances which are relevant to my work with you and the ways I might support you, such as: your relationships, occupation, emergency person contact details and name and contact details of other health service providers (e.g. doctor).
your presenting health conditions and symptoms, personal and family health history, medication details, wellbeing, lifestyle, diet, personal goals and treatments/services provided by other health service providers, including hospitals or specialists.
genetic information, genetic profiling results, nutrigenomic reports, functional testing results, pathology results, laboratory reports and other health-related test results that you choose to share with me or that are generated as part of our work together.
The reason why I collect your sensitive information is:
So that I can provide you with the services you have requested from me
To ensure that I am providing you with the most appropriate services
Secure Storage of Sensitive Information
I am committed to securely storing and handling your sensitive information.
STORAGE:
Sensitive information is stored securely in HealthBank, which meets the Australian Privacy Principles under The Privacy Act 1988. You can read their security measures and safeguards to obtain patient privacy and confidentiality here: https://help.healthbank.io/en/articles/3949654-what-security-measures-and-safeguards-does-healthbank-put-in-place-to-obtain-patient-privacy-and-confidentiality
Sensitive data may also be stored in password protected devices.
ACCESS:
Only I, the practitioner responsible for your treatment and any authorised support providers who assist me on a genuine need-to-know basis, have access to your sensitive information. I only access HealthBank on either a password protected computer or device with a high level of cybersecurity.
CLOUD STORAGE:
Sensitive information will be securely stored on HealthBank, which is a fully encrypted cloud platform (also refer to their security policy link, under ‘STORAGE’ above).
Some business-related files, messages, documents or device backups may be stored securely using iCloud or other password-protected cloud services. Where possible, sensitive client health records are stored in HealthBank or other purpose-selected clinical platforms.
Zoom webinar recordings will be stored in the cloud by Zoom. You can find out more about their security provisions in the section on Security below.
Collection of Information from Minors
All information collected from children under the age of 18 is classified as sensitive information.
Sensitive information may be collected from children under the age of 18 under the following circumstances:
In the presence of their parents
With their parent or guardian’s full consent
This information is collected for the sole purpose of providing services/products and is handled with heightened security. Parents/guardians can request access to, correction of, or deletion of their child’s information. Requests for deletion are considered on a case-by-case basis and may be subject to legal, professional, insurance, record-keeping or association requirements.
Destruction of Sensitive Information
I retain personal information only for as long as necessary to fulfil my obligations to you, or as required by law. Personal information for adults is archived for 7 years and for minors, 7 years after they turn 18 and then securely deleted or de-identified.
Archived data is reviewed annually, and any information no longer required is securely destroyed. Physical records are shredded, and digital records are permanently deleted from my systems, including backups.
Disclosure of Information
I may disclose your information if required under the following circumstances:
To provide you with the services you have requested
To send you products that you have purchased
Where disclosure is necessary to carry out your instructions, such as corresponding with someone else on your behalf, requesting pathology tests, ordering supplements etc. This may include sharing relevant information with pathology providers, functional testing laboratories, genetic testing providers, practitioner supplement dispensaries, product distributors, secure booking platforms, clinical documentation platforms and other providers involved in delivering the services you have requested.
Where I use support services to assist me in my business
To engage in professional supervision, although any information I share under these circumstances is de-identified to preserve client confidentiality
To refer you to other service providers at your request
You consent to me sharing relevant information, on a strictly need-to-know basis, with:
people you authorise me to correspond with, as reasonably required to carry out your instructions
my employees / subcontractors
third party providers who assist with
accounting
administration
archiving
auditing
business consulting
email marketing
invoicing and payment processing
legal or financial advice
professional supervision
website maintenance
technological services
Where I issue an invoice or payment link, limited personal and billing information, such as your name, contact details, invoice details, payment status and transaction information, may be processed by my invoicing, accounting or payment processing provider.
I will also disclose your information if required by law in response to a subpoena, discovery request or a court order, in compliance with mandatory reporting obligations, or in circumstances permitted by the Privacy Act – for example, where I have reasonable grounds to suspect that someone is engaging in unlawful activity, or misconduct of a serious nature, that relates to my work with you. I may also make a disclosure to an appropriate authority if I have serious concerns about your health, safety or wellbeing.
I will use all reasonable means to protect the confidentiality of your information while in my possession or control. I will not knowingly share any of your information with any third party other than the service providers who assist me with necessary business activities or the services I am providing to you. To the extent that I do share your information with third-party service providers, I only do so if I am satisfied that the service provider has a suitably protective privacy policy of their own, or they have signed a confidentiality agreement with me. Some of my service providers may be overseas and may not be subject to Australian Privacy Laws. You can find further information under the Security section below.
If you have any concerns regarding the disclosure of your information, please do not hesitate to get in touch with me to discuss this personally.
Security
I take reasonable physical, technical and administrative safeguards to protect your personal and sensitive information from misuse, interference, loss, and unauthorised access, modification and disclosure.
I manage risks to your information by:
storing files securely
ensuring that only I and trusted key subcontractors have access to sensitive information
releasing information to service providers on a strictly need-to-know basis
conducting regular audits of my security systems
Third Party Storage
As mentioned above, your information may also be stored with a third-party provider, where it will be managed under their security policy. The following security policies may apply during our work together:
• Fitgenes – https://www.fitgenes.com/privacy-consent-terms/?v=322b26af01d5
• Google Workspace - https://workspace.google.com/intl/en_au/security/
• Heidi Health - https://www.heidihealth.com/en-au/safety
• iCloud https://support.apple.com/en-us/102651
• i-screen - https://www.i-screen.com.au/blog/how-we-protect-your-data
• MailerLite - https://www.mailerlite.com/legal/security-statement
• Meta advertising tools, including Facebook and Instagram - https://www.facebook.com/business/m/privacy-and-data
• QuickBooks - https://quickbooks.intuit.com/au/security/
• Squarespace - https://www.squarespace.com/privacy
If you are communicating with me via electronic means such as email, Zoom, contact forms, Facebook or Instagram, I may not have full control over the transmission or storage of any personal information disclosed (although I try to employ best practice cybersecurity standards). You agree that by participating in such forms of communication you understand and accept that there is an inherent risk of disclosure or loss of your personal information for which I cannot be held responsible. If you are concerned about transferring particularly sensitive information, please ask me about alternative options that may be more secure.
AI Technology
I use AI-powered tools to enhance efficiency, support administration, improve documentation and assist with drafting educational or business-related content. These tools may assist with tasks such as note-taking, transcription, drafting, summarising, brainstorming, planning and improving communications.
I select AI tools with consideration of their privacy and security policies and use them in a way that is intended to align with the Australian Privacy Principles.
Heidi Health may be used as an AI-supported notetaking and transcription tool for consultation documentation. Heidi may assist with transcription, draft consultation notes, summaries and related clinical documentation. Before I first use Heidi Health in a consultation with you, you will receive a consent form for using Heidi Health as a supplementary documentation tool. You may opt out and are encouraged to discuss any concerns or questions with me. I may also confirm your consent verbally at the start of consultations where Heidi Health is used.
ChatGPT, Copilot or similar AI tools may be used for general drafting, summarising, brainstorming, website content, educational resources, business planning and improving communications. I do not intentionally enter identifiable client health information into general AI tools unless you have specifically consented or the information has been de-identified so that you cannot reasonably be identified.
AI-generated material is used as a support tool only. I remain responsible for reviewing, editing and finalising any notes, documents, recommendations or communications before they are relied on, stored in your client record, or shared with you.
Cookies
Cookies are small text files that are commonly used by websites to improve a user’s experience, collect statistics or marketing information and provide access to secure areas. My website uses cookies and tracking technologies to enhance user experience, analyse site performance and provide personalised content.
My website may use Meta/Facebook advertising tools, such as the Meta Pixel or similar tracking technologies, to help me understand how visitors interact with my website, measure the effectiveness of advertising, and show relevant advertisements to people who may be interested in my services. These tools may collect information about your visit to my website and may share that information with Meta in accordance with Meta’s own privacy and data policies.
You can choose to configure your browser settings not to accept cookies, but this may interfere with the functioning of this website.
Automated Decision Making
My business does not use fully automated decision-making processes that significantly impact customers. All key decisions are made with human oversight.
Access to Information
You can contact me to access, correct or update your personal information at any time. Please message me via either the Contact page of this website https://harnessinghealth.com.au/contact or HealthBank and expect a reply within 7 days. Unless I am subject to a confidentiality obligation or some other restriction on giving access to the information which permits me to refuse you access under the Privacy Act, and I believe there is a valid reason for doing so, I will endeavour to make your information available to you within 30 days.
Complaints
Complaint Procedure
If a breach of this Privacy Policy occurs, or if you wish to request a change to your personal information, you may contact me by sending a message outlining your concerns to me via the Contact Page of this website: https://harnessinghealth.com.au/contact
Complaint to External Body
If you are not satisfied with my response to your complaint, you may seek a review by contacting:
• The Office of the Australian Information Commissioner using the information available at http://www.oaic.gov.au/privacy/privacy-complaints
• The health ombudsman in your state or territory.
Notification of Change
When I update my Privacy Policy, I will post a copy of the revised policy on my website. It is your responsibility to check whether any changes have been made since your last visit.
Notification of Breach
If I have reason to suspect that an eligible data breach may have occurred, I will promptly assess the situation and take reasonable steps to contain the breach, reduce the risk of harm, and determine whether notification is required.
If I determine that a data breach is likely to result in serious harm, I will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.
Thank you!
This Privacy Policy was created with the support of Carefree Counsel. Copying it without permission is an infringement of copyright. Look after your business and your clients by creating your own legal documents.