2.21 Privacy Policy

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Privacy Policy

IntroductionImage of a primary school student

This Privacy Policy applies to Catholic Education Melbourne (CEM) and sets out how CEM manages the personal and sensitive information it collects and holds.

In dealing with personal and sensitive information about individuals, CEM is bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). In relation to health records, CEM is also bound by the Health Records Act 2001 (Vic) and the Health Privacy Principles in that Act.

CEM may, from time to time, review and update this Privacy Policy to take account of new laws and technology and changes to CEM operations and practices and to ensure the policy remains current in a changing environment.

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 CEM's treatment of an employee record unless required by law or organisational policy where the treatment is directly related to a current or former employment relationship between CEM and the employee. CEM handles staff health records in accordance with the Health Privacy Principals in the Health Records Act 2001 (Vic.).

What kinds of personal information does CEM collect and how does CEM collect it?

CEM collects information from individuals that is necessary in order for it to perform one or more of its functions or activities related to its work of advising and supporting Catholic schools in the Archdiocese of Melbourne. CEM collects and holds personal information, including health and other sensitive information, about:

  • Students, 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
  • other people who come into contact with CEM.

In the case of student and parent information, the schools will generally collect this information on behalf of CEM. The type of information that is collected by CEM may include:

  • students and parents
    • name, contact details (including next of kin), date of birth, gender, language background, previous school and religion
    • parents’ education, occupation and language background
    • medical information (eg details of disability and/or allergies and details of any assistance the student receives in relation to those disabilities)
    • conduct and complaint records, or other behaviour notes, school attendance and school reports
    • information about referrals to government welfare agencies
    • counselling and medical reports
    • any court orders
    • photos and videos at school events
  • Job applicants, staff members, volunteers and contractors, including:
    • name, contact details (including next of kin), date of birth and religion
    • information on job application
    • professional development history
    • salary and payment information, including superannuation details
    • medical information, (eg. details of disability and/or allergies and medical certificates)
    • complaints records and investigation reports
    • leave details
    • photos and videos at CEM and/or school events
    • work emails and private emails (when using work email address) and internet browsing history.
  • Other people who come into contact with CEM, including name and contact details and any other information necessary for the particular contact with CEM.
Personal information you provide

CEM will generally collect personal information held about an individual from forms filled out by the individual, face-to-face meetings and interviews, emails and telephone calls. On occasions people other than the individual provide CEM with personal information. CEM may receive information about students, parents and staff of Catholic schools in the Archdiocese of Melbourne from schools.

Personal information provided by other people

In some circumstances CEM may receive personal information about an individual from a third party, for example a report provided by a school or a medical professional or a reference from another employer.

Information collected by CEM’s website

When you look at the CEM website, CEM’s Internet Service Provider makes a record of your visit and logs the following information for statistical purposes:

  • your server address
  • your top-level domain name (for example .com, .gov, .au, .uk, etc.)
  • the date and time of your visit to the site
  • the pages you accessed and the documents you downloaded
  • the previous site you have visited
  • the type of browser you are using.
Access to information collected by CEM’s website

CEM will not attempt to identify users by their browsing activities. However, in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect CEM’s Internet Service Provider's logs.

Use of information collected by CEM’s website

CEM will only record your email address if you send CEM a message. Your email address will only be used for the purpose for which you have provided it and it will not be added to a mailing list or used for any other purpose without your consent.

CEM’s website does not provide facilities for the secure transmission of information across the Internet. Users should be aware that there are inherent risks in transmitting information across the Internet.

Cookies

CEM’s website only uses session cookies and only during a search query of the website. On closing your browser the session cookie set by CEM’s website is destroyed and no personal information is retained which might identify you should you visit CEM’s website at a later date.

How will CEM use the personal information you provide?

CEM 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

CEM uses personal information about students and parents collected by the CEM or provided to CEM to:

  • Identify student need, implement reasonable adjustments to assist with students’ learning and wellbeing
  • satisfy CEM’s responsibilities, accountabilities, legal and professional obligations.
Job applicants and contractors

In relation to personal information of job applicants and contractors, CEM's primary purpose of collection is to assess and (if successful), engage the applicant or contractor.

In addition, CEM uses the personal information of job applicants and contractors for the purpose of:

  • administering the individual's employment or contract
  • insurance purposes
  • satisfying CEM's legal obligations, for example in relation to child protection legislation.
Volunteers

CEM may also obtain personal information about volunteers who assist CEM in its functions or to conduct associated activities to enable CEM to conduct its functions and to confirm their suitability.

Marketing

CEM undertakes marketing activities to promote the future growth and development of Catholic schools in the Archdiocese of Melbourne. CEM may receive personal information held by schools for CEM’s marketing purposes.

Who might CEM disclose personal information to and store your information with?

CEM may disclose personal information, held about an individual to:

  • the Catholic Education Commission of Victoria Ltd, (CECV), Victorian Catholic Education Offices, and specialist visiting teachers
  • third party service providers that provide educational support or pastoral care services to schools and school systems including the Integrated Catholic Online Network system (ICON) and the Enterprise Content Management system
  • another school to facilitate the transfer of a student
  • recipients of CEM and/or school publications, such as newsletters and magazines
  • anyone who we are required or authorised to disclose the information to by law.

CEM may from time to time use the services of third party online service providers, including for the delivery of services and third party online applications, or Apps. These online service providers may be located in or outside Australia.

CEM makes reasonable efforts to be satisfied about the protection and security of any personal information processed and stored in the cloud. CEM will endeavour to ensure they will be located in countries which have substantially similar protections as the APPs.

Sending and storing information overseas

CEM will not send personal information about an individual outside Australia without:

  • your consent (in some cases this consent will be implied)
  • otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.
How does CEM treat sensitive information?

Sensitive information relating to a person's racial or ethnic origin, political opinion, religion, trade union or other professional or trade association membership, philosophical beliefs, sexual orientation or criminal record 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

CEM staff are required to respect the confidentiality of students' and parents' personal information and the privacy of individuals.

CEM has various methods in place to protect the personal information it holds from misuse, interference, loss, unauthorised access, modification or disclosure. These include, but not limited to, locked storage of paper records, access protocols, password protected computer records, high level security measures and encryption.

CEM will also respond to any incidents which may affect the security of the personal information it holds. If the CEM assesses that anyone whose information is affected by such a breach is likely to suffer serious harm as a result, we will notify them and the Office of the Australian Information Commissioner of the breach. Do not share your personal information with anyone without first verifying their identity and organisation. If you believe any of your personal information has been compromised, please let the CEM know immediately.

Access and correction of personal information

Under the Commonwealth Privacy Act and the Health Records Act 2001 (Vic.) an individual has the right to obtain access to any personal information which CEM holds about them and may request correction of the information. There are some exceptions to the access right set out in the applicable legislation. Students will generally be able to access and update their personal information through their parents, but older students may seek access and correction themselves.

The exceptions to these rights set out in the applicable legislation.

To make a request to access or update any personal information CEM holds about you or your child, please refer to the contact details below.

CEM may require you to verify your identity and specify what information you are seeking. CEM 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, CEM will advise the likely cost in advance. If CEM cannot provide you with access to that information, you will be provided with a written notice explaining the reasons for refusal.

Consent and rights of access to the personal information of students

CEM respects every parent's right to make decisions concerning their child's education.

Generally, CEM will refer any requests for consent and notices in relation to the personal information of a student to the student's Parents. CEM 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.

While Parents may seek access to personal information held by CEM about them or their child by contacting the CEM Privacy Officer (see contact details below), 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 CEM’s duty of care to a staff member or student.

CEM may, at its discretion, on the request of a student, grant that student access to information held by CEM about them, or allow a student to give or withhold consent to the use of their personal information, independently of their parents. Normally, this would only be done when the maturity of the student and/or the student's personal circumstances warrant it.

Enquiries and complaints

If you would like further information about the way CEM manages the personal information it holds about you, or wish to complain that you believe that CEM has breached its privacy obligations, please contact the CEM Privacy Officer:

CEM Privacy Officer
Catholic Education Office Melbourne
PO Box 3, EAST MELBOURNE 8002
Phone 9267 0228
Email privacy@cem.edu.au

CEM will investigate any complaint and notify you of a decision in relation to your complaint as soon as practicable after the decision has been made.

** If you are not satisfied with the CEM’s decision you may make a complaint to the Office of the Australian Information Commissioner (OAIC) whose contact details are:
GPO Box 5218, Sydney, NSW 2001
Telephone: 1300 363 992
www.oaic.gov.au

 

Updated 13 June 2018 
Next Review May 2019