This statement outlines the Brighton Grammar School’s policy on how the School uses and manages personal information provided to or collected by it.
The School is bound by the Australian Privacy Principles (Privacy Principles) contained in the Privacy Act 1988 (Cth) (Privacy Act).
What kind of personal information does the School collect and how does the School collect it?
The type of information the School collects and holds includes (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 you provide: The School 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, and telephone calls. On occasions people other than Parents and students provide personal information.
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 will the School use the personal information you provide?
The School 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.
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 schooling for the student. 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:
- To keep Parents informed about matters related to their child’s schooling, through correspondence, newsletters, School social media sites, the School website and magazines;
- Day-to-day administration;
- Looking after students’ educational, social and medical wellbeing;
- Seeking donations and marketing for the School;
- To satisfy the School’s legal obligations and allow 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.
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:
- Ιn administering the individual’s employment or contract, as the case may be;
- For insurance purposes;
- Seeking funds and marketing for the School;
- Τo satisfy the School’s legal obligations, for example, in relation to child protection legislation.
Volunteers: The School also obtains personal information about volunteers who assist the School in its functions or conduct associated activities to enable the School and the volunteers to work together.
Marketing and fundraising: The School treats marketing and seeking donations 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 students and staff thrive.
Personal information held by the School may be disclosed to an organisation that assists in the School’s fundraising, for example, the School’s Foundation or Old Boys Association.
Parents, staff, contractors and other members of the wider School community may from time to time receive fundraising information. School publications, like newsletters, the School website, School social media sites and magazines, which include personal information, may be used for marketing purposes.
Who might the School disclose personal information to?
The School may disclose personal information, including sensitive information, held about an individual to:
• Another school (within the bounds of the Privacy Principles);
• Government departments;
• Medical practitioners;
• Service providers who support the School;
• Recipients of School publications, like newsletters and magazines;
• Parents; and
• Anyone you authorise the School to disclose information to.
How does the School treat sensitive information?
In referring to ‘sensitive information’, the School means: information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences or criminal record, that is also personal information; 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 you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.
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.
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 using the School website/portal or where this is not possible by way of written notification to the Risk and Compliance Manager.
The Privacy Principles require the School not to store personal information longer than necessary.
You have the right to check what personal information the School holds about you
Under the 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 (including the Employee Records exemption). Students will generally have access to their personal information through their Parents, but older students may seek access themselves.
To make a request to access any information the School holds about you or your child, please contact the Risk and Compliance Manager in writing.
The School may require you to verify your identity and specify what information you require. The School 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 School will advise the likely cost in advance.
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 refer any requests 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 Risk and Compliance Manager. 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 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 maturity of the student and/or the student’s personal circumstances so warranted.
Use of Cloud Services
The School currently stores some elements of personal information through the use of third party cloud services. The School is committed to ensuring the cloud services comply with legislative obligations and address the School’s robust privacy and security requirements.
Transborder Data Flows
Brighton Grammar School may transfer personal information to countries outside Australia (for example when sending correspondence to overseas agencies representing international students). The School will only do so in compliance with all applicable Australian data protection and privacy laws. The School will take reasonable steps to protect personal information no matter what country it is stored in or transferred to. The School has procedures and data transfer contracts as appropriate to help ensure this.
Breach of Privacy Principles
In accordance with the current Privacy Act, all breaches of privacy that are brought to the attention of the School will be reported to the School Council. In accordance with the Notifiable Data Breaches (NDS) Scheme, should the data breach be likely to result in serious harm to any of the individuals to whom the information relates, those individuals and the OAIC will be notified.
Complaints and Enquiries
If you have a complaint about a breach of privacy or would like further information about the way the School manages the personal information it holds, please contact the Property and Compliance Manager.