This Policy is intended to be made available to students, parents, guardians, caregivers, prospective parents, job applicants, staff, volunteers, coaches, counsellors and others including past students, contractors, visitors and others that come into contact with the Centre.
- who we collect information from;
- the types of personal information collected and held by us;
- how this information is collected and held;
- the purposes for which your personal information is collected, held, used and disclosed;
- how you can gain access to your personal information and seek its correction;
- how you may complain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled;
- whether we are likely to disclose your personal information to any overseas recipients.; and
- how we report any data breaches.
Who do we collect personal information from?
At Columba Cottage Early Learning Centre, we collect personal information from students, parents, guardians, caregivers, prospective parents, job applicants, staff, volunteers, coaches, counsellors and others including past students, contractors, visitors and others that come into contact with the Centre.
It is noted that employee records are not covered by the Australian Privacy Principles or the Health Privacy Principles where they relate to current or former employment relations between the Centre and the employee.
What kinds of personal information do we collect?
The kinds of personal information we collect is largely dependent upon whose information we are collecting and why we are collecting it, however in general terms the Centre may collect:
- Personal Information including names, addresses and other contact details; dates of birth; next of kin details; financial information, photographic images and attendance records.
- Sensitive Information (particularly in relation to student and parent records) including religious beliefs, government identifiers, nationality, country of birth, languages spoken at home, professional memberships, family court orders and criminal records.
- Health Information (particularly in relation to student and parent records) including medical records, disabilities, immunisation details, individual health care plans, counselling reports, nutrition and dietary requirements.
How do we collect your personal information?
How we collect personal information will largely be dependent upon whose information we are collecting. If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible the Centre has attempted to standardise the collection of personal information by using specifically designed forms (e.g. an Enrolment Form). However, given the nature of our operations, we often also receive personal information by email, letters, notes, over the telephone, in face to face meetings, through financial transactions and through surveillance activities such as the use of CCTV security cameras or email monitoring.
We may also collect personal information from other people (e.g. a personal reference) or independent sources (e.g. a telephone directory), however we will only do so where it is not reasonable and practical to collect the information from you directly.
Sometimes we may be provided with your personal information without having sought it through our normal means of collection. We refer to this as “unsolicited information”. Where we collect unsolicited information we will only hold, use and/or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the information as appropriate.
How we use personal information
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.
Our primary uses of personal information include 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 the Centre’s community matters through correspondence, newsletters and magazines;
- promotional, marketing and fundraising activities;
- supporting community based causes and activities, charities and other causes in connection with the Centre’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;
- Centre administration including for insurance purposes;
- the employment of staff;
- the engagement of volunteers.
We only collect sensitive information reasonably necessary for one or more of these functions or activities, if we have the consent of the individuals to whom the sensitive information relates, or if the collection is necessary to lessen or prevent a serious threat to life, health or safety, or another permitted general situation (such as locating a missing person) or permitted health situation (such as the collection of health information to provide a health service) exists.
If we do not have the relevant consent and a permitted health situation or permitted general situation does not exist, then we may still collect sensitive information provided it relates solely to individuals who have regular contact with the Centre in connection with our activities. These individuals may include students, parents, volunteers, former students and other individuals with whom the Centre has regular contact in relation to our activities.
We will only use or disclose sensitive information for a secondary purpose if you would reasonably expect us to use or disclose the information and the secondary purpose is directly related to the primary purpose.
Storage and security of personal information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices including laptop computers, mobile phones, cameras and other recording devices. The Centre may store information in the ‘cloud’ which may mean that it resides on servers which are situated outside Australia.
The security of your personal information is of importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
These steps include:
- Restricting access to information on the Centre’s databases on a need to know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
- Ensuring all staff are aware that they are not to reveal or share personal passwords.
- Ensuring where sensitive and health information is stored in hard copy files that these files are stored in lockable filing cabinets in lockable rooms. Access to these records is restricted to staff on a need to know basis.
- Implementing physical security measures around the Centre’s buildings and grounds to prevent break-ins.
- Implementing ICT security systems, policies and procedures, designed to protect personal information storage on our computer networks.
- Implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
- Undertaking due diligence with respect to third party service providers who may have access to personal information, including cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
We ensure personal information is protected in accordance with our obligations under the Privacy Act 1988 (Cth), Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth).
Personal information we hold that is no longer needed is destroyed in a secure manner, deleted or de-identified as appropriate.
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their privacy policies.
When we disclose personal information
We only use personal information for the purposes for which it was given to us, or for purposes which are related (or directly related in the case of sensitive information) to one or more of our functions or activities. We may disclose your personal information to government agencies, other parents, other Schools, visiting teachers, counsellors and coaches, our service providers, agents, contractors, business partners and other recipients from time to time, only if one or more of the following apply:
- you have consented;
- you would reasonably expect us to use or disclose your personal information in this way;
- we are authorised or required to do so by law;
- disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
- where another permitted general situation or permitted health situation exception applies;
- disclosure is reasonably necessary for a law enforcement related activity.
Please note that as we are related parties, information will be shared between Columba Cottage Early Learning Centre and St Columba Anglican School if it is in the interest of the child’s health, safety or wellbeing, and/or educational welfare.
Personal information of students
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.
At Columba Cottage Early Learning Centre 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/guardians/caregivers. We will treat notices provided to parents/guardians/caregivers as notices provided to students and we will treat consents provided by parents/guardians/caregivers 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/guardians/caregivers.
There may also be occasions where parents/guardians/caregivers 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 Centre’s duty of care to the children.
Education and Care Services National Regulations
Children (Education and Care Services) National Law NSW
168: Education and care services must have policies and procedures.
181: Confidentiality of records kept by approved provider.
181-184: Confidentiality and storage of records.
National Quality Standards (NQS)
Quality Area 4: Staffing Arrangements
4.2.2. Professional standards Professional standards guide practice, interactions and relationships.
Quality Area 5: Relationship with Children
5.1.2 Dignity and rights of the child The dignity and the rights of every child are maintained at all times.
Quality Area 7: Governance and Leadership
7.1.2 Management systems Systems are in place to manage risk and enable the effective management and operation of a quality service.
Discover for yourself…