The School is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988. In relation to health records, the School is also bound by the NSW Health Privacy Principles which are contained in the Health Records and Information Privacy Act 2002.
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, including:
- name, contact details (including next of kin), date of birth, gender, language background, previous school and religion;
- parents’ education, occupation and language background;
- medical information (e.g. details of disability and/or allergies, absence notes, medical reports and names of doctors);
- conduct and complaint records, or other behaviour notes, and school reports;
- information about referrals to government welfare agencies;
- counselling reports;
- health fund details and Medicare number;
- any court orders;
- volunteering information; and
- photos and videos at School events;
- job applicants, staff members, volunteers and contractors, including:
- name, contact details (including next of kin), date of birth, and religion;
- information on job application;
- professional development history;
- salary and payment information, including superannuation details;
- medical information (e.g. details of disability and/or allergies, and medical certificates);
- complaint records and investigation reports;
- leave details;
- photos and videos at School events;
- workplace surveillance information;
- work emails and private emails (when using work email address) and Internet
- browsing history; and
- other people who come into contact with the School, including name and contact details and any other information necessary for the particular 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 to pupils enrolled at the school, exercise its duty of care, and perform necessary associated administrative activities, which will enable pupils to take part in all the activities of the School. 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 and contractors: In relation to personal information of job applicants and contractors, the School’s primary purpose of collection is to assess and (if successful) to engage the applicant or contractor, as the case may be.
The purposes for which the School uses personal information of job applicants and contractors include:
- administering the individual’s employment or contract, as the case may be;
- for insurance purposes;
- seeking donations and marketing for the School; and
- 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 conduct associated activities, such as [PTA committee], 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 PTA committee. Parents, staff, contractors and other members of the wider School community may from time to time receive fundraising information. School publications, like newsletters, which include personal information, may be used for marketing purposes. The School engages in various marketing initiatives to achieve this aim:
- Google Analytics & Google AdWords: this includes anonymised traffic data as well as the DoubleClick cookie associates your visit with Google’s demographic information about you and also allow us to serve you ads based on your website activities. We cannot target you on an individual basis and Google will only show us your demographic data in an aggregate report, not on an individual basis.
- Facebook Pixel: this is used for the same activities as Google Analytics & Google AdWords, except that your website behaviour is anonymously associated with your behaviour on Facebook. Again, Facebook does not let us see your data or target you on an individual basis.
- If you are located in the European Economic Area, the School will only set a session cookie version of Google Analytics by default, instructing your browser to delete this cookie at the end of your session. Only if you choose to continue using the website (by scrolling down after viewing the consent popup shown at the start of your website visit) will we enable the other cookies.
Who might the School disclose personal information to and store your information with?
The School may disclose personal information, including sensitive information, held about an individual for educational, administrative and support purposes. This may include to:
- other schools and teachers at those schools;
- government departments (including for policy and funding purposes);
- medical practitioners;
- people providing educational, support and health services to the School, including specialist visiting teachers, [sports] coaches and volunteers,
- providers of learning and assessment tools;
- assessment and educational authorities such as NESA and MEXT, NAPLAN Test and Administration Authorities (who will disclose it to the entity that manages the online platform for NAPLAN)
- people providing administrative and financial services to the School;
- recipients of School publications, such as newsletters
- pupils’ parents or guardians;
- anyone you authorise the School to disclose information to; and
- anyone to whom the School is required or authorised to disclose the information to by law, including child protection laws.
Sending and storing information overseas: The School may disclose personal information about an individual to overseas recipients, for instance, to report to the Ministry of Education, Culture, Sports, Science and Technology (MEXT) Japan. 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 such as Google, to store personal information and to provide services to the School that involve the use of personal information, such as services relating to email, education tools 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.
How does the School treat sensitive information?
In referring to ‘sensitive information’, the School means: information relating to a person’s racial or ethnic origin, political opinions, religion, 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.
Management and security of personal information
The School’s staff are required to respect the confidentiality of pupils’ and Parents’ personal information and the privacy of individuals.
The School has in place steps to protect the personal information the School holds from misuse, interference and loss, unauthorised access, modification or disclosure by use of various methods including locked storage of paper records and password access rights to computerised records.
Access and correction of personal information
Under the Commonwealth Privacy Act (NSW) and the Health Records Act, an individual has the right to seek and obtain access to any personal information which the School holds about them and to advise the School of any perceived inaccuracy. Pupils will generally be able to access and update their personal information through their Parents.
There are some exceptions to these rights set out in the applicable legislation.
To make a request to access or to update any personal information the School holds about you or your child, please contact the School Executive Assistant at: email@example.com. The School may require you to verify your identity and specify what information you require.
Consent and rights of access to the personal information of pupils
The School respects every Parent’s right to make decisions concerning their child’s education.
Generally, the School will refer any requests for consent and notices in relation to the personal information of a pupil to the pupil’s Parents. The School 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 School about them or their child by contacting firstname.lastname@example.org. However, there may be occasions when access is denied. Such occasions 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 pupil.
The School may, at its discretion, on the request of a pupil grant that pupil access to information held by the School 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 warrant it.
Enquiries and complaints
If you would like further information about the way the School manages the personal information it holds, or wish to complain that you believe that the School has breached the Australian Privacy Principles please contact the School Principal at: email@example.com or call: 02 94501833. The School will investigate any complaint and will notify you of the decision in relation to your complaint as soon as is practical after it has been made.