ÎÞÂëÊÓƵ

last updated: December 2020

1.  Purpose and nature

Mount ÎÞÂëÊÓƵ Memorial ÎÞÂëÊÓƵ, Gandel Besen House Limited and Mount ÎÞÂëÊÓƵ Memorial ÎÞÂëÊÓƵ Early Learning Limited (together, the ÎÞÂëÊÓƵ) recognise the importance of your privacy and the privacy of students.  This Privacy Policy explains how the ÎÞÂëÊÓƵ intends to collect, store, use, disclose, protect and otherwise handle your personal information and the personal information of students having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by the ÎÞÂëÊÓƵ to you as to the manner in which the ÎÞÂëÊÓƵ will or may collect, store, use, disclose, protect or otherwise handle your personal information.  Some matters are beyond the control of the ÎÞÂëÊÓƵ, such as third party malicious or criminal attacks. 

The ÎÞÂëÊÓƵ may allow its related entities, such as its subsidiaries, and their employees, to use and process your personal information in the same way and to the same extent that the ÎÞÂëÊÓƵ is permitted to under this Privacy Policy.  These related entities comply with the same obligations that the ÎÞÂëÊÓƵ has to protect your personal information under this Privacy Policy.

2.  What is personal information?

Personal information is information or an opinion about you from which you can be reasonably identified.

3.  Why does the ÎÞÂëÊÓƵ collect personal information?

The ÎÞÂëÊÓƵ collects personal information for the primary purpose of providing educational services and related pastoral care and extra-curricular services. This includes, but is not limited to:

· processing or assessing enrolment, bursaries, subsidies and fees;

· satisfying our legal obligations including our duty of care and child protection obligations;

· keeping parents informed as to ÎÞÂëÊÓƵ community matters, including through correspondence, newsletters and magazines;

· marketing, promotional and fundraising activities;

· supporting the activities of school associations such as the Alumni Association, including for use and disclosure in the Alumni archive database;

· managing enquiries to or from other education institutions regarding parents’ credit status in relation to payment of school fees (Fee Information);

· student behaviour and attendance (Student Details)

· supporting the activities of the School Parents and Friends Association;

· supporting community-based causes and activities, charities and other causes in connection with the ÎÞÂëÊÓƵ’s functions or activities;

· helping us to improve our day to day operations including training our staff; systems development; developing new programs and services; undertaking planning, research and statistical analysis;

· ÎÞÂëÊÓƵ administration including for insurance purposes;

· the employment of staff; and

· the engagement of volunteers.

The ÎÞÂëÊÓƵ may also use your personal information for secondary purposes closely related to this primary purpose. If the ÎÞÂëÊÓƵ does not collect your personal information, it may not be able to provide you or the student(s) with these services.

4.  What personal information does the ÎÞÂëÊÓƵ collect?

The types of personal information collected by the ÎÞÂëÊÓƵ include:

(a) names;

(b) contact details (including address, email address, telephone number(s) and other contact details);

(c) sex;

(d) dates of birth;

(e) tax file numbers;

(f) banking details;

(g) credit status in relation to payment of school fees;

(h) student behaviour and attendance records;

(i) receipt of and eligibility for government benefits relevant to child care subsidies;

(j) images, photos and videos; and

(k) other information you provide to us.

The ÎÞÂëÊÓƵ expects you to only provide the ÎÞÂëÊÓƵ with personal information that is accurate, complete and up to date.

The ÎÞÂëÊÓƵ collects personal information from parents, students, prospective parents, prospective students, job applicants, staff, volunteers and others.

4.1 Sensitive Information

The personal information collected by the ÎÞÂëÊÓƵ may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Health information collected by the ÎÞÂëÊÓƵ includes medical records, disabilities, immunisation details and counselling reports.

The ÎÞÂëÊÓƵ will only use sensitive information:

(a) for the primary purpose for which it was obtained;

(b) for a secondary purpose that is directly related to the primary purpose;

(c) with your consent; or

(d) where required or authorised by law.

5.  Personal information of students

The Privacy Act does not differentiate between adults and children. The Privacy Act does not specify an age after which students can make their own decisions regarding their personal information.

The ÎÞÂëÊÓƵ’s practice is to refer requests for personal information or consent to a student’s parents or carers. The ÎÞÂëÊÓƵ treats notices to parents as notices to students and will accept consents provided by parents as consent on behalf of a student.

However, the ÎÞÂëÊÓƵ understands that in some circumstances, particularly in relation to older students, it may be appropriate to directly seek personal information and consent from students.

There may be circumstances where a student of a certain age, maturity and understanding withholds consent and personal information held by the ÎÞÂëÊÓƵ will not be disclosed to parents, including circumstances where providing such information would impact on the privacy of others or undermine the ÎÞÂëÊÓƵ’s duty of care to the student.

6.  How does the ÎÞÂëÊÓƵ collect your personal information?

The ÎÞÂëÊÓƵ will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide the ÎÞÂëÊÓƵ with personal information about yourself or your child you consent to the use, disclosure and handling of that personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 13).

6.1 Collecting information from you

If it is reasonable and practical do to so, the ÎÞÂëÊÓƵ will collect personal information directly from you.

Depending on how you choose to interact with the ÎÞÂëÊÓƵ, the ÎÞÂëÊÓƵ may collect your personal information when you contact, or are contacted by, the ÎÞÂëÊÓƵ or its service providers by telephone, by email, through the ÎÞÂëÊÓƵ’s website, through financial transactions and surveillance activities such as CCTV, email monitoring, social media and other digital services, from photographers hired by the school, or from photos or videos take by school staff or volunteers, or when you complete a form or document and provide it to the ÎÞÂëÊÓƵ.

6.2 Collecting information from third parties

The ÎÞÂëÊÓƵ may also collect information about you or your child from other people (e.g. a third party administrator), another education provider or institution or independent sources. For example, the ÎÞÂëÊÓƵ may collect personal information about you from character referees in an employment context or from another education institution in an enrolment context.

However, the ÎÞÂëÊÓƵ will only do so where it is not reasonable and practicable to collect the information from you directly. If you are a parent of a prospective student of the ÎÞÂëÊÓƵ, you consent to the ÎÞÂëÊÓƵ contacting other education institutions that a prospective student has previously attended, to request and receive Fee Information and Student Details.   

Where the ÎÞÂëÊÓƵ has collected your information from a third party, such personal information will be held, used and disclosed by the ÎÞÂëÊÓƵ in accordance with this Privacy Policy.

6.3 Collecting information from visits to the ÎÞÂëÊÓƵ’s website

The ÎÞÂëÊÓƵ may also collect information based on how you use its website, including through ‘cookies’, web beacons and other similar technologies.

Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable the ÎÞÂëÊÓƵ’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services. No attempt is made by the ÎÞÂëÊÓƵ to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the ÎÞÂëÊÓƵ’s website may not function fully for users that disable cookies.

6.4 Unsolicited information

If the ÎÞÂëÊÓƵ receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, the ÎÞÂëÊÓƵ will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

7.  How does the ÎÞÂëÊÓƵ hold your personal information?

The security of your personal information is important to the ÎÞÂëÊÓƵ.  Accordingly, the ÎÞÂëÊÓƵ takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps include the implementation of the following safeguards including the provision of information in relation to what processes apply - e.g. password protected databases, staff training, system firewalls, internal information security policies, restricting access to school data bases, levels of security clearance, training staff, lockable filing cabinets, security measures to protect ÎÞÂëÊÓƵ grounds.

In relation to personal information collected about parents and students, the ÎÞÂëÊÓƵ will retain personal collected until the later of the expiry of seven years after all children in the same family have completed Year 12, or when all children in the same family have otherwise permanently left the ÎÞÂëÊÓƵ (including by cancelled enrolment), or all fees and other amounts payable to the ÎÞÂëÊÓƵ in respect of those children have been paid in full.

The ÎÞÂëÊÓƵ will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed, where it is lawful for the ÎÞÂëÊÓƵ to do so.

The ÎÞÂëÊÓƵ’s data security practices have been adopted with a view to protecting the data held by the ÎÞÂëÊÓƵ.  Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, the ÎÞÂëÊÓƵ cannot guarantee any transmission will be completely secure.

8.  How does the ÎÞÂëÊÓƵ use your personal information?

The ÎÞÂëÊÓƵ may hold, use or disclose your personal information so that it can administer and provide educational services that you request.

The ÎÞÂëÊÓƵ may also hold, use or disclose your personal information to:

(a) consider any concern or complaint that you raise against the ÎÞÂëÊÓƵ or to manage any legal action between you and the ÎÞÂëÊÓƵ;

(b) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or

(c) comply with any relevant laws, regulations, codes of practice and court orders.

9.  How is personal information disclosed to others?

The ÎÞÂëÊÓƵ does not sell, rent or trade personal information to, or with third parties.

The ÎÞÂëÊÓƵ may disclose your personal information to third parties in limited circumstances, including to government agencies, external providers that perform services on behalf of the ÎÞÂëÊÓƵ, other parents including another parent with whom you share parental responsibility for a student, visiting teachers, counsellors and coaches, persons who access school databases including the Alumni archive, and to other education institutions that contact the ÎÞÂëÊÓƵ after you or a student has left the ÎÞÂëÊÓƵ to obtain information regarding Fee Information and/or Student Details.

The ÎÞÂëÊÓƵ may also disclose your information to its staff, the ÎÞÂëÊÓƵ’s Executive Committee, Bursary Committee and Finance Committee (being committees whose membership includes both parent representatives and senior staff representatives), on a need to know basis, for the purposes described in clause 3.

The ÎÞÂëÊÓƵ’s website may contain certain links to other websites. The ÎÞÂëÊÓƵ does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.

The ÎÞÂëÊÓƵ regularly takes photos and videos of the ÎÞÂëÊÓƵ’s students and students’ activities. These images are sometimes used for publicity purposes such as in school newsletters, in the press or for use in brochures or other materials promoting the ÎÞÂëÊÓƵ. On occasion the ÎÞÂëÊÓƵ shares these images with partner organisations when the ÎÞÂëÊÓƵ considers this to be in the interest of promoting the ÎÞÂëÊÓƵ. Parents who do not wish to have images of their children used for publicity purposes will need to notify the college of writing, using the contact details in clause 12 below.

9.1 Cross-border disclosure

The ÎÞÂëÊÓƵ may transfer your personal information to an entity which is in a foreign country to assist the ÎÞÂëÊÓƵ in providing its educational services. 

If personal information is shared overseas, the ÎÞÂëÊÓƵ must take reasonable steps to ensure that the overseas entity is APP compliant, unless an exemption applies.  One of these exemptions is when the ÎÞÂëÊÓƵ obtains prior consent to such disclosure from parents and students after expressly informing them that the obligation to ensure APP compliance will not apply to any disclosures given with such consent. However, including this statement in the privacy policy itself would not be sufficient to imply consent.  If the ÎÞÂëÊÓƵ proposes to use this exemption, consent will need to be directly obtained from the individual at the time the personal information is collected, or at some later time. Otherwise, the ÎÞÂëÊÓƵ will to take reasonable steps to ensure the overseas party is complying with the APPs.

10.  How you may access or correct your personal information

You may contact the ÎÞÂëÊÓƵ to request access to the personal information it holds about you at any time. You may also ask the ÎÞÂëÊÓƵ to correct information about you that you may believe is inaccurate, incomplete or out of date.

Please contact the ÎÞÂëÊÓƵ using the contact details set out in clause 12. The ÎÞÂëÊÓƵ will need to verify your identity before giving you access to, or correcting, your personal information. The ÎÞÂëÊÓƵ will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however the ÎÞÂëÊÓƵ may charge a reasonable fee to cover the administrative costs of retrieving your personal information.

In certain circumstances, the ÎÞÂëÊÓƵ may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, the ÎÞÂëÊÓƵ will write to you to explain the reasons why this is the case.

11.  How you may complain if you have concerns about how the ÎÞÂëÊÓƵ has managed your personal information

If you have a complaint related to how the ÎÞÂëÊÓƵ has managed your personal information, please contact the ÎÞÂëÊÓƵ using the contact details set out in clause 12. The ÎÞÂëÊÓƵ may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.

The ÎÞÂëÊÓƵ will provide you with an estimated response timeframe in relation to your complaint. The ÎÞÂëÊÓƵ will endeavour to resolve the complaint as soon as reasonably practicable.

If a complaint remains unresolved, or you are not satisfied with the ÎÞÂëÊÓƵ’s resolution of the complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at to have the complaint heard and determined.

12.  How to contact us

If you have any questions about this Privacy Policy or the ÎÞÂëÊÓƵ’s management of your personal information, please contact the ÎÞÂëÊÓƵ on:

Attention: Sue Templeman, Risk & Compliance Manager

Tel: 03 9834 0024

Email: stempleman@scopus.vic.edu.au

13.  Changes to the ÎÞÂëÊÓƵ’s privacy policy and information handling practices

This Privacy Policy is subject to change at any time so we encourage you to review this Privacy Policy at regular intervals. If the ÎÞÂëÊÓƵ changes this Privacy Policy an updated version will be posted on the ÎÞÂëÊÓƵ’s website to notify you of this change. By continuing to use the ÎÞÂëÊÓƵ’s services after that time you will be deemed to have accepted any changes to its Privacy Policy.