Privacy Policy

1 – INTRODUCTION

Privacy Policy sets out how Helena River Waldorf School (HRWS) manages personal information provided to or collected by it. The School is bound by the Australian Privacy Principles (APP) contained in the Commonwealth Privacy Act. All members of the staff of the School and individuals who serve on the Board, committees and other groups conducting the business of the School are formally required to respect the confidentiality of personal information and the privacy of individuals and to comply with the School’s Privacy Policy. The School may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the School’s operations and practices and to make sure it remains appropriate to the changing school environment.

2 – POLICY AND PROCEDURE2.1 PERSONAL INFORMATION COLLECTED

The type of information the School 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 pupil’s enrolment at the School.
  • Job applicants, staff members, relief staff, volunteers, and contractors.
  • Other people who come into contact with the School.

2.1.1 Personal Information Provided by Students and Parents

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, emails and telephone calls. On occasions people other than Parents and students provide personal information.

2.1.2 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.

2.1.3 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 the School’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the School and employee.

2.1.4 How the School will use the Personal Information Provided

The School will use personal information it collects from a person 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 the person has consented.

2.1.5 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 the needs of Parents, the needs of the student and the needs of the School 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 and magazines.
  • Day-to-day administration of the School.
  • Looking after students’ educational, social and medical wellbeing.
  • Seeking donations and marketing for the School.
  • To satisfy the School’s legal obligations and registration requirements 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 provided, the School may not be able to enrol or continue the enrolment of the student or permit the student to take part in a particular activity.

2.1.6 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. The purposes for which the School uses personal information of job applicant, 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.

2.1.7 Relief Staff and Volunteers

The School also obtains personal information about relief staff and volunteers who assist the School in its functions or conduct associated activities, such as alumni associations, to enable the School and the volunteers to work together.

2.1.8 Marketing and Fundraising

The School treats marketing and the seeking of donations for the future growth and development of the School, as an important part of ensuring that the School continues to provide a quality learning environment, in which both pupils and staff thrive. Personal information held by the School may be disclosed to organisations that assist in the School’s fundraising, for example, the School’s Foundation or alumni organisation or, on occasions, external fundraising organisations. Parents, staff, contractors, and other members of the wider School community may from time to time receive fundraising information. School publications, like newsletters and magazines, which include personal information, may be used for marketing purposes.

2.1.9 Who Might the School Disclose Personal Information to?

The School may disclose personal information, including sensitive information, held about an individual to:

  • Another school.
  • Government departments.
  • Medical practitioners.
  • People providing services to the School, including specialist visiting teachers, counsellors and sports coaches.
  • Recipients of School publications, such as newsletters and magazines.
  • Parents.
  • Anyone the individual authorises the School to disclose information to.
  • Anyone to whom the School is required to disclose the information to by law.

2.1.10 Sending Information Overseas

The School may disclose personal information about an individual to overseas recipients, for instance, when storing personal information with ‘cloud’ service providers which are situated outside Australia or to facilitate a school exchange. However, the School 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.

2.1.11 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, 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 the individual agrees otherwise, or the use or disclosure of the sensitive information is allowed by law.

2.1.12 Management and Security of Personal Information

The School 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, 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.

2.1.13 Access and Correction of Personal Information

Under the Commonwealth 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. Students will generally be able to access and update their personal information through their Parents, but older students may seek access and correction themselves. There are some exceptions to these rights set out in the applicable legislation.

To make a request to access or update any personal information the School holds about individual or the individual’s child, the Principal will need to be contacted in writing. The School may require the individual to verify their identity and specify what information is required. The School may charge a fee to cover the cost of verifying the 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. If the School cannot provide access to that information, then a written notice explaining the reasons for refusal will be provided.

2.1.14 Consent and Rights of Access to the Personal Information of a Student

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 students’ 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 Principal. However, there may 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.

3 STANDARD COLLECTION NOTICE

The ‘Standard Collection Notice’, which is drafted to cover the School’s usual collection practices, deals with the matters listed in Australian Privacy Policies in the Privacy Act (Section 5.1) concerning how any personal and sensitive information collected from the individual about him/herself or a third party would be dealt with. The ‘Standard Collection Notice’ will be reproduced in enrolment forms, be contained in the School’s Privacy Policy, and will be located on the School’s website. The School may place a ‘Standard Collection Notice’ in other relevant documents. The ‘Standard Collection Notice’ will be distributed with all enrolment forms to students’ parents. The current notice will be sent at the commencement of each school year to parents of students at the same time as other materials are sent. (Refer Appendix I for a copy of the Standard Collection Notice) .

4 – ENQUIRIES AND COMPLAINTS

Further information about the way the School manages the personal information it holds or any complaints that the School may have breached the Australian Privacy Principles can be directed to the Principal. The School will investigate any complaint and will notify the individual of the decision in relation to the complaint as soon as is practicable and in line with the School’s Concerns and Grievance Policy.

5 –  REFERENCESRelated Documents / Links With Related Legislation

  • AISWA – Privacy Policy Guidelines
  • National Catholic Education Commission and Independent Schools Council of Australia Privacy Compliance Manual
  • Records Management Policy
  • Child Protection Policy
  • Enrolment Policy
  • Safeguard for Students Policy
  • Concerns and Grievance Policy
  • The Privacy Act 1988
  • Australian Privacy Principle & Privacy Amendment (Enhancing Privacy Protection) Act 2012

Appendices

  • Appendix I: Standard Collection Notice

6 –  APPENDICESAPPENDIX I. STANDARD COLLECTION NOTICE

1. The School collects personal information, including sensitive information about students and parents or guardians before and during the course of a student’s enrolment at the School. This may be in writing or in the course of conversations. The primary purpose of collecting this information is to enable the School to provide schooling to the student and to enable them to take part in all the activities of the School.

2. Some of the information the School collects is to satisfy the School’s legal obligations, particularly to enable the School to discharge its duty of care.

3. Laws governing or relating to the operation of a school require certain information to be collected and disclosed. These include relevant Education Acts, Public Health, and Child Protection laws.

4. Health information about students is sensitive information within the terms of the Australian Privacy Principles under the Privacy Act. The School may ask that medical reports about students be provided from time to time.

5. The School from time to time discloses personal and sensitive information to others for administrative and educational purposes, including facilitating the transfer of a student to another school. This includes to other Schools, government departments, medical practitioners and people providing services to the School.

6. Personal information collected from students is regularly disclosed to their parents or guardians.

7. The School’s Privacy Policy sets out how parents or students may seek access to personal information collected about them. However, there will be occasions when access is denied. Such occasions would include where access would have an unreasonable impact on the privacy of others, where access may result in a breach of the School’s duty of care to the student, or where students have provided information in confidence.

8. The School Privacy Policy also sets out how complaints are made concerning a breach of privacy and how the School will deal with such a complaint.

9. The School from time to time engages in fundraising activities. Information received from individuals may be used to make an appeal. It may also be disclosed to organisations that assist in the School’s fundraising activities solely for that purpose. The School will not disclose personal information to third parties for their own marketing purposes without consent of the individual.

10. On occasions, information such as academic and sporting achievements, student activities and similar news is published in School newsletters and magazines and on the School website. Photographs of student activities may be taken for publication in School newsletters and magazines and on the School website. The School will obtain separate permissions from the students’ parent or guardian prior to publication.

11. The School may include students’ and students’ parents’ contact details in a class list and School directory.

12. If personal information of others is provided to the School, such as doctors or emergency contacts, it is encouraged that the affected parties be informed about the disclosure of information to the School and the reasons why. They should also be advised that the School does not usually disclose this information to third parties.