Loreto College Privacy Policy
Purpose
Loreto College (hereinafter referred to as the College) is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act. This policy sets out how the College uses and manages the personal information provided to or collected by it. The College may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the College's operations and practices and to make sure it remains appropriate to the changing school environment.
Scope
This Policy applies to Loreto College owned, operated and administered by Loreto College Marryatville Association Incorporated.
Related Documents
- South Australian Catholic Schools Enterprise Agreement 2013
- Fair Work Act 2009 (Cth)
Definitions
'the College' includes Loreto College as well as sites on which staff or others are engaged in duties or activities such as excursions or conference attendance sanctioned by the College.
'Staff' means staff employed by the College.
'Volunteer' means volunteers who provide services to the College on a voluntary basis.
Policy
4.1 What kinds of personal information does The College collect and how does it 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's enrolment at the College;
- job applicants, staff members, volunteers and contractors; and
- other people who come into contact with the College.
- 4.1.1 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.
- 4.1.2 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 school.
- 4.1.3 Exception in relation to employee records: Under the Privacy Act the Australian Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to The College treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the College and the employee.
4.2 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, or to which you have consented.
4.3 Students and Parents:
In relation to personal information of students and Parents, the College's primary purpose of collection is to enable 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;
- looking after students' educational, social, spiritual and medical wellbeing;
- seeking donations and marketing for the College; and
- to contribute to aggregated data that the College may require from time to time to meet its reporting, planning, contract and funding responsibilities;
- 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 obtained, the College may not be able to meet its legal obligations or to enable a quality learning environment for students.
4.4 Job applicants, staff members and contractors:
In relation to personal information of job applicants, staff members and contractors, the College 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;
- to contribute to aggregated data that The College uses to meet its reporting, planning, contract and funding responsibilities;
- to enable The College to maintain necessary staff information for entitlements including long service leave, maternity leave, workers compensation and other necessary industrial or employment purposes, and for accreditation and funding purposes.
- to satisfy The College legal obligations, for example, in relation to child protection legislation.
4.5 Volunteers:
The College also obtains personal information about volunteers who assist the College in its functions or conduct associated activities, such as to enable the College and the volunteers to work together.
4.6 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 enable a quality learning environment in schools in which both students and staff thrive. Personal information held by the College may be disclosed to an organisation that assists in College fundraising.
Parents, staff, contractors and other members of the wider 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.
4.7 To whom might the College disclose personal information?
The College may disclose personal information, including sensitive information, held about an individual to:
- another school;
- a Catholic Education Office in South Australia
- government departments;
- the local Catholic parish;
- people providing services to The College;
- recipients of The College publications, such as newsletters and magazines;
- Parents;
- anyone you authorise The College to disclose information to; and
- anyone to whom we are required to disclose the information by law.
4.7.1 Sending information overseas:
The 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. 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.
4.9 How does the College treat 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.
4.10 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 held 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.
4.11 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. There are some exceptions to this right set out in the Act. 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 Principal 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. If we cannot provide you with access to that information, we will provide you with written notice explaining the reasons for refusal.
4.12 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 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.
4.13 Enquiries
If you would like further information about the way the College manages the personal information it holds please contact the Principal.
Consequences of a Breach
If you wish to complain that you believe the College has breached the Australian Privacy Principles, please contact the Principal. The College will investigate any complaint and will notify you of a decision in relation to your complaint as soon as is practicable after it has been made
Related Policies and/or Procedures
This Policy is to be read in conjunction with, and is additional to, any other relevant South Australian Commission for Catholic Schools (SACCS), College or CEO Policy, Procedure or Guideline. All Staff are required to comply with the provisions of any such document, including the following:
SACCS Code of Conduct
SACCS Charter for Staff
Loreto College Loreto College, Technology and Me
Related Documents/Links
Privacy Amendment (Enhancing Privacy Protection) Bill 2012
www.comlaw.gov.au/privacy amendments
National Catholic Education Commission and National Council of Independent Schools' Association Privacy Compliance Manual September 2013
CESA privacy collection
Office of the Federal Privacy Commissioner
www.privacy.gov.au
Privacy Collection - Policy and collection notice templates for schools, privacy information for enrolments, employees, volunteers, contractors, etc.
CESA privacy collection
Document Control
Prepared by:
| Position | Incumbent | Date |
|---|---|---|
| Director of Staff | Anna Fitzpatrick | 25 July 2014 |
Reviewed by:
| Position | Incumbent | Date |
|---|---|---|
| Principal | Rosalie Gleeson | 29 July 2014 |
| Deputy Principal | Philip Donato | 29 July 2014 |
| Director of Business Operations | Paul Noon | 29 July 2014 |
| Director of Staff | Anna Fitzpatrick | 29 July 2014 |
Approved by:
| Position | Incumbent | Date |
|---|---|---|
| Principal | Rosalie Gleeson | 1 August 2014 |
| Deputy Principal | Philip Donato | 1 August 2014 |
| Director of Business Operations | Paul Noon | 1 August 2014 |
| Director of Staff | Anna Fitzpatrick | 1 August 2014 |
History
| Issue Status | Description of Change | Date | Review Date |
|---|---|---|---|
| 1 | Privacy Policy | ||
| 2 | Revised Document | 1 August 2014 | 1 May 2019 |