Privacy Policy
The Privacy Act 1988 requires entities bound by the Australian Privacy Principles to have a privacy policy. This privacy policy outlines the personal information handling practices of Wesley College Melbourne.
This Policy is written in plain language. The specific legal obligations of the College when collecting and handling your personal information are outlined in the Privacy Act 1988 and specifically the Australian Privacy Principles found in that Act. We will update this privacy policy when our information handling practices change. Updates will be publicised on our Website and through our Intranet.
Overview
The College collects, holds, uses and discloses personal information to carry out the functions and activities under the Privacy Act 1988 and other legislation that confers obligations to schools including the Victorian Health Records Act 2001.
These functions and activities include:
- Enrolling students and processing applications
- Performing our duty of care and child protection legal obligations to students while at school
- Hiring and managing staff members, volunteers and contractors
- Communicating to our community and to the public
- Maintaining our records and databases
- Meeting our legislative reporting requirements to government agencies
At all times we try to only collect the information we need for the particular function or activity we are carrying out. We will explain to you clearly the reason for the collection and how it may be used.
The main way we collect personal information about you is when you provide it to the College upon request. More specifically:
- Paper or online forms filled out by parents, students and staff
- Through visitor kiosks at our campus receptions
- Face to face meetings and interviews, and telephone calls
- When you apply for employment at the College
- Enquiries from prospective parents through our Website or via email/phone
- From a third party, for example a report provided by a medical professional or a personal reference from another organisation
- Photographs and videos taken of students, staff and parents at formal and informal College functions and events
- Through the use of cookies on our College Website to record usage statistics
- Social networking services such as Twitter, Facebook and YouTube to communicate with the public about our events and news. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service will also handle your personal information for its own purposes. These services have their own privacy policies
- Indirectly through publicly available sources
In some circumstances persons may opt out of the collection of personal information for specific purposes. This may include not being included in distribution lists for marketing materials, the use of your photograph in a publication or your contact details being available to other same year level parents. In such specific circumstances an opt out option will be available.
Sensitive information includes matters of health, gender, race, ethnicity, religious beliefs, family court orders, financial information and criminal history. The College will sometimes need to collect sensitive information to carry out its functions and activities. These include:
- To provide a safe environment for our staff and students by being aware of and catering for dietary requirements, allergies, immunization details and individual health care plans
- Managing our accommodation needs at our Learning in Residence, Clunes, Yiramalay and Outdoor Education sites and all other overnight camps and excursions
- Managing gender ratios in student classes to meet our coeducational requirements
- To be able to provide immediate first level health care to students while in the care of the College
- To assist employees with return to work plans, manage work related injuries and our obligations under Occupational Health and Safety laws
- To provide pastoral care support to students
- Ensuring all of our employees and contractors have current police and Working With Children checks. These must be provided to the College and remain current during an employee’s contract with the College.
Where possible, we will allow you to interact with us anonymously. For example, if you contact our College enquiries number with a general question we will not ask for your name unless we need it to adequately handle your question.
However, for most of our functions and activities we usually need your name and contact information and enough information about the matter to enable us to fairly and efficiently handle your inquiry, request, complaint or application.
The College uses your personal information in a variety of ways to meet its legal obligations and to provide its educational services. These include:
- To enrol students and provide them with the appropriate schooling, facilities and educational tools
- To keep parents informed about matters related to their child's schooling, through correspondence, including assessment reports, newsletters and magazines
- Day-to-day administration
- To receive income and to meet our financial obligations
- To market and seek attendees to events and functions
- Looking after students' educational, social, emotional and medical well-being
- Using photographs and videos of staff, parents and students in class photos, news articles, publications, the College social media channels and website
- Seeking donations and other philanthropic opportunities for the College
- Recording our history
- To be able to assess potential employees and contractors and then engage and administer their employment
- Seeking funds and marketing for the College
- To satisfy the College's legal obligations, for example, in relation to child protection legislation
- Providing parent occupation and highest education level data to government agencies to allow them to calculate applicable school funding
- The College also obtains personal information about volunteers who assist the College in its functions or conduct associated activities, such as the Old Wesley Collegians Association (OWCA), 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 students 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 Fundraising Foundation or OWCA.
The College may disclose personal information, including sensitive information, held about an individual to:
- Another school
- Government agencies
- Medical practitioners
- People providing services to the College, including specialist visiting teachers and sports coaches
- Recipients of College publications, like newsletters and magazines
- College’s legal representatives and/or financial collection agency in the event of payment default or legal proceedings
- College employees with injury management and injury prevention responsibilities
- Parents and anyone to whom you authorise the College to disclose information
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)
- Otherwise complying with the National Privacy Principles
Web traffic information is disclosed to Google Analytics when you visit our website. Google stores information across multiple countries.
When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.
An amendment to the Privacy Act requires the College from February 2018 to report and disclose any breaches of privacy that seriously affects any individuals the College manages personal information about. The disclosure will be made to both the individuals affected and to the Australian Office of the Information Commissioner.
Web traffic information is disclosed to Google Analytics when you visit our website. Google stores information across multiple countries.
When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.
An amendment to the Privacy Act requires the College from February 2018 to report and disclose any breaches of privacy that seriously affects any individuals the College manages personal information about. The disclosure will be made to both the individuals affected and to the Australian Office of the Information Commissioner.
- regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information
- taking measures to address those risks, for example, we keep a record (audit trail) of when someone has added, changed or deleted personal information held in our electronic databases and regularly check that staff only access those records when they need to
- conducting regular internal and external audits to assess whether we have adequately complied with or implemented these measures
- destroying personal information in a secure manner when we no longer need it in line with the Victorian Retention and Disposal Authority for School records 2017.
The Privacy Act Amendment (Notifiable Data Breaches) 2017 requires organisations like the College to notify all individuals affected by a data breach where that breach is likely to result in serious harm. The Australian Office of the Information Commissioner must also be notified of the details of any breach that meets the criteria for notification.
The College’s notifiable data breach response plan will be used in the event that a breach is suspected or occurs. The response plan is published on the College’s Intranet accessible by all parents, students and employees.
The College endeavours to ensure that the personal information it holds is accurate, complete and current. We achieve this by:
- recording information in a consistent format
- where necessary, confirm the accuracy of information we collect from a third party or a public source
- promptly add updated or new personal information to existing records
- regularly audit our contact lists to check their accuracy
- review the quality of personal information before we use or disclose it
Under the Privacy Act (Australian Privacy Principles 12 and 13) you have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information. You can ask for access or correction by contacting us and we must respond within 30 days. If you ask, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to. There are some exceptions to this right set out in the Act. Students will generally have access to their personal information through their Parents.
We will ask you to verify your identity before we give you access to your information or correct it, and we will try to make the process as simple as possible. If we refuse to give you access to, or correct, your personal information, we must notify you in writing setting out the reasons.
If we make a correction and we have disclosed the incorrect information to others, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.
If we refuse to correct your personal information, you can ask us to associate with it (for example, attach or link) a statement that you believe the information is incorrect and why.
Parents can request access any information the College holds about them or their child, by contacting the relevant Head of Campus in writing. 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, or according to other exemptions stated in the Privacy or Health Records Acts.
Employees and contractors may request access to their personal information by contacting the Human Resources Director 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 extensive, the College will advise the likely cost in advance. It may take 30-45 days for the information to be made available.
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.
The College may, at its discretion, 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.
- 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. The primary purpose of collecting this information is to enable the College to provide schooling for your son/daughter.
- 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.
- Certain laws governing or relating to the operation of schools require that specific information is collected. These include the Victorian Health Records Act 2001 and Child Protection laws.
- Health information about students is sensitive information within the terms of the Australian Privacy Principles under the Commonwealth Privacy Act 1988. We ask you to provide medical information about your child when necessary.
- The College from time to time discloses personal and sensitive information to others for administrative and educational purposes. This includes to other schools, government departments, medical practitioners and people providing services to the College, including specialist visiting teachers, sports coaches, volunteers and contractors.
- If we do not obtain the information referred to above we may not be able to enrol or continue the enrolment of your son/daughter, or allow him/her to participate in associated activities.
- Personal information collected from students is regularly disclosed to their parents or guardians. On occasions information such as academic and sporting achievements, student activities and other news is published in College newsletters, magazines and on our website.
- Parents may seek access to personal information collected about them and their son/daughter by submitting a written request to the relevant Head of Campus. Students may also seek access to personal information 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.
- The College engages in fundraising activities and 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.
- We may include your contact details in a class list, but will seek your permission to do so.
- 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 the information to third parties.
- Student records are archived to meet the needs for a range of possible future inquiries and for historical purposes. Other personal information is destroyed as per regulatory requirements.
Related Documents:
- Australian Privacy Act 1988
- Australian Privacy Principles 2014
- Victorian Health Records Act 2001
- Victorian Retention and Disposal Authority for Records of School Records 2017
- Wesley College Human Resources Privacy Policy 2018
- Wesley College Notifiable Data Breach Response Plan 2018
- Wesley College Social Media Policy 2018
- Wesley College Photography, Filming and Recording Policy 2018
- Wesley College Collection Notice 2018