Highlands Christian College is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act. This statement outlines the privacy policy of the College and describes how the College uses and manages personal information provided to or collected by it.

The policy applies to board members, employers, employees, volunteers, parents/guardians and students, contractors, and people visiting the College site; and describes the type of information the College collects, how the information is handled, how and to whom the information is disclosed, and how the information may be accessed.

Responsibility: Principal with reference to College Board

LEGISLATION

  • Privacy Act 1988 (Cth)
  • Privacy Amendment (Enhancing Privacy Protection) Act 2012
  • Child Protection Policy
  • Disabilities PolicyDisclaimer: The information contained in this policy is to the best of our knowledge and belief correct at the date of publication. However, no warranty or guarantee is or can be given by Independent Schools Queensland or any member of its staff, and no liability is or can be accepted for any loss or damage resulting from any person relying on or using the information contained in this policy.

BACKGROUND

Exception in relation to employee records:

Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record held by the employing entity. As a result, this Privacy Policy does not apply to the College’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the College and employee.

Policy

This Privacy Policy sets out how Highlands Christian College manages personal information provided to or collected by it.

The College is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act.

The College may, from time to time, review and update this Privacy Policy to take account of new laws andtechnology, changes to the College’s operations and practices and to make sure it remains appropriate tothe changing College environment.

Note

POLICY

What kinds 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 health and other sensitive information, about:

  • students and parents and/or guardians (‘Parents’) before, during and after the course of a student’senrolment at the College;
  • job applicants, staff members, volunteers and contractors; and
  • other people who come into contact with the College.1. PERSONAL INFORMATION YOU PROVIDE:The College 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, emails and telephone calls. On occasions people other than Parents and students provide personal information.

    2. 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 College. As part of the enrolment process, the College will also request information kept on file from the students’previous school (where applicable).

Australian Privacy Principles (APPs) replace the existing National Privacy Principles (NPPs) that apply to businesses and the Information Privacy Principles (IPPs)

B. 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 by you, or to which you have consented.

1. Students and Parents

In relation to personal information of students and Parents, the College’s primary purpose of collection is toenable the College to provide schooling for the student. This includes satisfying the needs of Parents, the needs of the student and the needs of the College throughout the whole period the student is enrolled at the College.

The purposes for which the College uses personal information of students 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 College;
  • looking after students’ educational, social and medical wellbeing;
  • seeking donations and marketing for the College; and
  • 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 student or Parent, if the information requested is not provided, the College may not be able to enrol or continue the enrolment of the student or permit the student to take part in a particular activity.2. 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;
  • seeking donations and marketing for the College; and
  • to satisfy the College’s legal obligations, for example, in relation to child protection legislation.3. VolunteersThe 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.

    4. 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 provide a quality learning environment in which both students and staff thrive. Personal information held by the College may be disclosed to organisations that assist in the College’s fundraising.

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.

C. Who might the College disclose Personal Information to?

The College may disclose personal information, including sensitive information, held about an individual to:

  • another College or school;
  • government departments;
  • medical practitioners and other health care professionals;
  • people providing services to and for the College, including camp organisers / venues, specialist visiting teachers, counsellors and sports coaches;
  • setting up student accounts with on-line educational services such as, but not limited to, Mathletics, Lexia, Google Docs
  • recipients of College publications, including newsletters, magazines, and the College Website;
  • Parents;
  • anyone you authorise the College to disclose information to; and
  • anyone to whom we are required to disclose the information to by law.Sending Information OverseasThe 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 College exchange.
    However, 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.

D. 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; 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.

E. Management and security of personal information

The College’s staff are required to respect the confidentiality of students’ 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, 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. Where personal information is not required by law to be retained, the College employs reasonable steps to destroy collected information or to ensure that information is de-identified.

F. Updating Personal Information

The College endeavours to ensure that the personal information it holds in accurate, complete and up-to- date. A person may seek to update their personal information held by contacting the College at any time.

From time to time the College may request a review and/or update of details for Parents, staff, volunteers or others about whom personal information is held.

G. Access and Correction of Personal Information

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. Students will generally be able to access and update their personal information through their Parents, but older students may seek access and correction themselves.

There are some exceptions to these rights set out in the applicable legislation.

To make a request to access or update any personal information the College holds about you or your child, please contact the College Principal in writing. The College may require applications be made using a specific form (refer Appendix 5). 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 extensive, 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 reasons for refusal (refer Appendix 6). Notice of refusal will be provided in writing by the Principal. The College will respond a request to access personal information within 30 calendar days of receiving the written request.

H. Consent and Rights of Access to the Personal Information of Students

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 student to the student’s Parents. The College 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.

As mentioned above, 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 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 student.

The College may, at its discretion, on the request of a student grant that student access to information held by the College about them, or allow a student 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 student and/or the student’s personal circumstances so warranted.

I. 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 that 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 is practicable after it has been made.

J. Collection Notices

A variety of collection notices will be used to ensure an individual is reasonably aware of the matters in theNPP’s and also to obtain consent for uses and disclosures of personal information that may not be regardedas being for primary or secondary purposes to the collection.

The Standard Collection Notice (APPENDIX 1) will be: (a) reproduced in enrolment packages;
(b) contained in this Policy;
(c) located on the College’s website; and;

(d) printed in the Parent Handbook, given to all new and existing parents/guardians and updated bi- annually.

The Alumni Collection Notice (APPENDIX 2) will be sent to all past students, where possible.

The Employment Collection Notice (APPENDIX 3) will be sent to all job applicants with an acknowledgement of receipt of an application for employment at the College.

The Contractor/Volunteer Collection Notice (APPENDIX 4) will be sent to all contractors (including instrumental music teachers) and volunteers.


APPENDIX 1

Standard Collection Notice

  1. The College collects personal information, including sensitive information, about students and parents or guardians before and during the course of a student’s enrolment at the College. This may be in writing or in the course of conversations. The primary purpose of collecting this information is to enable the College to provide schooling to the student and to enable them to take part in all the activities of the College.
  2. Some of the information we collect is to satisfy the College’s legal obligations, particularly to enable the College to discharge its duty of care.
  3. Laws governing or relating to the operation of a College require certain information to be collected and disclosed. These include relevant Education Acts, and Public Health and Child Protection laws.
  4. Health information about students is sensitive information within the terms of the Australian Privacy Principles under the Privacy Act. We will ask you to provide medical reports about students from time to time.
  5. The College from time to time discloses personal and sensitive information to others for administrative and educational purposes, including facilitating the transfer of a student to another College. This includes to other Colleges or schools, government departments, medical practitioners, and people providing services to and for the College, including specialist visiting teachers, coaches, volunteers and counsellors.
  6. Personal information collected from students is regularly disclosed to their parents or guardians.
  7. The College may store personal information online (in the ‘cloud’) which may mean that it resides on servers which are situated outside Australia.
  8. The College’s Privacy Policy sets out how parents or students may seek access to personal information collected about them. However, there will be occasions when access is denied. Such occasions would include where access would have an unreasonable impact on the privacy of others, where access may result in a breach of the College’s duty of care to the student, or where students have provided information in confidence.
  9. The College Privacy Policy also sets out how you may complain about a breach of privacy and how the College will deal with such a complaint.
  10. As you may know the College from time to time engages in fundraising activities. Information received from you may be used to make an appeal to you. It may also be disclosed to organisations that assist in the College’s fundraising activities solely for that purpose. We will not disclose your personal information to third parties for their own marketing purposes without your consent.
  11. On occasions information such as academic and sporting achievements, student activities and similar news is published in College newsletters and magazines and on our website. Photographs of student activities such as sporting events, College camps and College excursions may be taken for publication in College newsletters and magazines and on our website.
  12. We may include your contact details in a class list or College directory. If you do not agree to this you must advise us in writing immediately.
  13. If you provide the College with the personal information of others, such as doctors or emergency contacts, we encourage you to inform them that you are disclosing that information to the College and why, that they can access that information if they wish and that the College does not usually disclose this information to third parties.

14. Information provided by an overseas student to College may be made available to Commonwealth

and State government agencies in accordance with applicable legislation. Such information may also be disclosed to a health insurance provider if the College is arranging health insurance cover on behalf of the overseas student.

IMPORTANT: Unless and until you advise us in writing that you do not consent to our use and disclosure of your personal information in the manner described in this notice, we will act on the basis that we have your consent to each such use and disclosure.

APPENDIX 2
Alumni Collection Notice

  1. We may collect personal information about you from time to time. The primary purpose of collecting this information is to enable us to inform you about our activities and the activities of Highlands Christian College and to keep alumni members informed about other members, reunions and past student events.
  2. We must have the information referred to above to enable us to continue your association with the College.
  3. From time to time we engage in fundraising activities. The information received from you may be used to make an appeal to you. It may also be used by the College to assist in its fundraising activities. If you do not agree to this, you must advise the College immediately. The College contact details are:

a. Postal Address: PO Box 7239, Toowoomba South, Qld 4350 b. Email: enquiries@coct.qld.edu.au
c. Telephone: 07 4617 6555

  1. We may publish details about you in our publications and the College’s website. If you do not agree to this, you must advise the College immediately.
  2. The College may store personal information online (in the ‘cloud’), which may mean that it resides on servers which are situated outside Australia.
  3. You may seek access to your personal information by contacting the College.
  4. If you provide personal information to us about other people, we encourage you to inform them ofthe above matters.

APPENDIX 3
Employment Collection Notice

1. In applying for this position you will be providing Highlands Christian College with personal information. The College contact details are:

d. Postal Address: PO Box 7239, Toowoomba South, Qld 4350 e. Email: enquiries@coct.qld.edu.au
f. Telephone: 07 4617 6555

If you provide us with personal information, for example, your name and address or information contained on your CV or resume, we will collect the information in order to assess your application. We may keep this information for a period of up to 12 months from the relevant application closing date.

  1. The College’s Privacy Policy contains details of how you may complain about a breach of the APPs or how you may seek access to personal information collected about you. However, there may be occasions when access is denied. Such occasions would include where access would have an unreasonable impact on the privacy of others.
  2. We will not disclose this information to a third party without your consent.
  3. We are required to conduct a criminal record check to collect information regarding whether youare or have been the subject of an Apprehended Violence Order and certain criminal offences under Child Protection laws. We may also collect personal information about you in accordance with these laws.
  4. The College may store personal information online (in the ‘cloud’), which may mean that it resides on servers which are situated outside Australia.
  5. If you provide us with the personal information of others, we encourage you to inform them that you are disclosing that information to the College and why, that they can access that information if they wish and that the College does not usually disclose the information to third parties but that we may store their information for up to 12 months.

APPENDIX 4
Contractor/Volunteer Collection Notice

1. In applying to provide services to the College, you will be providing Highlands Christian College with personal information. The College contact details are:

a. Postal Address: PO Box 7239, Toowoomba South, Qld 4350 b. Email: enquiries@coct.qld.edu.au
c. Telephone: 07 4617 6555

  1. If you provide us with personal information, for example your name and address or information contained on your resume, we will collect the information in order to assess your application. We may also make notes and prepare a confidential report in respect of your application.
  2. You agree that we may store this information for for the term of your contract and thereafter as required by the College.
  3. The College’s Privacy Policy sets out how you may seek access to your personal information and how you may complain about a breach of the APPs.
  4. We will not disclose this information to a third party without your consent.
  5. We are required to collect information regarding whether you are or have been the subject of anApprehended Violence Order and certain criminal offences under Child Protection law, for applicants who are not parents. We may also collect personal information about you if wedetermine a requirement for you to hold a “blue card” issued by the Commission for Children and Young People and Child Guardian in Queensland.
  6. The College may store personal information online (in the ‘cloud’), which may mean that it resides on servers which are situated outside Australia.
  7. If you provide us with the personal information of others, we encourage you to inform them that you are disclosing that information to the College and why, that they can access that information if they wish and that the College does not usually disclose the information to third parties by that we may store their information for up to 12 months.

APPENDIX 5
Request for Access to Personal Information

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