Privacy Policy

Effective date: 10 January 2024

When you use or, you’re trusting us to handle your personal information with care. We take that trust seriously. This Privacy Policy describes how Pamela Douglas Consulting, trading as Dr Pam and the Possums programs, and The NDC Institute, collects, uses, discloses, and protects your personal information when you use our online websites and courses.

This Privacy Policy applies to

  • Pamela Douglas Consulting (“Us”, “We”, “NDCI”, “Possums programs”, “our”, “PDC”) trading as The NDC Institute and Dr Pam and the Possums programs and its subsidiaries and related bodies corporate, including Pamela Douglas Consulting Pty Ltd.

This Privacy Policy has been developed in compliance with

  • the Privacy Act 1988 (Cth) (Australian Privacy Act) and the Australian Privacy Principles (APPs) made under that Act.

1. Key privacy points

We hope you read this entire Privacy Policy for full detail. But if you choose not to, here are some key points

  • Our money comes from you, not from ads. As a subscription / purchase based for-purpose business, we rely on your purchases from our websites
  • Other people and platforms may sell your data for advertising. We do not, and never will
  • We would only process data about you and your use of our content so we can learn what you are interested in, serve you the best possible experience, and communicate with you
  • We use a small number of trusted online software systems, such as Google analytics and third-party payment processors, to help optimise and deliver our websites
  • We honour all your requests to exercise privacy rights

In this Privacy Policy

  • Privacy Act means, in respect of Pamela Douglas Consulting, the Australian Privacy Act
  • Privacy Principles means, in respect of Australia, the Australian Privacy Principles made under the Australian Privacy Act.

Pamela Douglas Consulting maintains a policy of strict confidence concerning your (you, your) personal information (Privacy Policy). This Privacy Policy applies to the collection, storage, use and disclosure of your personal information by us. By accessing the following Websites and platforms (Websites), you accept the terms of this Privacy Policy

Australian Websites


This Privacy Policy applies to information provided to us whether via these Websites, in connection with the product or services we offer, or by any other means and demonstrates our policies, procedures and practices for compliance with the Privacy Principles under the Privacy Act.

This Privacy Policy applies in respect of information provided to us by persons under the age of 18 years however, those persons must obtain the consent of a parent or guardian prior to using the Site and the parent or guardian will be responsible for appropriately supervising the person’s use of the Site.

If you have any further questions or if you wish to receive more information on our information practices and Privacy Policy, please contact us (see Contact Us below).

2. Types of personal information we collect

General Purpose of Collection

All personal information that we or our related bodies corporate collect, is reasonably necessary for the purposes relating to providing our products and services.

We will not collect personal information unless the information is reasonably necessary for or directly related to one, or more of our functions or activities. If we are unable to collect personal information we reasonably require, we may not be able to do business with you or the organisation with which you are connected.

We predominantly collect information about your identity, qualifications and place of practice. Whilst much of this information is not personal information, some of the information we collect, on its own or when matched with other information, may be personal information about you.

You may provide the following types of information to us

  • Identifiers, such as
    • Name
    • Date of birth
    • Contact details including email and phone number
    • Residential address
    • Occupational details
  • Where you practice and your website
  • Payment information, such as credit card number, for your purchase (which is stored and processed by our third-party payment processor or directly by the third-party app store)
  • Commercial information, such as
    • a record of the content on our website that you experience
    • details about about your purchases and other business interactions with us, responses to surveys, and participation in our online events
  • Information about your interests and preferences
  • Audio or visual information, such as profile photo and recordings of calls or online events
  • Rough geolocation (inferred from your IP address)
  • Inferences based on any of the above.

Sensitive Information

We will not collect any sensitive information from you, revealing your: race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability.

3. Use and disclosure of personal information


We and our service providers use the information described above for the following purposes

  • Manage and improve our website and app generally
  • Process your registration and verify your information
  • Customize content, preferences, and advertising on our website and app, across the Internet and elsewhere
  • Send you confirmations, updates, security alerts, and support and administrative messages
  • Conduct sales and marketing
  • Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development
  • Protect against, identify, investigate, and respond to misuse of our website or app or other unlawful behavior
  • Address legal requirements
  • Establish, exercise, or defend our legal rights; and
  • Create aggregated or de-identified information.

We may use personal information about you for the primary purpose of providing our services, and for which you would reasonably expect us to use that information, including sending you newsletters by email. We may use any email address you provide to us at any time for this purpose.

We may also use or disclose information about you

  • where we have obtained your consent
  • as required by relevant laws, statutes, regulations, codes and external payment systems.


We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. In order to deliver the services that we provide, we may disclose your personal information to other organisations, only in relation to providing our services to you. We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information.

We may share with third-parties information that is not associated with your name or identity, such as Website usage information, non-personally identifiable demographic information.

Unauthorised access use or disclosure

In the event of a security incident involving unauthorised access, use or disclosure of personal information where a third party with whom we share personal information is involved, we will seek to work cooperatively with them to protect the personal information we have shared with them.

4. Opt Out

You can opt out of receiving marketing material from us at any time by unsubscribing. You agree and acknowledge that even if you opt out of receiving material from us, we will still send you essential information that we are legally required to send you relating to the services we provide. Once you opt out of receiving marketing material from us, you agree and acknowledge that this removal from our distribution lists may take several business days after the date of you request to be removed.

5. Third Parties and your information

We will only collect, store, use or disclose personal information as set out in this Privacy Policy unless we are required by law to use that information to protect our rights or property (or those of any third party), or to avoid injury to any person.

Although the Site may link directly to Websites operated by third parties (Linked Websites), you acknowledge that Linked Websites are not operated by us. We encourage you to always read the applicable privacy Policy of any Linked Site on entering the Linked Site. We are not responsible for the content or practices of the Linked Websites nor their privacy policies regarding the collection, storage, use and disclosure of your personal information.

6. Disclosure of Information Overseas

For Pamela Douglas Consulting’s Australian businesses, we store and retain your personal information in Australia.

7. Your consent

By using the Websites, you consent to the collection, storage, use and disclosure of your personal information in accordance with this Privacy Policy and as otherwise permitted under the Privacy Act.

Where you provide information directly to us, you consent to use and disclosure of that information in accordance with this Privacy Policy.

8. Cookies

When you visit the Site the server may attach a "cookie" to your computer's memory. A "cookie" assists us to store information on how visitors to the Website use it and the pages that may be of most interest. This information may be used by Pamela Douglas Consulting (including by or on behalf of our third party commercial partners) to provide users of your computer with information that we think may interest the users of your computer.

Cookies also allow us to provide you with more personalised service. We use cookies to

  • determine whether you have previously accessed our Websites
  • store user preferences, identify the pages you have accessed, your IP address and the date, time, login location and duration of your visit
  • improve the performance of the Website. For instance, they help pages load quicker
  • aid in the security of your use of our Pamela Douglas Consulting Websites
  • aid in the log-in process
  • facilitate administration of Pamela Douglas Consulting Websites
  • generate statistics about the use of our Websites (including through the use of third party analytics services) to continually improve our Websites and customer service, and data products and identify product trends
  • help us to serve you relevant advertisements and implement frequency capping procedures

However, this information is not linked to any personal information you may provide to the Websites and cannot be used to identify you.


We may use third party analytics service providers, including but not limited to Google Analytics, to evaluate and provide us with information about the use of the Website. Your IP address and other information will be collected by automated means to report on your use of the services. These third-parties use cookies, web beacons, pixels, embedded scripts and other, similar technologies to automatically collect information about your Website use, report Website trends, and help us compile Website metrics. You can learn about Google’s specific practices by going to For more information about how Google Analytics uses your information please click here.

Opting out from Cookies and analytics

You may withdraw or change your cookies consent at any time by modifying your browser settings to accept or decline cookies. You may also go to or if you are in Europe, or to if you are anywhere else for instructions on how to disable cookies.

If you choose to configure your computer so that it disables cookies or does not accept them, you may not be able to make full use of our Websites.

You may opt-out from Google Analytics here or by downloading the Google Analytics opt-out browser add-on, available at: In some instances, when you opt- out, a new cookie (Opt-Out-Cookie) is placed in your web browser. This tells the third party provider to cease data collection from your browser and prevents advertisements from being delivered to you.

9. Storage and security

We will use all reasonable endeavours to keep your personal information in a secure environment, however, this security cannot be guaranteed. Your use of our Websites and the electronic storage of your personal information is secured by practices and procedures which we consider are consistent with Australian industry standards. All orders placed online using a credit card are covered by SSL security technology to protect customer details. These security measures are designed to ensure your personal information is not subject to unauthorised access, loss or misuse. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see Contact Us below).

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with our document and information retention policy.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

10. Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy. You will be deemed to have consented to such variations by your continued use of the Site following such changes being made.

11. Accuracy of your information

We take all reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your personal information is not accurate, up-to-date, complete, relevant and not misleading, please contact us (see Contact Us below) and we will take all reasonable steps to correct it within a reasonable time.

12. Access to information we hold about you

You may request to access the personal information we hold about you. We will endeavour to respond to any such request within a reasonable period of time and as required under the Privacy Act and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by contacting us (see Contact Us below).

We may charge a reasonable fee for providing that information.

13. Complaints or Disputes

If you have a complaint about our treatment of your personal information, please contact our general manager at Our general manager will consider and if, in our reasonable opinion, necessary, investigate your complaint and endeavour to respond to you within a reasonable period of time.

If we do not adequately answer your concerns, you have the right to make a complaint as follows

  • Australia: to the Office of the Australian Information Commissioner

14. Contact Us

If you have any questions relating to this Privacy Policy or your personal information, please contact our general manager at

When contacting us or using our products and services, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way. We are required to verify your identity if you wish to exercise any of your rights in relation to your personal information held by us.

15. Annex - Processing of Personal Data (Residents of the EEA, Switzerland and UK)

PDC provides additional information to its EEA, Switzerland and UK based users to comply with data protection laws.

What is personal data?

“Personal data” is information about you (a “data subject”) the use of which is governed by applicable data protection laws. It will include any information from which you can be identified, directly or indirectly, in particular by reference to an identifier such as your name, an identification number, location data, an online identifier or other information about your identity. Most information collected about you on the Website will constitute personal data.

Who is responsible for your personal data?

If you use our Website, the data controller is Pamela Douglas Consulting Pty Ltd

What is the legal basis for processing your personal data?

On some occasions, we process your personal data with your consent, for example, when you agree to receive our newsletter or to deal with your enquiries.

On other occasions, we process your personal data when we need to do this in order to fulfil a contract with you, such as granting you access to our online services.

We also process your personal data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we may process your personal data in our legitimate interests to ensure that our Website and services are provided efficiently and in an user- friendly and personalised manner taking into account user feedback, data and profiles, unless consent is required for any such processing under applicable law. We will process personal data to ensure the security of our business and the information of our users, and to ensure the proper and efficient administration of our business. You may contact us for further information.

Finally, we will process your personal data where we are required to do this by law. For example, where we have to fulfil anti-money laundering requirements or disclose information under a court order.

Data transfers

Personal data that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the personal data in accordance with this Privacy Policy.

Personal data which you provide may be transferred to our group companies, commercial partners, suppliers or agents located outside your country as set out above. We will ensure adequate protection of personal data transferred outside of your country as required under applicable laws. For example, if you are located in the EEA, Swiss or in the UK, we may enter into model clauses with the recipient. You may contact us for a copy of the safeguards which we have put in place to protect your personal data in these circumstances.

In addition, personal data that you submit for publication on the Website will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

How long does Pamela Douglas Consulting keep personal data?

PDC keeps your personal data for only as long as required to provide you with the necessary Website content and services and to carry out the processing set out in this Privacy Notice, and in line with its obligation under applicable law. This means that we will generally not keep your personal data for longer than six years following your last interaction with us, and the actual retention period will often be shorter. You may contact us for further information.

Your rights

Data subjects may ask us for a copy of their personal data, to correct it, erase it or to transfer it to other organisations at their request. Data subjects also have rights to object to some processing including profiling and, where we have asked for their consent to process the data subject’s personal data, to withdraw this consent. In particular, data subjects have the right to object to direct marketing at any time. Where a data subject withdraws their consent, this will not affect the legitimacy of the processing conducted prior to your request. Where we process personal data because we have a legitimate interest in doing so (as explained above), the data subject has a right to object to this. Where we make a decision based solely on automated processing which significantly affects the data subject, he or she may have the right to contest the decision, express his or her point of view and obtain human intervention.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal data.

Please use the contact information set out in our Contacting Us section above. We will aim to acknowledge your enquiries within 72 hours and respond within one month, unless otherwise required by law.

We hope that we can satisfy queries you may have about the way we process your personal data. However, if you have unresolved concerns you also have the right to complain to your local data protection authority.

16. General

This Privacy Policy is effective as at 10 January 2024

Pamela Douglas Consulting may vary this Privacy Policy from time to time. Pamela Douglas Consulting will notify you of these changes by publishing them on our Websites.