Privacy Policy
Introduction
St Kevin's College is committed to using and managing personal information provided to or collected by it in an ethical manner and in accordance with the National Privacy Principles contained in the Commonwealth Privacy Act and the Privacy Policy of the Catholic Education Commission of Victoria.
The College will regularly review and update this policy to take account of new laws and technology, changes to any operations and practices and to make sure it remains appropriate to the changing school environment.
Definition
The type of information that is collected and held 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
- job applicants, staff members, volunteers and contractors
- other people who come into contact with the College
Personal information will generally be collected and held about an individual by way of forms completed by parents or students, face-to-face meetings and interviews, and telephone calls. On occasions people other than parents and students provide personal information.
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.
Under the Privacy Act the National 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 employee.
Guidelines
The College will use personal information it collects for the primary purpose of that collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which the College has gained consent.
Students and Parents: In relation to personal information of students and parents, the primary purpose of collection is to enable the College 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. 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 and medical wellbeing
- seeking donations and marketing for the College
- to satisfy 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 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 primary purpose of collection is to assess and (if successful) to engage the applicant, staff member or contractor. 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
- for insurance purposes
- seeking funds and marketing for the College
- to satisfy the College legal obligations
Volunteers: The College also obtains personal information about volunteers who assist the College in its functions or conduct associated activities to enable the College and the volunteers to work together.
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 be a quality learning environment in which both students and staff thrive. Personal information held by the College may be disclosed to an organisation that assists in the College fundraising, for example, the College Development Office. Parents, staff, contractors and other members of the wider College 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.
Disclosing personal information: The College cannot disclose an individual’s personal information for a purpose other than the purpose for which it was collected, without the individual’s consent. ‘Personal information’ is information or an opinion about an individual that is capable of identifying the individual. Given this, information about a student’s personality and observations about the difficulties a student may have experienced at school may identify the student and therefore may constitute ‘personal information’.
The College, having received prior consent, may disclose personal information including sensitive information held about an individual to the following:
- another school
- government departments
- medical practitioners
- people providing services to the College, including specialist visiting teachers and sports coaches
- recipients of College publications, like newsletters and magazines
- parents
- anyone authorising the College to disclose information to
However, the College does not have to comply with the NPP (National Privacy Principles) where it is disclosing the personal information of a student or their family when:
- the student or family would reasonably expect such disclosure of their personal information
- the College is disclosing the personal information because of health, safety or legal reasons (such reasons having to pass a high threshold test).
Sending information overseas: The College will not send personal information about an individual outside Australia without:
- the consent of the individual (in some cases this consent will be implied)
- complying with the National Privacy Principles
How the College treats 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, 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: All staff at the College 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 the College 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.
Data Security Breach: In the event any member of staff either academic or administrative is aware of or becomes aware that a security breach may have or has occurred, and that personal information including sensitive information is or may have been misused, lost, accessed without authority modified or improperly disclosed, then, that member of staff shall notify the Deputy Headmaster of the breach or suspected breach as a matter of urgency to allow for the commencement of an investigation.
Updating personal information: The College 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 College by contacting the Administration of the College at any time. The National Privacy Principles require the College not to store personal information longer than necessary.
Seeking access to the personal information the College holds: Under the Commonwealth Privacy Act, an individual may seek access to personal information, which the College holds about them. There are some exceptions to this set out in the Act. Students will generally have access to their personal information through their parents, but older students may seek access themselves. Any request for access to information the College holds needs to be directed to the Headmaster in writing. The College may require identity verification and specification of information required. The College may charge a fee for access and will advise the likely cost in advance.
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.
Parents may seek access to personal information held by the College about them or their child by contacting the Headmaster. 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 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.
Queries may be directed to the St. Kevin’s College Privacy Officer
in writing to
St. Kevin’s College, Moonga Road, Toorak. 3142
T 03 9822 0911 or E omnia@stkevins.vic.edu.au
Review
This policy will be reviewed annually or as the Board determines.
Approved and Adopted 2009
