This Policy addresses the kinds of personal information that we collect, how we collect and hold personal information, how we store personal information, why we collect, hold, use and disclose personal information, and how you can access and seek correction of your personal information.
The Policy also details how you can contact us if you have any questions about this Policy or if you would like to lodge a complaint with us regarding our compliance with the Privacy Act, or this Policy.
Kinds of personal information we collect
‘Personal Information’ refers to information or an opinion (whether true or not) about an individual in which an individual’s identity can be ascertained.
THE STUDIO 64 GROUP will only collect personal information for a lawful purpose that is directly related or reasonably necessary for the purposes of our business. The personal information we collect will depend on the nature of your interaction with us and the circumstances of the collection. For example, our Early Learning Centre collects and holds personal information about you or your child (that is, information relating to an individual or which can be used to identify an individual), that is reasonably necessary for or related to our activities and the services we provide. The purposes for which your personal information is collected will usually be obvious at the time it is collected. For example our Early Centre collects personal information of parents and guardians, children, employees and stakeholders for the primary purposes of providing early childhood education and care services and advocating for the well-being, protection and development of children. The personal information we collect will depend on the nature of your interaction with us and the circumstances of the collection.
The kinds of personal information we collect and hold, may include any of the following:
- Your name, address (residential or business), and contact details (e.g. phone and email)
- Information about your personal circumstances (e.g. marital status, age, gender, custody arrangements)
- Information about your identity (e.g. date of birth, passport details, visa details, driver’s licence)
- Information about your financial affairs (e.g. payment details, credit card details,bank account details and superannuation)
- Information about your workers compensation claims, results of drug and alcohol testing, and in some cases, health (limited)
- Information about your employment (e.g. work history, reference checks, remuneration, occupation and employer)
- Information about your background (e.g. qualifications, career history, professional memberships and affiliations)
- Records of communications and interactions with us
- Records relating to your engagement, conduct, hours worked, and payment as a contractor
- Credit card and debit card information
- Your ABN, Tax File Number and Centrelink Customer Reference Number or government related identifiers
- Information about the way you use our website
- Your Internet Protocol (IP) address
In carrying out our functions and activities we may collect personal information that is sensitive information. ‘Sensitive Information’ is a special category of Personal Information and includes information about your health, race ethnic origin, religious beliefs or criminal record.
In our Early Learning Centre this may include information such as your child’s racial or ethnic origin or any cultural or religious requirements. We are also required by the Education And Care National Regulations to collect and hold details of your child’s medical conditions, immunisation history and additional needs.
We collect this information as it is reasonably necessary for ensuring the well-being, protection and development of children in our care. For example staff may wish to develop an educational program that includes reference to a child’s country of origin.
The Studio 64 Group will only collect your sensitive information with your consent and will ensure that it is stored securely. If you do not wish for your sensitive information to be collected by The Studio 64 Group, you should discuss this with a The Studio 64 Group employee.
The Studio 64 Group employees will act strictly in accordance with this policy and will be happy to discuss the reasons for seeking to collect your sensitive information. They will also discuss with you any consequences of not providing your sensitive information which may include an effect on the services your The Studio 64 Group Early Learning centre can provide to you.
THE STUDIO 64 GROUP will only collect sensitive information with your consent and will not disclose your sensitive information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act or to comply with any Australian law or court/tribunal order. THE STUDIO 64 GROUP may also collect sensitive information where authorised to do so for the purposes of human resource management and taking appropriate action against suspected unlawful activity or serious misconduct.
From time to time we receive personal information that is not requested by us or reasonably necessary for our business purposes. Where unsolicited information is received from us we will, as soon as is practicable, destroy or permanently de-identify this information, unless it is unlawful for us to do so.
How we collect and hold personal information
THE STUDIO 64 GROUP will collect personal information directly from you where it is lawful and reasonable and practicable to do so. This is primarily done through forms, other electronic or paper correspondence where you have corresponded with or registered your details with us, entered into an arrangement with us or provided feedback to us, or over the phone. Personal information may also be collected from third parties, such as recruitment agencies and Australian Government agencies.
We may collect your personal information if you:
- Submit information through our website
- Visit our website (use of ‘cookies’)
- Interact with us on our social media platforms
- Communicate with us orally, by telephone, in writing (mail and email), SMS and in person
- Attend a face to face meeting or event conducted by us, our Contractors or Clients
- Submit an application, quote, purchase order and/or service request to us
- In the course of supplying products and services to you, or through our other dealings with you. (For example, Photos and videos of children and children’s work samples are collected at our Early Learning Centre. Name, address and phone numbers of children’s additional emergency contact people are collected from children’s parents or guardians.)
Where we outsource our functions to third party service providers (including Sub-contractors), those providers may also collect personal information from you on our behalf.
You do not have to give us your personal information. You can advise us if you wish to remain anonymous or use a pseudonym when dealing with us. However, if you do not provide us with your personal information or identify yourself, it may impact on our ability to provide you with our services, process or assess your application, resolve a dispute, finalise payments, or otherwise do business with you or an entity you are connected with. If you do not wish for your personal information to be collected you should discuss this with an employee or our Centre Manager. Our employees will act strictly in accordance with this policy and will be happy to discuss the reasons for seeking to collect your personal information. They will also discuss with you any consequences of not providing your personal information, or providing incomplete or inaccurate personal information, which may include an effect on what services we can provide to you.
There may be on occasion be instances where personal information about you will be collected indirectly because it is unreasonable or impractical to collect the personal information from you directly. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
How we store personal information
We hold your personal information in paper-based form, electronic records, including cloud computing, at our own secure premises.
We are committed to keeping your personal information safe, confidential and secure. All reasonable steps are taken to ensure that the personal information that we hold is protected from loss, interference, misuse, unauthorised access, modification, disclosure, and corruption by computer viruses.
We use physical, electronic and procedural safeguards to do this. We also train our employees on privacy matters as appropriate, and seek to limit access to personal information to those staff members, and third parties who need to know that information.
When we no longer require your personal information, we will take reasonable steps to archive, destroy or permanently de-identify that information. Document retention and destruction comply with relevant legislation requirements.
Why we collect, hold, use and disclose personal information
We use and disclose your personal information for the purposes disclosed to you at the time it is collected, or to which you have consented, or as otherwise set out in this Policy.
We collect, use and disclose personal information that is reasonably necessary for our business purposes or a reasonably expected or related secondary purpose, and as required by law.
Those business purposes may include:
- Supplying our customers with products and services
- Managing the supply of our products and services (including processing invoices, receipts and payments)
- Responding to enquiries
- Assessing job applications or expressions of interests from potential Sub-contractors and managing those relationships
- Performing our employment and personnel functions in relation to our employees and Sub-contractors
- Performing legislative and administrative functions
- Handling of complaints
- Ensuring safety of all stakeholders including the children in our care, and those working in our premises.
- Management of correspondence with the public
- Contract management
In our Early Learning Centre, for example, we may disclose personal information about you or your child to:
- third party service providers, who assist us in operating our business (including credit reporting bodies, collection agencies, legal advisors and technology service providers). We will take reasonable steps to ensure these service providers do not breach the Australian Privacy Principles.
- a purchaser of the assets and operations of our business or a part of it, provided those assets and operations are purchased as a going concern
- child protection agencies or family support agencies when we reasonably believe that a child is at risk of significant harm, as required by our Child Protection Procedures.
The Studio 64 Group will not otherwise disclose personal information to a third party for any other purpose without your consent unless it is authorised or required by law.
How I can access my personal information and seek correction of it?
THE STUDIO 64 GROUP will take all reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete, kept up to date, not misleading and is relevant.
Under the Privacy Act you have the right to access the personal information we hold about you and request that it be updated or corrected. To ensure confidentiality, we will only pass details onto you where we are satisfied that that the information relates to you. Please contact our Privacy Officer using the contact details set out below.
We will usually respond to reasonable requests for personal information and correction of personal information within 30 days of receiving the request in writing. Where possible we will give you access to your requested personal information in the way that you have requested it. If we refuse your request, we will give you notice in writing, setting out the reasons for our refusal and the process for you to complain about the refusal.
Factors that may affect your right to access include:
- We reasonably believe that access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety
- Access would have an unreasonable impact on the privacy of other individuals
- The request for access is frivolous or vexatious
- The information relates to existing or anticipated legal proceedings between you and us, and would not be accessible by the process of discovery in those proceedings
- Access would prejudice negotiations with you
- Access would be unlawful
- Denying access is required or authorised under Australian law or a court/tribunal order
- Access would prejudice appropriate action being taken in relation to serious misconduct, unlawful activity or enforcement related activities
- The information relates to commercially sensitive decision-making process
Who can I contact if I have a complaint or question?
All complaints should be made in writing to:Mail:The Privacy Officer
THE STUDIO 64 GROUP
64 Mill Point Rd, South Perth, 6151Email: firstname.lastname@example.org
THE STUDIO 64 GROUP will review and investigate complaints as soon as possible, usually within 30 days of receiving the complaint. If you are not satisfied with the way your complaint has been handled by us, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details can be found below. Please note that the Information Commissioner may not investigate your complaint if you have not written to us in the first instance and given us a reasonable time frame to resolve your complaint.
Office of the Australian Information Commissioner (OAIC)Telephone: 1300 363 992Email: email@example.comMail:GPO Box 5218, Sydney NSW 2001
GPO Box 2999, Canberra ACT 2601