The policy applies to board members, employers, employees, volunteers, parents/guardians and students, contractors, and people visiting the school site; and describes the type of information the school collects, how the information is handled, how and to whom the information is disclosed, and how the information may be accessed.
- Privacy Act 1988 (Cth)
- Privacy Amendment (Enhancing Privacy Protection) Act 2012
- Student Protection Policy
- Disabilities Policy
The College is required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs direct the way in which personal information is processed throughout its life cycle, from collection, to use and disclosure, storage, accessibility and disposal.
EXCEPTION in relation to employee records:
What is personal information?
Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
What is sensitive 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 orientation or practices or criminal record, that is also personal information; 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.
What kinds of personal information does the School collect and how does the School collect it?
The type of information the School collects and holds includes (but is not limited to) personal information, including health and other sensitive information, about:
- pupils and parents and/or guardians (‘Parents’) before, during and after the course of a pupil’s enrolment at the School;
- job applicants, staff members, volunteers and contractors; and
- other people who come into contact with the School.
Personal Information you provide:
The School 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, emails and telephone calls. On occasions people other than Parents and pupils provide personal information.
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.
How will the School use the personal information you provide?
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 reasonably expected by you, or to which you have consented.
Pupils and Parents
In relation to personal information of pupils and Parents, the School’s primary purpose of collection is to enable the School to provide schooling for the pupil. This includes satisfying the needs of Parents, the needs of the pupil and the needs of the School throughout the whole period the pupil is enrolled at the School.
The purposes for which the School 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 of the School;
- looking after pupils’ educational, social and medical wellbeing;
- seeking donations and marketing for the School; and
- to satisfy the School’s legal obligations and allow the School to discharge its duty of care.
In some cases where the School requests personal information about a pupil or Parent, if the
information requested is not provided, the School may not be able to enrol or continue the enrolment of the pupil or permit the pupil to take part in a particular activity.
Job applicants, Staff Members and Contractors
In relation to personal information of job applicants, staff members and contractors, the School’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 School 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;
- seeking donations and marketing for the School; and
- to satisfy the School’s legal obligations, for example, in relation to child protection legislation.
The School also obtains personal information about volunteers who assist the School in its functions or conduct 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 provide a quality learning environment in which both pupils and staff thrive. Personal information held by the School may be disclosed to organisations that assist in the School’s fundraising, for example, the School’s Foundation or alumni organisation [or, on occasions, external fundraising organisations].
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, may be used for marketing purposes.
Who might the School disclose Personal Information to?
The School may disclose personal information, including sensitive information, held about an individual to:
- another school;
- government departments;
- medical practitioners;
- people providing services to the School, including specialist visiting teachers, counsellors and sports coaches;
- recipients of School publications, such as newsletters and magazines;
- anyone you authorise the School to disclose information to; and
- anyone to whom we are required to disclose the information to by law.
Sending Information Overseas
The School 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, the School 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.
The School may use online or ‘cloud’ service providers to store personal information and to provide services to the School that involve the use of personal information, such as services relating to email, instant messaging and education and assessment applications. Some limited personal information may also be provided to these service providers to enable them to authenticate users that access their services. This personal information may be stored in the ‘cloud’ which means that it may reside on a cloud service provider’s servers which may be situated outside Australia.
An example of such a cloud service provider is Google. Google provides the ‘Google Apps for Education’ (GAFE) including Gmail, and stores and processes limited personal information for this purpose. School personnel and the AIS and its service providers may have the ability to access, monitor, use or disclose emails, communications (e.g. instant messaging), documents and associated administrative data for the purposes of administering GAFE and ensuring its proper use.
APP 8 imposes an obligation on Schools, if they use cloud computing, to take reasonable steps to ensure that the overseas provider does not breach the APP’s. This imposes an additional obligation upon them in a similar way to the other privacy principles.
Countries in which personal information may be located include:
- Cambodia – use of information for student care and safety on College Missions trip.
- Ireland – use of information by off-site RTP Facilitator to provide home communications to students and parents related to incomplete homework, drafts and assignments and well as data collection for student care and wellbeing reports.
Overseas students, who are enrolled at Parklands Christian College, should be made aware that information provided, by the student to the College, may be made available to Commonwealth and State agencies. Acknowledgement of this disclosure would be in the form of a student signature on the College’s enrolment form; which should clearly state the above.