To ensure that ETC meets its legislative requirements regarding the receipt, storage and sharing of information about its customers and staff (individuals).
SCOPE OF POLICY
This policy applies to all ETC Staff, Managers, Board of Directors and contractors acting on behalf of ETC.
The Privacy Act does not apply to the handling of information that does not relate to individuals eg businesses, corporations and companies
Information or an opinion (including information or an opinion forming part if a database), whether true or not and whether recorded in a material form or not, about an individual whose entity is apparent or can reasonably be ascertained from the information or opinion.
Information or an opinion about an individual’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs, memberships of professional or trade associations, sexual preferences or practices, criminal record.
1) ETC is committed to respecting the right to privacy and protecting personal information. ETC is bound by the Australian Privacy Principles that underpin the Privacy Act of 1988 (Commonwealth).
2) ETC must also adhere to other applicable legislation, guidelines and contractual obligations as required and listed in Related Documents and References of this Policy.
3) This policy applies to the management of personal information, how it is captured, stored, used and disclosed and describes the purposes for which it is obtained.
4) This policy is to be used in conjunction with the Australian Privacy Principles
Collecting your personal information
ETC collects personal information so that we can perform our primary business functions in line with contractual obligations and legislative requirements.
The purposes for collecting information may include activities associated with; course enquiries, course enrolment and assessment, confirming your identity for funded and unfunded training and assessment, workshop registration, recruitment, payroll information, personnel information for HR purposes, confirming your identify to provide secure access to databases and IT systems required to conduct ETC business, jobseeker assistance, supplier payments, customer success stories, processing customer feedback and wage payments.
As much as reasonably practical, an individual will be notified at or before the collection of any of personal or sensitive information and the purpose for which the information will be used and who it will be shared with.
How ETC will collect personal information
ETC will collect this information through forms completed and provided to us by our customers and staff such as enrolment forms, business cards, job applications, payroll related forms, assessment evidence, workshop registration (Register Now), forms associated with the delivery and service of any of our current contracts.
Sensitive information may also be collected from individuals as part of the delivery of our services.
ETC does not collect cookies from its website or gather other personal information from any social media medium.
Collection of information from third parties
ETC may collect information about individuals from other parties such as; (not limited to) the Department of Employment (DoE), NSW Department of Communities (DEC), Queensland Department of Education and Training (DET), Australian Apprenticeship Centres (AAC’s), Employers, other jobactive providers, Disability Employment Service (DES), Criminal history checks, Working with Children checks etc.
Collection of this information will only occur as is reasonably necessary for one or more of ETC’s functions or activities.
Who we will disclose your information to
ETC will only use personal or sensitive information for the purpose/s that it was gathered for.
If it is deemed necessary to use this information for any other purpose, the customer must consent to its use for this purpose. In some instances the individual would reasonably expect that the information would be used for the secondary purpose.
Personal information may be disclosed and passed on to the Department of Employment and to other persons in relation to providing Services under the Employment Services Deed.
In some instances ETC may be required by law to disclose information to a Third Party.
Requirements for confirming identity and retaining anonymity
Individuals have an option of using a pseudonym or not identifying themselves when making enquiries about our product or services. In most instances it is impractical for ETC to provide a full service to customers who have not identified themselves; it may also be a requirement of law or a Commonwealth or state contract to confirm an individual’s identity before providing a full service to them.
Use of Government Identifiers
ETC is required to use government related identifiers such as state drivers licence, passport, Job Seeker Identification Number, Training Contract Identification Number, Centrelink Customer Reference Number, Unique Student Identifier, Tax File Number, Australian Business Number etc. to confirm an individual’s identity for the purposes of providing services to the individual and where it is a requirement of a State, Territory or Commonwealth authority.
Protection, Storage and Disposal of customer information
ETC will take reasonable steps to ensure that any information that is disclosed/stored by any other party, that this party has a policy in place that is in line with the Australian Privacy Principles (for example a cloud computing data base).
When handling Protected Information, ETC complies with the requirements of the Social Security (Administration) Act 1999.
ETC takes privacy of information very seriously and will at all times take steps to ensure that an individual’s information is stored and disposed of securely through the use of and adherence to protected IT systems, filing systems, security procedures, secure offsite storage and records management policies.
ETC may contact an individual to advise them about a product or related service that they have expressed interest in. ETC will only use personal information from an individual for the purpose of direct marketing;
a) with their consent; or
b) if the individual would reasonably expect ETC to use their information for this purpose
ETC will provide an easily accessible “opt out’ option for all direct marketing.
ETC will not disclose customer information to any Third Party for the purposes of Direct Marketing.
Accuracy of information
ETC will take reasonable steps to ensure that the information it holds about an individual is accurate and up to date. With most of the services and functions that ETC delivers, opportunity is provided at regular intervals for individuals to update information.
ETC will correct any information that it may have about an individual within a reasonable timeframe if it is satisfied that the information is accurate and complete.
Access to information
An individual may request access to their records held by ETC. In some instances ETC is not obliged to provide access to the information such as in circumstances where the information held is a commonwealth record, giving access is unlawful, would impact on the privacy of other individuals or is frivolous or vexatious.
If ETC denies or grants access to or charges a fee for producing copies of records, it will notify the individual of the reason or cost. The cost of any fees must be fair and not excessive.
If an individual believes that ETC has not protected their information in line with the Privacy Act 1988 and the Australian Privacy Principles, they can contact ETC via the ETC website – Feedback tab to have their concern addressed.
If a concern is not satisfactorily addressed an individual may contact the Office of Australian Information Commissioner (OIAC) to have the concern heard and determined.
RELATED DOCUMENTS AND REFERENCES
• Privacy Act 1988
• Privacy Amendment (Enhancing Privacy Protection) Act 2012
• Privacy Regulation 2013
• Australian Privacy Principles (Office of Australian Information Commissioner)
• Employment Services Deed 2012 – 2015
• Social Security (Administration) Act 1999
• Approved Providers List Contract 2011 to 2015
• Records Management Policy and Procedure (ETC)
• Deed of Confidentiality (ETC)