Privacy Policy
1. Purpose
The Australian Centre for Career Education (we, our, us) and our related entities recognise the importance of your privacy and understands your concerns about the security of the personal information provided to us.
This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs).
This Privacy Policy details how personal information we may collect, use, disclose, store and otherwise handle your personal information, and how you may gain access to or make complaints about the personal information we hold about you.
In this Privacy Policy:
· Personal information has the definition set out in the Privacy Act and, in general terms, is information or an opinion about an identified individual, or about an individual who is reasonably identifiable.
· Sensitive information is a sub-set of personal information, which is information or an opinion about an individual’s racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices or criminal record, and includes health information and genetic information.
This Policy does not form part of any contract of employment or contract for services.
2. What personal information we collect and hold
The kinds of personal information we collect from you or about you depend on the transaction you have entered into with us and may include:
· your name;
· your residential, billing and/or postal address;
· your contact details such as telephone numbers and e-mail addresses; and
· details of your employment history.
Generally, we do not collect sensitive information. However, we may collect sensitive information from you or about you where it is reasonably required for our activities, there is a legal requirement to do so, or where we are otherwise permitted by law. For example, we may collect sensitive information about you during the recruitment process, such as procuring a criminal history check. In all other situations, we will specifically seek your consent.
We also collect technical information and general analytics, which may include web browser type and browsing preferences, Internet service provider, referring/exit pages, and date/time stamps, and IP address arising from your use of our websites.
3. How we collect and hold personal information
We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so. For example, we may collect personal information from you through telephone calls with our employees, your emails and other correspondence to us or our employees, online forms, letters, account set up, enquiries and membership forms, access or use of our website, subscription to our newsletters, entering surveys, competitions or promotions, or if you apply to work with us or are engaged by us as a contractor.
We also use cookies and other technologies (such as log files, web beacons, tags or pixels) to collect technical information and general analytics. Cookies are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. By using our website, you are consenting to the use of cookies in accordance with this Privacy Policy.
4. Can you choose not to disclose your personal information
You can be anonymous or use a pseudonym when dealing with us, unless:
· the use of your true identity is a legal requirement; or
· it is impracticable for us to deal with you on such basis.
However, if we do not collect, hold, use or disclose your personal information, or if you do not provide your consent, then we may not be able to answer your enquiry. For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number.
5. Why we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities. For example, we collect, hold, use and disclose your personal information as necessary to provide our services, for our administration and accounting purposes associated with providing these services, for statistical and data collection purposes, providing you with information about other services offered by us, marketing and promotions, market research and newsletter communications.
Technical information and general analytics is used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are on our website, and to improve our website and our products and services.
Where we wish to use or disclose your personal information for other purposes, we will obtain your consent unless it could be reasonably expected that we would use the information for a related purpose.
Where we use your personal information for marketing and promotional communications, you can opt out at any time by notifying us. Opt out procedures are also included in our marketing communications.
We may also use or disclose your personal information to third parties (including government departments and enforcement bodies) where required or permitted by law.
6. To whom do we disclose personal information
We may disclose your personal information to third parties in connection with the purposes described above. This may include disclosing your personal information to the following types of third parties:
· our related companies;
· any potential third party acquirer of our business or assets, and advisors to that third party;
· our professional advisers (such as lawyers, accountants or auditors) and insurers;
· our employees, contractors and third party service providers who assist us in performing our functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, telecommunications providers and IT support services providers;
· organisations authorised by us to conduct promotional, research or marketing activities;
· third parties to whom you have authorised us to disclose your information (e.g. referees); and
· any other person as required or permitted by law.
If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.
7. Does personal information leave Australia
We store personal information in servers located in Australia. We may disclose your personal information to overseas recipients, such as to our service providers located overseas. For example, we transfer personal information to our service provider located in the United Kingdom.
Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Australian Privacy Principles stated in the Privacy Act in relation to such information.
8. How we hold, store and keep secure your personal information
Your personal information is held and stored on paper, by electronic means or both. We have reasonable physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorised access, modification and disclosure. Our staff members receive training on privacy procedures.
When you provide us with your personal information, it is stored in a secure environment that is accessible only by authorised staff or where off-site storage is required, by authorised professional storage contractors.
However, as the Internet is inherently insecure, we cannot guarantee the security of transmission of personal information you disclose to us online. Accordingly, you transmit your personal information to us online at your own risk.
Please notify us immediately if you become aware of any breach of security.
9. Destruction and de-identification
We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose. We will take reasonable steps and use secure methods to destroy or de-identify personal information that is no longer required for any purpose for which the personal information may be used under this Privacy Policy in accordance with the Privacy Act.
10. Requests for access and correction
We will take reasonable steps to ensure that the personal information we use or disclose is accurate, complete and up to date, having regard to the purpose of the use or disclosure.
We rely on the personal information we hold about you to efficiently provide our services. For this reason, it is very important that the personal information we collect from you is accurate, complete and up-to-date. We have procedures in place for dealing with and responding to requests for access to, and correction of, the personal information held about you. In order to protect your Personal Information, we may require identification from you before releasing or changing your personal information. In most cases, we expect that we will be able to comply with your request. However, if we do not agree to provide you access or to correct the information as requested, we will give you written reasons for our decision.
If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you. To assist us to keep our records up-to-date, please notify us at admin@ceav.vic.edu.au of any changes to your personal information.
11. Data Breaches
In Australia, if we suspect that an eligible data breach (as defined under the Privacy Act) has occurred, we will undertake an assessment into the circumstances of the suspected eligible data breach within 30 days after the suspected eligible data breach has occurred. Where it is ascertained that an eligible breach has actually occurred and where required by law, we will notify the Privacy Commissioner and affected individuals as soon as practicable after becoming aware that an eligible data breach has occurred in accordance with our obligations under the Privacy Act.
12. Complaints and concerns
We have procedures in place for dealing with your complaints and concerns about our practices in relation to the Privacy Act, and any alleged breach of this Policy. We will respond to your complaint in accordance with the relevant provisions of the APPs.
Our Privacy Officer can be contacted to discuss or attempt to resolve any complaints relating to the collection, storage and use of your personal information. For further information, please contact our Privacy Officer at admin@ceav.vic.edu.au.
If you are unsatisfied with the outcome, we will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.
13. Local exemptions and inconsistency with law
Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption), we may rely on such an exemption.
This Privacy Policy will not apply to the extent that it is inconsistent with any applicable law.
14. Changes to this Privacy Policy
It may be necessary for us to review and revise our Privacy Policy from time to time in accordance with legislative changes. This Policy replaces any previous policies relating to Privacy.
15. How to Contact Us
Should you have other questions or concerns about this privacy statement, please send us an email to admin@ceav.vic.edu.au or write to us at our Head Office at:
Privacy Officer
Lee Ponsioen
The Australian Centre for Career Education
61 Civic Drive
GREENSBOROUGH VIC 3088
Tel. (03) 9433 8000
Last updated: 21/06/2023