“Obey your earthly masters in everything; and do it not only when their eye is on you and to curry their favour, but with sincerity of heart and reverence for the Lord. Whatever you do, work at it with all your heart, as working for the Lord, not for human masters…” Colossians 3: 22-23
“Serve one another humbly in love. For the entire law is fulfilled in keeping this one command; “Love your neighbour as yourself.” Galatians 5: 13-14
Your privacy is important
This statement outlines the Colleges’ policy on how the College uses and manages personal information provided to or collected by it. This policy has been developed to ensure that personal information is managed openly and transparently.
The College is bound by the Australian Privacy Principles (APPs) contained in the Commonwealth Privacy Act 1988, amended 12th March 2014.
Definition of Personal Information
Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- Whether the information is true or not; and
- Whether the information or opinion is recorded in a material form or not
What kind of personal information does the College collect and how does the College collect it?
The type of information the College collects and holds includes (but is not limited to) personal information, including sensitive information, about:
- Pupils and parents and/or guardians before, during and after the course of a pupil’s enrolment at the College;
- Job applicants, staff members, volunteers and contractors; and
- Other people who come into contact with the College.
Personal Information you provide: The College will generally collect personal information held about an individual by way of forms filled out by Parents or pupils, face-to-face meetings and interviews, and telephone calls. On occasions, people other than Parents and pupils provide personal information. Any information that may be an Australian Government identifier will not be adopted as an identifier within the College context e.g. Medicare numbers.
Personal Information provided by other people: In some circumstances the College 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.
Personal Information collected without consent: Sensitive information about an individual (deemed to be personal information) may only be collected with the individual’s consent or if an exclusion applies and only collected if it is reasonably necessary for one or more of the College’s functions or activities. Such an exception includes a “general health situation”, where the College believes the collection of the sensitive information is necessary to lessen or prevent a serious threat to life, health or safety of an individual or to public health or safety and it is unreasonable or impractical to obtain the individual’s consent.
Unsolicited Personal Information: The College may receive information that it did not request. If the College is permitted to keep such information, it will do so under the same conditions as information it did request. If the College is not permitted to collect the information, it will destroy or de-identify the information, unless it is not lawfully reasonable to do so.
How will the College use the personal information you provide?
The College 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 reasonably expected, or to which you have consented.
Pupils and Parents: In relation to personal information of pupils and parents, the College’s primary purpose of collection is to enable the College to provide schooling for the pupil. This includes satisfying both the needs of Parents and the needs of the pupil throughout the whole period the pupil is enrolled at the College. The purposes for which the College uses personal information of pupils and Parents include:
- To keep Parents informed about matters related to their child’s schooling, through correspondence, newsletters and magazines;
- Day-to-day administration;
- Looking after pupils’ educational, social and medical well being;
- Seeking donations and marketing for the College;
- To satisfy the College’s legal obligations and allow the College to discharge its duty of care.
In some cases where the College requests personal information about a pupil or Parent, if the information requested is not obtained, the College may not be able to enrol or continue the enrolment of the pupil.
Job applicants, staff members and contractors: In relation to personal information of job applicants, staff members and contractors, the College’s primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor, as the case may be.
The purposes for which the College uses personal information of job applicants, staff members and contractors include:
- In administering the individual’s employment or contract, as the case may be;
- For insurance purposes;
- For seeking funds and marketing for the College;
- To satisfy the College’s legal obligations, for example, in relation to child protection legislation.
Volunteers: the College also obtains personal information about volunteers who assist the College in its functions or conduct associated activities, such as alumni associations, to enable the College and the volunteers to work together.
Marketing and Fundraising: The College treats marketing and seeking donations for the future growth and development of the College as an important part of ensuring that the college continues to be a quality learning environment in which both pupils and staff thrive. Personal information held by the College may be disclosed to an organisation that assists in the College’s fundraising for example, the College’s Foundation or alumni organisation.
Parents, staff, contractors and other members of the wider College community may from time to time receive fundraising information. College publications, like newsletters and magazines, which include personal information, may be used for marketing purposes.
Should an individual not consent to this, they may contact the Principal in writing to opt out of being involved.
Who might the College disclose personal information to?
The College may disclose personal information, including sensitive information, held about an individual to:
- Another school;
- Government departments
- Medical practitioners;
- People providing services to the college, including specialist visiting teachers and sports coaches;
- Recipients of College publications, like newsletters and magazines;
- Anyone you authorise the College to disclose the information to; and
- Anyone to whom we are required to disclose the information by law
Sending information overseas:
The College may disclose personal information about an individual to overseas recipients, for instance, when storing personal information with “cloud” service providers which are situated outside Australia or to facilitate a school exchange. However, whilst it is unlikely that personal information would be disclosed to overseas recipients, the College will not send personal information about an individual outside Australia without:
- Obtaining the consent of the individual (in some cases this consent will be implied); or
- Otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.
In the unlikely event of personal information being disclosed overseas, this could be the case in situations such as student exchange programs. The recipient would be informed that they are also bound not to breach the APPs in relation to this personal information.
How does the College treat sensitive information?
In referring to ‘sensitive information’, the College 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 orientation or practices or criminal record, that is also personal information; and 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 the use or disclosure of the sensitive information is allowed by law.
In accordance with APP 6, additional exceptions for using or disclosing personal information include:
- To assist in locating a missing person;
- To establish, exercise or defend a legal or equitable claim; or
- For the purposes of a confidential alternative dispute resolution
Management and security of personal information
The College’s staff are required to respect the confidentiality of pupils and parents personal information and the privacy of individuals. The College has in place steps to protect the personal information the College holds from misuse, loss, unauthorised access, modification or disclosure by use of various methods including locked storage of paper records and pass worded access rights to computerised records.
Updating personal information
The College endeavours to ensure that the personal information it holds is accurate, complete and up to date. It will be updated at the start of each new calendar year and throughout the year as updates are requested and received. A person may seek to update their personal information held by the College if it is out-of-date, correct it if it is inaccurate or complete it if it is incomplete by contacting the Administration Assistant of the College at any time. The Australian Privacy Principles require the College not to store personal information longer than necessary.
You have the right to check what personal information the College holds about you
Under the Commonwealth Privacy Act, an individual has the right to obtain access to any personal information which the College holds about them and to advise the College of any perceived inaccuracy. There are some exceptions to this right set out in the Act. Pupils will generally have access to their personal information through their parents, but older pupils may seek access themselves.
There are some exceptions to these rights set out in the applicable legislation.
To make a request to access any information the College holds about you or your child, please contact the College Principal in writing.
The College may require you to verify your identity and specify what information you require. The College 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 expensive, the College will advise the likely cost in advance. If we cannot provide you with access to that information, we will provide you with written notice explaining the reason for refusal.
Consent and rights of access to the personal information of pupils.
The College respects every parent’s right to make decisions concerning their child’s education.
Generally, the College will refer any requests for consent and notices in relation to the personal information of a pupil to the pupil’s Parents. The College will treat consent given by parents as consent given on behalf of the pupil, and notice to parents will act as notice given to the pupil.
Parents may seek access to personal information held by the College about them or their child by contacting the College Principal. However, there will be occasions when access is denied. Such occasions would include where the 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 College’s duty of care to the pupil.
The College may, at its discretion, on the request of a pupil grant that pupil access to information held by the College about them, or allow a pupil to give or withhold consent to the use of their personal information, independently of their parents. This would normally be done only when the maturity of the pupil and/or the pupil’s personal circumstances so warranted.
Individuals who seek to find out information about the College, regarding enrolments, may do so without the need to identify themselves via the website contact page. Any further enquiries would need the individual being asked to identify themselves so that the questions and information sought may be answered in the most appropriate and helpful manner. (This precludes other businesses seeking information which may benefit their own above the College).
Enquiries and complaints
If you would like further information about the way the College manages the personal information it holds, or wish to complain that you believe the College has breached the Australian Privacy Principles, please contact the College Principal. The College will investigate any complaint and will notify you of the making of a decision in relation to your complaint as soon as practicable after it has been made.
APPENDIX 1: Record Storage Summary
|Admin office||P, BM, AA||Locked room, locked cabinet|
|Student files e copy||PC/Laptop School database||P, BM, AA & PT||Password protected|
|Staff Files hard copy||Principal’s office||P, BM, AA||Locked room, locked cabinet|
|P, BM||Password protected|
|BM’s office drawer||P, BM||Room and cabinet locked|
|Financial files e copy||BM’s computer||BM||Password protected|
|Emergency student files||P & AA laptop
& roll books
|All staff||Password protected|
|Allergy charts||Kitchen/Office||All staff||All staff|
|Staff record books, files in classrooms, offices||P, TS, BM, AA||Password protected & locked cabinet|
|PC School and Report Drive||P, AA||Password protected|
P = Principal
PA = Administration Assistant
BM = Business Manager
TS = Teaching Staff