This statement outlines Ivanhoe Grammar School’s arrangements concerning its management of personal information provided to, or collected by the School.
The School is bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). In relation to health records held by the school the school is also bound by the Health Records Act 2001 (Vic).
The School recognises and acknowledges that the protection of individuals’ privacy is important and required under the relevant legislation. This statement explains how the School protects the privacy of personal information and health information which the School collects and uses, how the School may use such information and to whom such information may be disclosed, and how individuals can access their personal information held by the School, correct any personal information held by the School, lodge complaints in relation to alleged breaches of privacy or make any related enquiry.
All members of School staff, contractors and volunteers must comply with this policy in relation to any personal information they handle in the course of carrying out their duties on the School’s behalf.
Personal information may be collected from any individual with whom the School may have contact (including current and prospective students and their parents/guardians, alumni, job applicants, volunteers, contractors, past employees and other individuals who come into contact with the School).
The School may also collect, use and disclose health information in relation to the provision of health services to students while they are in the care of the School.
A) The type of information the School collects and holds, embraces (but is not limited to) personal information, including sensitive information about:
• Students and parents and/or guardians (“Parents”) before, during and after the course of a student’s enrolment at the School;
• Job applicants, staff members, volunteers and contractors; and
• Other people who come into contact with the School.
Personal Information provided by or about Parents and Students: The School will generally collect personal information held about an individual by way of forms filled out by Parents or students and submitted to the School, face-to-face meetings and interviews and telephone calls, mail correspondence, emails and other electronic means (including by accessing the School’s website and the use of the “contact us” form), publicly available sources of information, reference from another school about an individual student and a report provided to the School by a medical professional in relation to health services previously provided or to be provided by the School to an individual.
From time to time, the School may seek the consent of parents/guardians to use their child’s name, image and likeness in materials produced or published by or for the School (including newsletters, magazines, posters and other advertising materials to promote the School and its services). Where parents/guardians do not consent to their child’s name, image and likeness being used by the School in this manner, the School will refrain from using their child’s name, image and likeness.
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 the personal information is collected: The School will usually collect personal information directly from the individual, unless it is unreasonable or impracticable to do so. Additionally, the School will usually only collect personal information when the School asks for that personal information. However, the School may from time to time receive unsolicited personal information about an individual. Where the School determines that it could not have collected such personal information lawfully, then the School will promptly destroy or de-identify such information.
Exception in relation to employee records: Although records of employees are exempt under the Privacy Act 1988 (Cth), the School is bound to maintain the confidentiality of such records in accordance with the requirements of the Fair Work Act 2009 (Cth).
B) Use of the personal information provided
The School generally only uses personal information for the primary purpose for which the information was collected or a secondary purpose when permitted by the Privacy Act. Generally, the School collects personal information for the purpose of facilitating its ability to function as an educational institution.
From time to time you may be able to deal with the School anonymously or by using a pseudonym. For example (without limitation) if you have a general inquiry about the School and/or its services, the School may be able to respond to your inquiry on an anonymous or pseudonymous basis. However, if you do not provide the personal information the School requests, or you provide the information anonymously or pseudonymously, then the School may be unable to fulfil its functions as an educational institution to you or to your child or discharge its duty or care to you or to your child.
Further, in some situations, the School may need to verify your identity as part of the School’s response to a request for access and/or correction of personal information and/or health information the School holds about an individual, or as part of the School’s complaints-handling procedure.
Students and Parents: In relation to personal information of students and Parents, the School’s primary purpose of collection is to enable the School to provide quality schooling for its pupils. This includes satisfying both the needs of Parents and the needs of the student throughout the whole period the student is enrolled at the School.
The purposes for which the School uses personal information of students and Parents include:
• Keeping Parents informed about matters related to their child’s schooling, through correspondence, newsletters and magazines;
• Day-to-day administration;
• Looking after students’ educational, social and medical well-being;
• Assessing applications for scholarships to attend the School and awarding and administering scholarships to current students at the School;
• Addressing queries or resolving complaints;
• Seeking donations and marketing for the School; and
• Satisfying the School’s legal obligations and allowing the School to discharge its duty of care.
In some cases where the School requests personal information about a student or
Parent, if the information requested is not obtained, the School may not be able to enrol or continue the enrolment of the student.
Images of the School's students, staff, alumni and visitors are used in many instances via the School's Magazine, Newsletters, Website and other public relations material, for both internal and external promotion of the School and its activities. Specific permission is obtained from parents with regards to the use of students photographs at the time of the annual record check.
Job Applicants, Staff Members and Contractors: In relation to personal information of job applicants, staff members and contractors, the School’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 School uses personal information of job applicants, staff members and contractors include:
• Administering the individual’s employment or contract, as the case may be;
• For insurance purposes;
• Seeking funds and marketing for the School;
• Satisfying the School’s legal requirements.
Volunteers: The School also obtains personal information about volunteers who assist the School in its functions or conduct associated activities such as (alumni associations), to enable the School and the volunteers to work together.
Marketing and Fundraising: The School regards marketing and fundraising for the future growth and development of the School as an important part of ensuring that the School continues to be a quality learning environment in which both pupils and staff thrive. Personal information held by the School may be disclosed to an organization that assists in the School’s fundraising, for example, the School’s Development or Alumni organisations.
Parents, staff, contractors and other members of the wider School community may from time to time receive fundraising information. School publications such as newsletters and magazines, which include personal information, may be used for marketing purposes.
C) Disclosure of personal information.
The School may disclose personal information, including sensitive information, held about an individual to:
• Another school;
• Government departments;
• Medical practitioners;
• its bankers, professional advisers, courts, tribunals and regulatory authorities;
• People providing services to the School, including specialist visiting teachers and sports coaches;
• Recipients of School publications, including newsletters and magazines;
• Parents; and
• Others who have been so authorized.
Such information may be disclosed for the purpose of:
• facilitating the School’s compliance with its obligations owed to a party under any contract between the School and the party, or as required by law;
• enabling those third parties to perform services on behalf of the School; and
• recovering debts where amounts owed to the School in consideration for services the School provides remain due and outstanding beyond the payment term.
Direct marketing: The School may directly market its services to you on the basis that you would reasonably expect the School to do so, where the School has already collected your personal information directly from you. Where the School collects personal information about you from a third party, the School will not use that information to directly market to you without your consent. The School will also comply with other laws relevant to marketing (including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Competition and Consumer Act 2010 (Cth)). All direct marketing communications which the School sends will include an easy opt-out procedure if at any time you wish the School to stop sending you information about the School or its services.
Cross-border transfer or disclosure of information: 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 eg: International Baccalaureate Students); or
• Otherwise complying with the Australian Privacy Principles.
D) Sensitive information
In referring to “sensitive” personal information, the School means: information relating to a person’s racial or ethnic origins, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record and health 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 agreed otherwise, or where the use or disclosure of that sensitive information is allowed by law.
The School may use health information collected about an individual for the purpose of providing health services to that individual where required. The School may disclose health information to a medical professional or to a health service provider where that professional or provider is engaged in providing health services to an individual. The School will not use or disclose such information for a purpose other than the primary purpose of collection unless:
• the individual consents to the use or disclosure;
• the secondary purpose is directly related to the primary purpose and the individual would reasonably expect the School to use or disclose the information for the secondary purpose;
• the use or disclosure is required, authorised or permitted, whether expressly or impliedly by or under law; or
• as otherwise authorised, permitted or required under the Health Records Act 2001 (Vic).
The School may transfer health information about an individual to an entity other than the School or the individual which is outside Victoria only when the School reasonably believes that the recipient is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the requirements under the Health Records Act 2001 (Vic), if the individual consents to the transfer or otherwise as permitted under the Health Records Act 2001 (Vic).
E) Management and security of personal information
The School’s staff are required to respect the confidentiality of students’ 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, loss, unauthorised access, modification or disclosure by use of various methods, including locked storage of paper records and pass worded access rights to computerised records.
Additionally the School takes reasonable steps to destroy or de-identify personal information it holds about an individual if the School no longer requires that personal information.
The School will only retain personal information for the period necessary for the use for which it is submitted to the School.
F) Updating personal information
The School endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. A person may seek to update their personal information held by the School by contacting the School’s Privacy Officer at any time.
The Australian Privacy Principles require the School to store personal information no longer than necessary.
G) Checking personal information held by the School
Under the Commonwealth Privacy Act, an individual has the right to obtain access to any personal information which the School holds about them and to advise the School of any perceived inaccuracy. There are some exceptions to this right, set out in the Act. Students will generally have access to their personal information through their Parents.
To make a request to access any information the School holds about you or your
child, please contact the School’s Privacy Officer in writing.
The School may require verification of identity and details of what information is required. The School may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, the School will advise the likely cost in advance.
H) Consent and rights of access to the personal information of students
The School respects every Parent’s right to make decisions concerning their child’s education.
Generally, the School will direct any request for consent and notices in relation to the personal information of a student, to the student’s Parents. The School 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.
Parents may seek access to personal information held by the School about them or their child by contacting the School’s Privacy Officer. However, there will be occasions when access is denied such as 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 student.
The School may, at its discretion on the request of a student, grant that student access to information held by the School 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 student involved had reached 18 years of age, but the School could do so in other circumstances when the maturity of the student and/or the student’s personal circumstances so warranted.
In addition to the above, the School may from time to time refuse an individual access to the information the School holds about the individual, in accordance with the relevant legislation. Where the School refuses access, the School will give an explanation for the refusal in writing.
Lodging a complaint
If you wish to complain about an alleged breach of the privacy of your personal information, the complaint should be made in writing to the attention of the School’s Privacy Officer at the address below.
The School will acknowledge receipt of your complaint and will endeavour to deal with your complaint and provide you with a response within a reasonable period of time following receipt of your complaint (generally 30 days of receipt of your complaint). Where a complaint requires a more detailed investigation it may take longer to resolve. If this is the case, the School will endeavour to provide you with progress reports.
The School reserves the right to verify your identity and seek (where appropriate) information from you and other relevant individuals in connection with the complaint.
Where required by law, the School will acknowledge your complaint in writing and provide information in writing on how we will deal with your complaint. Further, if required to do so by law, the School will provide its determination on your complaint to you in writing.
The School reserves the right to refuse to investigate and deal with a complaint if the School considers it to be vexatious or frivolous.
If you are dissatisfied with the outcome of your complaint, you may seek an internal review of the School’s decision, which will be completed by an officer not previously involved in your complaint. If you remain dissatisfied, you may escalate your complaint to the Office of the Australian Information Commissioner.
If you would like to solicit, collect or deal with personal information in a way that is not explicitly described above written permission from the Schools Privacy Officers (the Business Manager, the Deputy Principal, Head of Campus TRC, Deputy Principal Head of Campus Plenty or Head of Campus Buckley House) or delegate is required.