Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as a student, contractor, volunteer, stakeholder, job applicant, alumni, visitors or others that come into contact with the school.
In the course of providing services we may collect and hold:
Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).
The collection of personal information depends on the circumstances in which Immanuel College is collecting it.
- We collect personal information via forms (e.g. an Enrolment Form), as well as email, letters, notes, via our website, over the telephone, in face-to-face meetings, through financial transactions and through surveillance activities such as CCTV or email monitoring.
- We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources.
- We collect information website data via "cookies’’ and other data collection methods to improve our website and marketing. We do not use this information to personally identify individuals.
We may be provided with personal information without having sought it through our normal means of collection, such as misdirected postal mail & email and employment applications sent to us that are not in response to an advertised vacancy
We only collect sensitive information if it is:
- reasonably necessary for our functions, and we have the individual’s consent
- necessary to lessen or prevent a serious threat to life, health or safety
- another permitted general or health situation.
We only use personal information that is reasonably necessary for our functions or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented including, but are not limited to:
- providing education, pastoral care, extra-curricular and health services
- satisfying our legal obligations including our duty of care and child protection obligations
- keeping parents informed as to school community matters through correspondence, newsletters and magazines
- marketing, promotional and fundraising activities
- supporting the activities of school associations such as Immanuel College Old Scholars Association and Immanuel College Parents and Friends Association
- supporting the activities of the College foundation
- supporting community based causes and activities, charities and other causes in connection with the School’s functions or activities
- helping us to improve our day-to-day operations including training our staff
- systems development; developing new programs and services; undertaking planning, research and statistical analysis
- school administration including for insurance purposes
- the employment of staff & the engagement of volunteers.
We store personal information in a variety of formats and takes all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:
- Restricting access and user privilege of information by staff depending on their role and responsibilities.
- Ensuring staff do not share personal passwords.
- Ensuring hard copy files are stored in lockable filing cabinets in lockable rooms.
- Ensuring access to Immanuel College’s premises are secured at all times.
- Implementing physical security measures around the school buildings and grounds to prevent break-ins.
- Ensuring our IT and cyber security systems, policies and procedures are implemented and up to date.
- Ensuring staff comply with internal policies and procedures when handling the information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information to ensure as far as practicable that they are compliant with the APPs or a similar privacy regime.
- The destruction, deletion or de-identification of personal information we hold that is no longer needed, or required to be retained by any other laws.
Immanuel College will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).
If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.
Personal information is used for the purposes for which it was given to Immanuel College, or for purposes which are directly related to one or more of our functions or activities.
Personal information may be disclosed, if the individual:
- Has given consent; or
- Would reasonably expect the personal information to be disclosed in that manner.
Immanuel College may disclose personal information without consent or in a manner which an individual would reasonably expect if:
- We are required to do so by law.
- The disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety.
- Another permitted general situation applies.
- Disclosure is reasonably necessary for a law enforcement related activity.
- Another permitted health situation exists.
Personal information about an individual may be disclosed to an overseas organisation in the course of providing our services, for example when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
- we have the individual’s consent (which may be implied);
- we have satisfied ourselves that the overseas recipient is compliant with the APPs, or a similar privacy regime;
- we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or
- we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.
We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.
If Immanuel College becomes aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.
You may submit a request to us to access the personal information we hold, or request that we change the personal information. We will take steps to verify your identity before granting access or correcting the information.
The Privacy Act does not differentiate between adults and children and does not specify an age after which individuals can make their own decisions with respect to their personal information.
We take a common sense approach to dealing with a student’s personal information and generally will refer any requests for personal information to a student’s parents/carers. We will treat notices provided to parents/carers as notices provided to students and we will treat consents provided by parents/carers as consents provided by a student.
We are however cognisant of the fact that children do have rights under the Privacy Act, and that in certain circumstances (especially when dealing with older students and especially when dealing with sensitive information), it will be appropriate to seek and obtain consents directly from students. We also acknowledge that there may be occasions where a student may give or withhold consent with respect to the use of their personal information independently from their parents/carers.
There may also be occasions where parents/carers are denied access to information with respect to their children, because to provide such information would have an unreasonable impact on the privacy of others, or result in a breach of the school’s duty of care to the student
You can make a complaint about how Immanuel College manages personal information, including a breach of the APPs, by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response. Immanuel College does not charge a fee for the handling of complaints. If you are not satisfied with our response, you may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.
If practical, you can contact us anonymously or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do.