Prace Privacy Statement
We are committed to protecting your privacy. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. Personal information we acquire or collect:
- Will be relevant and necessary,
- Will not be elicited by unfair or unlawful means,
- Will be factual rather than interpretative in nature,
- Will be collated in a single file where practicable,
- Will be maintained in a secure place at all times.
What personal information do we collect?
The personal information we collect about you may include:
- Residential and postal address
- Date of birth
- Email address
- Phone number
Depending on your relationship with Prace, and the program or service we are providing, we may also collect information such as your:
- Education history
- Work history
Under certain circumstances, we may need to collect sensitive information about you. This might include information about your racial or ethnic origin, criminal record, health information, or disability.
Any detailed information collected about disability, health, or medical conditions will only be collected where it may affect your participation in a program or service, or your safety and wellbeing as a student or an employee of Prace.
If we collect your sensitive information, we will do so only with your consent, or as otherwise required or authorised by law. We take appropriate measures to protect the security of this information.
We may collect and use a government related identifier – or document containing such an identifier – to verify your identity in relation to our business activities and in order to provide a service or to employ you.
This includes, but is not limited to:
- Victorian Student Number (VSN) for students up to the age of 24 years
- Unique Student Identifier (USI)
- Pension or Concession Card containing your Customer Reference Number (CRN) / Job Seeker Identification (JSI)
- Passport / Visa / Travel Document
- VASS Number (Prace College enrolments)
- Medicare Card
- Driver’s Licence or Learner Permit
- Proof of Age card
- Tax file number (employees only)
You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may be unable to:
- Provide the requested programs, products, services, or volunteer opportunity to you, either to the same standard or at all.
- Provide you with the information about the programs and services that you may want.
- Employ you.
- Tailor the content of our website to your preference, and your experience of our website may not be as enjoyable or useful.
We may also collect some information that is not personal information because it does not identify an individual. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
How do we collect your personal information?
We collect your personal information directly from you when you:
- Interact with us over the phone
- Interact with us in person
- Interact with us online
- Participate in surveys or questionnaires
- Attend a Prace event
- Subscribe to our mailing list
- Apply for a position with us as an employee, contractor or volunteer
- Enrol in a Prace program or service
- Purchase a product from PageTurners
- Hire a Prace venue.
Wherever possible, personal information will be collected directly from you.
If you are under the age of 18, we will ask for your parent or guardian to provide consent when you are providing personal information as part of an enrolment or application or employee related form.
Video surveillance / closed circuit television (CCTV)
The common areas and grounds of training venues operated by Prace may be under constant video and audio surveillance to protect Prace property and ensure the safety and wellbeing of staff, visitors, and students. Unless permitted by the Privacy Act or otherwise required by law, Prace will not, without prior written consent of any person concerned, use the information recorded via CCTV for any other purpose. For further information on how Prace may use the CCTV system, who may access the footage, and how you may request a record of any footage, refer to our CCTV Policy and Procedure.
CCTV cameras are located in/at:
- Building entrances
- Car park areas
- Indoor and outdoor communal areas
Collecting personal information from third parties
We may also collect your personal information from third parties, including community service organisations, law enforcement agencies or government entities. We collect your personal information from these third parties so that we can:
- Assess your suitability to work at Prace
- Determine your eligibility to study, and/or for a government-subsidised place in an educational program
- Provide personalised support to you, where required.
Information may be collected from a third party only if:
- You have consented to such collection, or
- You would reasonably expect us to collect your personal information in this way, or
- It is necessary for a specific purpose such as the investigation of a privacy complaint, or
- Required or permitted by law.
For example, sharing information appropriately and lawfully for the purpose of supporting a student’s safety and wellbeing, and to reduce risk, is an important part of a school’s duty of care. Prace College is authorised under the Child Information Sharing Scheme and Family Violence Information Sharing Scheme to share information, including personal and sensitive information, with other permitted entities to support the wellbeing of a child, or to manage family violence risk. This may include collecting and sharing information:
- To support students’ social and emotional wellbeing, and health
- When necessary to lessen or prevent a serious threat to a person’s life, health, safety or welfare
- With parent, carer or mature minor student consent
- When required or authorised by law.
How do we use your personal information?
We may use your personal information for a range of purposes in connection with our functions and activities, including the following:
- To answer enquiries and provide information or advice about existing and new programs and services
- To send requested communications
- To provide programs, services or products that you request from us
- To deliver to you a more personalised and supportive experience and service offering
- To conduct business processing functions, including providing personal information to related bodies or other third parties
- For internal administrative purposes
- For marketing and research purposes
- For planning, evaluation, program or service development, quality management and research purposes, to improve the quality of the services we offer
- To update our records and keep contact details up to date
- To process and respond to any complaint made
- To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country)
- To provide a secure environment for all staff, service users and visitors to our facilities through video surveillance.
Personal information will only be used and disclosed for the primary purpose for which it was collected, or for a related secondary purpose that you would reasonably expect, or in other limited circumstances permitted by law.
Personal information will not be sold or rented; and will not be shared or disclosed other than as described in this Privacy Statement.
When enrolling in a Prace program or service we will ask for your consent for us to use any photographs, video or audio recording of you, or feedback from you that we may collect while you are participating with us. You may opt out of these being used by us for promoting or marketing Prace programs and services.
For more information about how Prace collects and uses photographs, video or audio recordings, refer to our Photographing, Filming and Recording Students Policy.
Disclosure of personal information to third parties
We may disclose your personal information to third parties in circumstances where you would reasonably expect us to disclose your information.
We will not disclose your personal information other than:
- For the purpose for which it was collected, or
- For a related secondary purpose you would reasonably expect, or
- If required by law.
Student, customer, and service user personal information
We may disclose personal information to government agencies in accordance with contractual obligations. In these circumstances, we will take reasonable steps to inform you, seek your consent, and take all reasonable steps to ensure that the information is handled in accordance with the Australian Privacy Principles, the Victorian Information Privacy Principles, and where applicable, the Victorian Health Privacy Principles. We may also disclose your personal information to:
- Our employees, contractors or service providers for the purposes of the operation of our business, fulfilling your requests, and to otherwise provide programs and services to you, including, without limitation, web hosting providers, IT system administrators, couriers, payment processors, data entry services providers, electronic network administrators, data collectors, and professional advisors such as accountants, solicitors, business advisors and consultants
- Suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes
- Prescribed Information Sharing Entities, under the Child Information Sharing Scheme and Family Violence Information Sharing Scheme (for information relating to Prace College students only).
- Any organisation for any authorised purpose with the individual’s express consent
Transfer of personal information outside of Victoria
Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Victoria, including in Europe and the US. For example, companies that provide internet-based software and data hosting services.
Where we disclose your personal information to third parties outside of Australia, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:
- You have given us your consent to disclose personal information to that third party; or
- We reasonably believe that:
- The overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the Australian Privacy Principles; and
- The law or binding scheme can be enforced; or
- The disclosure is required or authorised by an Australian law or court / tribunal order.
How do we protect your personal information?
We will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:
- Having a robust physical security of our premises and databases / records
- Taking measures to restrict access to only personnel who need that personal information to effectively provide services to you
- Having technological measures in place (for example, anti-virus software, fire walls).
As the Internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online, whether via the Prace website or via email, as we cannot guarantee that the information you supply will not be intercepted while being transmitted over the Internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website uses Google Analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.
We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe” set out in the relevant communication or by contacting us using the details set out in the “How to contact us” section below.
If you create an account on the PageTurners website, we will securely store and use your personal information to manage access to your account and process any future orders.
Retention of personal information
We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws or funding arrangements, for example record-keeping obligations associated with employment or participation in an accredited or government-funded program.
Personal information will be destroyed or permanently de‐identified when it is no longer needed for the purpose for which it was collected.
How to access and correct your personal information
Prace will endeavour to keep your personal information accurate, complete and up to date.
You have the right to access and / or correct the personal information we hold about you, unless there is a sound reason under the Privacy Act, or other relevant law, to withhold the information. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give written reasons for any refusal.
If you wish to make a request to access and / or correct the personal information we hold about you, you should contact the Prace Privacy Officer via the contact details below. We will usually respond within 10 business days.
Links to third party sites
Prace websites may contain links to websites operated by external organisations or government agencies. If you access a third-party website through one of our websites, personal information may be collected by that third-party website. We make no representations or warranties in relation to the privacy practices of any such external website, and are not responsible for the privacy policies or the content of those websites. The owners of external websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.
Enquiries and complaints
For complaints about how we handle, process or manage your personal information, please contact the Prace Privacy Officer. Note we may require proof of your identity and full details of your request before we can process your complaint.
Please allow up to 10 business days for us to respond to your complaint, in accordance with our Complaints and Appeals Policy and Procedure. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with our response to a complaint, you have the right to contact the Office of Australian Information Commissioner (at www.oaic.gov.au/) to lodge a complaint.
How to contact us
If you have a question or concern in relation to our handling of your personal information or this Privacy Statement, you can contact us for assistance as follows:
Email: firstname.lastname@example.org Contact number: (03) 9462 6077
Post: Attention: Prace Privacy Officer, PO Box 510, Reservoir, 3073