Privacy Policy
| Purpose: | King’s Christian College is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act. This statement outlines the privacy policy of the school and describes how the school uses and manages personal information provided to or collected by it. |
| Scope: | The policy applies to board members, employers, employees, volunteers, parents/guardians and students, contractors, and people visiting the school site; and describes the type of information the school collects, how the information is handled, how and to whom the information is disclosed, and how the information may be accessed. |
| References: |
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| Supersedes: | Previous |
| Authorised by: | Campus Principal |
| Date of Authorisation: | December 2022 |
| Review Date: | Annually, as appropriate, to take account of new laws and technology, changes to school’s operations and practices and to make sure it remains appropriate to the changing environment. |
| Next Review Date: | December 2024 |
| Policy Owner: | College Board |
Exception in Relation to Employee Records:
Under the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles do not apply to an employee record held by the employing entity. As a result, this Privacy Policy does not apply to King’s Christian College’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the College and employee.
Policy
This Privacy Policy sets out how King’s Christian College manages personal information provided to or collected by it. King’s Christian College is bound by the Australian Privacy Principles contained in the Privacy Act. King’s Christian College may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to College operations and practices and to make sure it remains appropriate to the changing school environment.
What kinds of personal information does the College collect and how does the College collect it?
The type of information King’s Christian College collects and holds includes (but is not limited to) personal information, including health and other sensitive information, about:
- students and parents and/or guardians ('Parents') before, during and after the course of a student's enrolment at the School: o 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 (e.g. details of disability and/or allergies, absence notes, medical reports and names of doctors);
- conduct and complaint records, or other behaviour notes, and school reports;
- information about referrals to government welfare agencies;
- counselling reports;
- health fund details and Medicare number;
- any court orders;
- volunteering information; and
- photos and videos at school events.
- job applicants, staff members, volunteers and contractors:
- 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 (e.g. details of disability and/or allergies, and medical certificates);
- complaint records and investigation reports;
- leave details;
- photos and videos at school events;
- workplace surveillance information;
- work emails and private emails (when using work email address) and Internet browsing history
- other people who come into contact with the School including name and contact details and any other information necessary for the particular contact with the school.
Personal Information you provide:
King’s Christian College 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, emails and telephone calls. On occasions, people other than parents and students provide personal information.
Personal Information provided by other people:
In some circumstances, King’s Christian 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.
How will the School use the personal information you provide?
King’s Christian College 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 by you, or to which you have consented.
Students and Parents
In relation to personal information of students and parents, the College’s primary purpose of collection is to enable the College to provide schooling to students enrolled at the school, exercise its duty of care, and perform necessary associated administrative activities, which will enable students to take part in all the activities of the school. This includes satisfying the needs of parents, the needs of the students and the needs of King’s Christian College throughout the whole period the student is enrolled at the School.
The purposes for which King’s Christian 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 of the College
- looking after student's educational, social and medical wellbeing
- seeking donations and marketing for the College
- to satisfy the College’s legal obligations and allow the school to discharge its duty of care.
In some cases where King’s Christian College requests personal information about a student or parent, if the information requested is not provided, the College may not be able to enrol or continue the enrolment of the student or permit the student to take part in a particular activity.
On occasions, information such as academic and sporting achievements, student activities and similar news is published in School newsletters and magazines, on our Compass portal, and on our website. This may include photographs and videos of student activities such as sporting events, school camps and school excursions.
During events such as sports carnivals, concerts, fetes and festivals, photographs and videos may be taken of students and adults attending the event. These images may be used as a record of the event activities and for publication in school newsletters, magazines and on the College website.
At enrolment, parents are asked to sign consent for their child(ren)’s images to be used in school publications for marketing purposes. If consent is not given, parents will be asked to nominate the specific uses for which their child’s image should not be used.
Documents are retained for the period/s of time stipulated in the Queensland Education and Training Sector retention requirements.
Job applicants, Staff Members and Contractors
In relation to personal information of job applicants, staff members and contractors, the College’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 King’s Christian College uses personal information of job applicants, staff members and contractors include:
- in administering the individual's employment or contract, as the case may be
- for insurance purposes
- seeking donations and marketing for the School
- to 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 College in its functions or conduct associated activities, such as alumni associations, to enable the College and the volunteers to work together.
Marketing and Fundraising
King’s Christian College treats marketing and seeking donations for the future growth and development of the school as an important part of ensuring that the College continues to provide a quality learning environment in which both students and staff thrive. Personal information held by the College may be used for the purposes of encouraging future enrolments. For example, from time to time, the College may send information about events such as Open Days or Tours, or general information about enrolling into the College to people who have previously expressed interest.
An option to opt-out of receiving this material will be routinely available within the specific marketing material.
Who might the School disclose Personal Information to and store your information with?
King’s Christian College may disclose personal information, including sensitive information, held about an individual for educational, legal, administrative, marketing and support purposes. This may include to:
- another school or staff at another school
- government departments (including for policy and funding purposes)
- medical practitioners
- people providing educational, support and health services to the School, including specialist visiting teachers, sports coaches, volunteers, counsellors and providers of learning and assessment tools
- assessment and educational authorities, including the Australian Curriculum, Assessment and Reporting Authority (ACARA) and NAPLAN Test Administration Authorities (who will disclose it to the entity that manages the online platform for NAPLAN)
- people providing administrative and financial services to the College;
- recipients of School publications, such as newsletters and magazines
- students' parents or guardians
- anyone you authorise the College to disclose information to
- anyone to whom we are required or authorised to disclose the information to by law, including child protection laws.
Sending and Storing Information Overseas
King’s Christian College may disclose personal information about an individual to overseas recipients, for instance, to facilitate a school exchange, or tour. However, the College 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)
- otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.
King’s Christian College may use online or 'cloud' service providers to store personal information and to provide services to the College that involve the use of personal information, such as services relating to email, instant messaging and education and assessment applications. Some limited personal information may also be provided to these service providers to enable them to authenticate users that access their services. This personal information may be stored in the 'cloud' which means that it may reside on a cloud service provider’s server which may be situated outside Australia.
An example of such a cloud service provider is Google. The College uses the Google service 'Google Apps for Education' (GAFE) including Gmail, and stores and processes limited personal information for this purpose. School personnel and the AIS and its service providers may have the ability to access, monitor, use or disclose emails, communications (e.g. instant messaging), documents and associated administrative data for the purposes of administering GAFE and ensuring its proper use.
The data centres where the personal information is likely to be kept are located in the USA, Taiwan, Singapore, Ireland, Netherlands and Belgium.
Sensitive Information
In referring to 'sensitive information', King’s Christian College means: information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, philosophical beliefs, sexual orientation or practices or criminal record, that is also personal information; health information and biometric 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 required by law.
Management and Security of Personal Information
College staff are required to respect the confidentiality of students' and parents' personal information and the privacy of individuals. King’s Christian College has in place steps to protect the personal information the College holds from misuse, interference and loss, unauthorised access, modification or disclosure by use of various methods including locked storage of paper records and password access rights to computerised records.
Data Breaches
It will be deemed that an ‘eligible data breach’ has occurred if:
- there has been unauthorised access to, or unauthorised disclosure of, personal information about one or more individuals (the affected individuals)
- a reasonable person would conclude there is a likelihood of serious harm to any affected individuals as a result
- the information is lost in circumstances where:
- unauthorised access to, or unauthorised disclosure of, the information is likely to occur
- assuming unauthorised access to, or unauthorised disclosure of, the information was to occur, a reasonable person would conclude that it would be likely to result in serious harm to the affected individuals.
Serious harm may include serious physical, psychological, emotional, economic and financial harm, as well as serious harm to reputation.
What must the school do in the event of an ‘eligible data breach’?
If King’s Christian College suspects that an eligible data breach has occurred, it will carry out a reasonable and expedient assessment/investigation within 30 days.
o there is no unauthorised access to, or unauthorised disclosure of, the information
o there is no serious harm to affected individuals, and as a result of the remedial action, a reasonable person would conclude the breach is not likely to result in serious harm.
If such an assessment/investigation indicates there are reasonable grounds to believe an eligible data breach has occurred, then the College will be required to lodge a statement to the Privacy Commissioner. Where practical to do so, the school entity will also notify the affected individuals. If it is not practicable to notify the affected individuals, the College will publish a copy of the statement on its website, or publicise it in another manner.
Exception to notification obligation
An exception to the requirement to notify will exist if there is a data breach and immediate remedial action is taken, and as a result of that action:
- there is no unauthorised access to, or unauthorised disclosure of, the information
- there is no serious harm to affected individuals, and as a result of the remedial action, a reasonable person would conclude the breach is not likely to result in serious harm.
Access and Correction of Personal Information
Under the Privacy Act, an individual has the right to seek and obtain access to any personal information which the College holds about them and to advise the College of any perceived inaccuracy. There are some exceptions to this right set out in the Act. Students will generally be able to access and update their personal information through their parents, but older students may seek access and correction themselves.
To make a request to access or to update any personal information King’s Christian College holds about you or your child, please contact the College in writing. The College may require you to verify your identity and specify what information you require. The College 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 College will advise the likely cost in advance. If we cannot provide you with access to that information, we will provide you with written notice explaining the reasons for refusal.
The School will take reasonable steps to ensure that any personal information is accurate, up to date, complete, relevant and not misleading. Routine personal information such as contact details and relevant student medical details are available for parents to review and update in the Parent Lounge web portal.
Consent and Rights of Access to the Personal Information of Students
King’s Christian 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. King’s Christian 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.
As mentioned above, parents may seek access to personal information held by the College about them or their child by contacting the Principal. 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 the College‘s duty of care to a 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 warrant it.
Enquiries and Complaints
If you would like further information about the way King’s Christian College manages the personal information it holds, or wish to make a complaint about College's breach of the Australian Privacy Principles please contact the Principal. The College will investigate any complaint and will notify you of the making of a decision in relation to your complaint as soon as is practicable after it has been made.