Your privacy is important. This statement outlines the School’s policy on how we use and manage personal information provided to or collected by it. The School is bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) as amended. This policy outlines how the School uses and manages personal information provided to, or collected by, it.
Collection of Personal Information
The School collects personal information, including sensitive information, about:
- Students and parents and/or guardians (‘parent’) before, during and after the course of a student’s enrollment at the School
- Job applicants, staff members, volunteers and contractors
- Other people who come in contact with the School. Personal information is information or an opinion relating to an individual which can be used to identify that individual.
Personal information that the School collects includes individuals’ names, email addresses, addresses, gender, occupation, contact information or preferences.
Personal information you provide: The School will generally collect personal information held about an individual by way of forms filled out by parents or students, face to face meetings and interviews e-mails and telephone calls.
Personal information provided by other people: In some circumstances, the School may be provided with personal information about an individual from a third party, for example a report provided by a medical professional or a reference from another school.
Use of Personal Information
The School will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and are reasonably expected, or to which you have consented.
Students and Parents: In relation to personal information of students and parents, the School’s primary purpose of collection is to enable the School to provide schooling for the student. This includes satisfying both the needs of parents and the needs of the student, throughout the whole period the student is enrolled at the School.
The purposes for which the School uses personal information of students and parents include:
- to keep parents informed about matters related to their child’s schooling, through correspondence, newsletters, marketing materials and online portals
- day to day administration
- looking after a student’s educational, social, spiritual and personal wellbeing
- seeking donations and marketing for the School
- to satisfy the School’s legal obligations and allow the School to discharge its duty of care
In some circumstances where the School requests personal information about a student or parent, if the information requested is not obtained, the School may not be able to enroll or continue the enrolment of the student or permit the student to take part in a particular activity.
Job applicants, staff members and contractors: In relation to personal information of job applicants, staff and contractors, the School’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor.
The purposes for which the School uses personal information of job applicants, staff members and contractors include:
- communicating with the individual
- administering the individual’s employment or contract
- satisfying payroll and industrial relations requirements
- satisfying the School’s legal obligations, for example in relation to child protection legislation
Volunteers: The School also obtains personal information about volunteers who assist the School in its functions or when conducting associated activities, such as alumni associations, to enable the School and the volunteers to work together.
Marketing and fundraising: The School treats marketing and seeking donations for the future growth and development of the School, as an important part of ensuring that the School continues to be a quality learning environment, in which both students and staff thrive. Personal information held by the School may be used for the purpose of assisting with the School’s fundraising and marketing activities.
Parents, staff, contractors and other members of the wider School community may, from time to time, receive fundraising information. School publications, like newsletters and magazines, which include personal information and sometimes visual images, may be used for marketing purposes.
Disclosure of Personal Information
We may disclose your personal information to companies that we have engaged to carry out functions and activities on our behalf, our professional advisers and insurers or to anyone else to whom you authorise us to disclose it.
With consent, the School may also disclose personal information, including sensitive information, held about an individual to:
- another school
- government departments
- Independent Schools Victoria (for LEAD survey, etc)
- VCAA, VTAC and tertiary entry authorities
- medical practitioners
- people providing services to the School, including visiting teachers, specialists and sports coaches, excursion or camp providers
- recipients of School publications, like newsletters and magazines
- newspapers; social media forums
- parent association/committees
- other parents or guardians
- anyone to whom we are required to disclose the information to by law
- anyone to whom you authorise the School to disclose information
Sending Information Overseas
The School may from time to time send personal information overseas, for instance, to facilitate a School exchange or travel program.
The School will not send personal information about an individual outside Australia without:
- obtaining consent of the individual (in some cases, consent will be implied); or
- otherwise complying with the Australian Privacy Principles.
In circumstances where a you consent to personal information being sent outside Australia, the receiving entity will be subject to applicable data protection and privacy laws operating in that jurisdiction. You may have rights to enforce the receiving entities compliance with applicable laws but you may not have recourse against the receiving entity under Australian Privacy Legislation and regulations in relation to how the receiving entity treats your personal information.
In referring to ‘sensitive information’ the School means information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, philosophical beliefs, sexual preferences, criminal record or health information and biometric information about an individual.
Sensitive information will be used and disclosed only for the purpose for which it was provided, or a directly related secondary purpose, unless you agree otherwise, or when the use or disclosure of the sensitive information is allowed by law.
Management and Security of Personal Information
The School’s staff are required to respect the confidentiality of students’, parents’ and guardians’ personal information and the privacy of individuals. The School has in place steps to protect the personal information the School holds from misuse, interference, loss, unauthorised access, modification or disclosure, by use of various methods including locked storage of paper records, physical security of servers, use of firewalls and restricted access rights to computerised records via logins and passwords.
The School endeavours to ensure that the personal information it holds is accurate, complete and up to date, relevant and not misleading. A person may seek to update their personal information held by the School at any time.
The Australian Privacy Principles require the School not to store personal information longer than necessary. The School takes reasonable steps to de-identify or destroy personal information no longer required by it for the permitted purpose.
Access and Correction to Personal Information
Under the Commonwealth Privacy Act (and Health Records Act), an individual has the right to request access to any personal information which the School holds about them and to advise the School of any perceived inaccuracy. There are some circumstances where access may be denied. Such circumstances would include where release of the information would have an unreasonable impact on the privacy of others, or where the release may result in a breach of the School’s duty of care to the student. Students will generally have access to their personal information through their parents, although older students may seek access themselves.
Requests to access any information the School holds about you or your child should be forwarded in writing to the Privacy Officer (firstname.lastname@example.org). The School may require you to verify your identity and specify what information you wish to view. The School may charge a fee to cover the cost of verifying your application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, the School will advise the likely cost in advance.
Note that personal employment records are exempted from the Act, and hence from access.
Breach of the Australian Privacy Principles
If a person believes the School has breached its obligations under the Australian Privacy Principles, that person should forward a complaint in writing to the Privacy Officer (email@example.com). The complaint should include sufficient details of the alleged breach. The School will respond to that person within a reasonable time after receipt of the complaint. In responding to that person, the School will determine whether a breach has occurred and, if so, the appropriate response in light of the circumstances.
If the person does not believe the complaint was adequately dealt with by the School, that person may make a further complaint to the Privacy Commissioner and seek advice regarding any such complaint from the Privacy Hotline 1300 363 992. Once referred to the Privacy Commissioner the complaint will be dealt with by way of conciliation. If a resolution cannot be reached the Privacy Commissioner may make a determination which is binding on the parties and enforceable at law.
A person wishing to make a complaint should first attempt to resolve any complaint with the School directly before referring the complaint to the Privacy Commissioner.
Generally, the School will refer any requests for consent and notices in relation to the personal information of a student to the student’s parents. The School will treat consent given by parents as consent given on behalf of the student and notice to parents will act as notice given to the student.