Social Media & Advertising Policy
1. Introduction
1.1. The purpose of this policy is to set out a framework for staff and practitioners of Jowell Chew Psychology (“the Practice”) in publishing content to Social Media, Advertising the Practice and issuing Public Comment in relation to matters associated with the Practice.
1.2. The Practice respects the right of its engaged workers, including employees and contractors (hereafter “Staff and Practitioners”), as private citizens to engage in debate on political and social issues on public forums including their personal social media.
1.3. The Practice respects the right of Practitioners to develop and independently advertise their public professional profiles.
1.4. At the same time, the Practice recognises that the actions of Staff and Practitioners reflect on the public standing of the Practice and the standing of other Practitioners and as such, expects that all Staff and Practitioners:
a) uphold a standard of professionalism as befitting allied health professionals and care workers;
b) exhibit ethical behavior online in accordance with the mission, vision and values of the Practice and with regard to maintaining public confidence in the Practice;
c) adhere to the advertising guidelines set out by the Regulator for regulated health services such as the Practice; and
d) support and maintain this standard within the Practice.
1.5. This policy applies to all Staff and Practitioners of the Practice.
1.6. The purpose of this policy is to:
a) manage the reputation of the Practice;
b) adhere to the Regulator’s advertising requirements for regulated health services; and
c) ensure that there is no breach of the Practice’s policies and procedures, particularly its Privacy Policy.
2. Definitions
2.1. Advertising takes its meaning from the AHPRA Advertising Guidelines (established under section 133 of the National Law) and means all forms of verbal, printed and electronic communication that promotes and seeks to attract a person to a regulated health service provider and/or to attract a person to use the regulated health service.
2.2. National Law means the relevant state equivalent of the Health Practitioner Regulation National Law.
2.3. Personal Information takes its meaning from the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, regardless of whether the information or opinion is true or not and regardless of the form the information or opinion is recorded in.
2.4. Post means the open publication of any content whether in video, images, audio or text form to Social Media.
A Post that is nominally private may become public through the actions of another actor; consequentially any Post to an indeterminate audience is an open publication.
2.5. Practice Manager means the person with that title, who at the time of adoption of this policy is Jowell Chew.
2.6. Practice Social Media Accounts means any and all Social Media Accounts operated by the Practice.
2.7. Practice Website means the website at the URL:
https://jowellchewpsychology.com.au/
2.8. Regulator means the Australian Health Practitioner Regulation Agency.
2.9. Social Media means any media channel or platform capable of being used by an individual to make a comment that is publicly available, and includes, without limitation:
a) social networking sites (i.e. Facebook, Threads, X, Instagram);
b) professional networking sites;
c) video and photo sites (i.e. TikTok, Flickr);
d) forums (i.e. Reddit);
e) podcasts;
f) blogs (whether individual or collaborative); and
g) comment sections of websites.
This policy is intended to also cover social media channels that may develop in the future.
3. Use of Social Media Generally
3.1. Use of Social Media during work hours is discouraged unless it forms a part of the scope of work responsibilities.
3.2. Staff and Practitioners ought to be mindful that any Post may be duplicated and republished, potentially by news media, and potentially with global reach. Staff and Practitioners acknowledge that Posts on Social Media have the potential to be considered a reflection of the mission and values of the Practice. As such, the Practice may:
a) direct an employee to remove a Post, issue a caution or take further action against an employee in relation to a Post; or
b) request a contractor to remove a Post, issue a caution or take further action against a contractor in relation to a Post.
4. Boundaries With Clients
4.1. Given the nature of the client-practitioner relationship, it is unsuitable for Staff and Practitioners to accept or offer connections or friend requests with clients on Social Media platforms that provide this service.
4.2. While some clients may contact the Practice through the Practice’s Social Media Accounts, social media messaging is not an appropriate channel for health service conversation and all inquiries should be promptly redirected to appropriate support channels.
5. Public Comment and Representation of the Practice
5.1. The Practice shall not constrain the capacity of its Staff and Practitioners from engaging in public debate or making public comment on political, social, or ethical issues on any platform.
5.2. However, Staff and Practitioners must not:
a) issue any public comment on behalf of the Practice unless expressly authorised;
b) identify themselves as a Staff member of the Practice unless expressly authorised; or
c) act in any manner that would lead a reasonable person to conclude that their public comment is associated with or in connection to their engagement with the Practice unless expressly authorised.
5.3. Staff and Practitioners are not to use the Practice’s name, logo, or email address in any manner that may suggest that the Practice endorses or supports any activity that is not within the individual’s scope of work. Use of Practice-provided email accounts for non-work uses (e.g. LinkedIn) is generally discouraged.
5.4. Should the Practice or an individual engaged by the Practice be required to make a public comment, such a statement may only be made on express authorisation by the Practice Manager.
6. Confidentiality
6.1. Under no circumstances may Staff or Practitioners breach client confidentiality or disclose Personal Information without the express authorisation of the Practice Manager. This includes:
a) disclosing case studies (even in redacted form);
b) confirming or disconfirming an individual is a client or a third-party payer of the Practice; or
c) confirming or disconfirming an individual is engaged by the Practice as an employee or contractor.
6.2. Staff and Practitioners must not disclose any operational details in relation to the Practice including financial details, services, assets, or contracts.
6.3. Staff and Practitioners must not identify any other Staff Member or Practitioner of the Practice nor any details about another Staff Member or Practitioner.
7. Advertising the Practice in Compliance with the National Law
Under Section 133 of the National Law a breach of an advertising requirement is a criminal offence for which a court may impose a monetary penalty. Current or previously registered health practitioners associated with the advertising may also be subject to disciplinary action by the Regulator.
7.1. All Advertising undertaken by the Practice and by Practitioners must be in accordance with the National Law (summarised at Appendix 1 – Advertising in Compliance with the National Law).
7.2. The Practice and Staff and Practitioners recognise that any person (including staff, practitioners and external advertisers) who authorise advertising content are individually liable under the National Law to penalties for improper advertising of a regulated health service such as the Practice. As such, all Advertising on behalf of the Practice must be authorised by the Practice Manager in accordance with this Policy.
7.3. All proposed Advertising of the Practice must:
a) utilise only pre-authorised titles for Practitioners of the Practice;
b) be drafted in accordance with Appendix 1 and in a form that permits the Practice Manager to review the material in advance of its scheduling for publication; and
c) be expressly authorised before being scheduled for posting to the Practice’s Social Media Accounts.
7.4. Practitioners may advertise themselves independently of the Practice, however:
a) the Practice reserves the right to notify the Practitioner it has concerns in relation to the content of the Practitioner’s advertising and to request it be removed or amended; and
b) if the Practitioner fails to remove or amend the Advertising content in question, the Practice reserves the right to take adverse action in accordance with the Practitioner’s terms of engagement with the Practice.
8. Intellectual Property in Advertising
8.1. Staff and Practitioners must ensure that any content Posted on the Practice Website or Practice Social Media Accounts, whether text, video, audio or images, is obtained in circumstances where it can be assured the content is copyright-free.
8.2. Staff and Practitioners who Post on the Practice Website or Practice Social Media Accounts must not infringe the intellectual property of any other right-holder.
9. Bullying, Harassment and Vilification
9.1. The Practice takes a zero tolerance approach to all bullying, harassment and vilification irrespective of whether it is online or in person.
9.2. Staff and Practitioners must not make any Post about any individual on Social Media which could be construed as defamatory, vilifying, harassing, threatening, racist, sexist or discriminatory.
9.3. Should a Staff member or Practitioner make any Post in contravention of this section, the Practice reserves its rights without limitation to:
a) take adverse action against the individual in respect of their engagement with the Practice;
b) take civil action against the individual for any damages suffered by the Practice; and/or
c) refer the Post to the relevant authority or regulator for consideration and potentially further action.
10. Implementation
10.1. It is the expectation of the Practice that all Staff and Practitioners comply with the terms of this policy.
10.2. All employees, Staff and Practitioners are obliged to report any apparent or potential breach of this policy to the Practice Manager.
10.3. This policy is reviewed periodically to ensure compliance with legislative changes and best practices. Staff and Practitioners will be notified of significant updates.
10.4. This version was adopted on 27 January 2026.
Appendix 1 – Advertising in Compliance with the National Law
The following sets out guidelines that must be adhered to when advertising a regulated health service under Section 133(1) of the National Law pursuant to AHPRA’s Advertising Guidelines:
(a) Advertisers must not make false, misleading or deceptive claims in their advertising.
To avoid being misleading or deceptive, advertisements should:
• sell the professional services on its merits;
• substantiate claims made on the basis of acceptable evidence;
• not make comparisons with other regulated health services;
• be precise in the use of titles and claims about registration, competence and qualifications;
• be precise in the description of endorsements and claims of specialty;
• not overstate the specialist area of practice of the Practitioner; and
• be precise in advertising relevant qualifications.
(b) Advertisers must not offer a gift, discount or other inducement to attract a person to use the service or the business, unless the advertisement also states the terms and conditions of the offer.
To avoid breaching inducement provisions, advertisements should:
• avoid listing price information that is unclear, inexact, vague or liable to vary unexpectedly;
• include or link to relevant terms and conditions; and
• avoid offering “free” items.
(c) Advertisers must not use testimonials or purported testimonials about the service or business.
To avoid breaching testimonial rules, advertisements should:
• avoid publishing or republishing any testimonial with a “clinical aspect” (referring to a symptom, diagnosis, treatment or outcome).
(d) Advertisers must not create an unreasonable expectation of beneficial treatment.
To avoid breaching unreasonable expectation rules, advertisements should:
• avoid claims, statements or implications likely to create an unreasonable expectation of beneficial treatment;
• avoid claims that may create an unreasonable expectation of outcomes or recovery time; and
• avoid graphic or visual representations that create an unreasonable expectation of benefit.
(e) Advertisers must not directly or indirectly encourage the indiscriminate or unnecessary use of regulated health services.
To avoid breaching indiscriminate use rules, advertisements should:
• avoid any sense of urgency in the advertising; and
• avoid incentives such as prizes, discounts, bonuses, or gifts that encourage people to use services regardless of clinical need or therapeutic benefit.
Document details
Approved by: Jowell Chew
Version: 1
Approval date: 27 January 2026
Next Review: 1 August 2026
