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Privacy Policy 11/2017

1. Purpose

The purpose of this policy (Privacy Policy) is to set out how The Hutchins School (School) uses and manages personal information provided to it or collected by it.

2. Scope

The School is bound by the Australian Privacy Principles contained in Schedule 1 of the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy outlines the School’s practices and procedures it has implemented to meet its obligations under the Privacy Act.

The School may, from time to time, review and update this Privacy Policy to take into account new laws and technology, and to ensure that it remains relevant to the School’s operations and practices. Any updated Privacy Policy will be available on our website and is accessible at www.hutchins.tas.edu.au/privacy.

3. Policy information

3.1. Collection of personal information

‘Personal information’ is information or an opinion, in any form (whether true or not), about an identified individual or an individual who is reasonably identifiable. The School collects and holds personal information, including health and other sensitive information, about:

  • students (before, during and after the course of the student’s enrolment at the School);
  • parents/guardians (before, during and after the course of their child’s enrolment at the School);
  • potential employees, current employees, volunteers and independent contractors; and
  • other people who deal with or come into contact with the School.

Personal information you provide

The School will typically collect personal information about an individual by way of forms filled out by parents/guardians or students (including on-line forms), face-to-face discussions and interviews, emails and telephone calls and any other form of communication.

The types of personal information the School may collect includes (but is not limited to):

  • in respect of personal information that is not sensitive information: names, residential addresses, email addresses, and telephone numbers;
  • in respect of sensitive information: nationality, country of birth details, languages spoken, religious beliefs, and family court orders; and
  • in respect of health information: medical records (including immunisation details), disability information, mental health and counselling information, and nutrition and dietary requirements.

Personal information provided by third parties

In some circumstances, the School may also be provided with personal information about an individual from third parties. These third parties may include medical professionals, government agencies, schools, or institutes.

If the School did not request the personal information that it has been provided by a third party, it will (within a reasonable time after receiving such personal information) determine whether it could have collected it from the individual to which the personal information relates. If the School determines that it could not have collected the information (and it is lawful and practical to do so), it will destroy the information or ensure that the information is de-identified.

Exemption in relation to employee records

Under the Privacy Act, this Privacy Policy does not apply to an employee record held by the School, where the record is directly related to a current or former employment relationship between the School and employee.

3.2. How the School uses personal information

The School will use personal information it collects from you for the primary purpose that it was collected, or, if you would reasonably expect the School to do so, for such secondary purposes that are related to the primary purpose of collection (or in the case of sensitive information, directly related to the secondary purpose). We may also use your personal information for other purposes where you have expressly provided your consent or as otherwise authorised under the Privacy Act or other Australian law.

Students and parents

The School may collect students’ and parents’ personal information to enable the School to provide schooling and extra-curricular activities for the student and to satisfy the needs of parents and students throughout the whole period the student’s enrolment at the School.

The purposes for which the School may use personal information of students and parents includes:

  • ensuring students’ educational, social and medical wellbeing are protected;
  • keeping parents informed about matters concerning their child’s schooling and extra-curricular activities, including through reports, letters and email correspondence, or school publications;
  • satisfying the School’s legal obligations, particularly in relation to the duty of care it owes to each Student;
  • conducting administration activities of the School; and
  • seeking donations and marketing for the School.

You may choose to remain anonymous, or to use a pseudonym when dealing with the School where it is lawful and practical to do so. In some cases, where the School requests personal information about a student or parent but the information requested is not provided, the School may be unable to enrol or continue to provide schooling to the student, or permit the student from taking part or continuing to take part in a particular activity.

Potential employees and independent contractors

The School may collect personal information of potential employees and independent contractors to assess and (if the applicant is successful) engage the relevant individual as an employee or independent contractor.

The purposes for which the School uses personal information of potential employees and independent contractors includes:

  • assessing the individual’s suitability for employment or contract;
  • administering the individual’s employment or contract;
  • satisfying the School’s legal requirements (for example, in relation to working with children and police checks);
  • meeting insurance requirements; and
  • seeking funds and marketing for the School.

Volunteers

The School may collect personal information about volunteers to assist the School in its sporting, social, educational, and fundraising functions and associated activities.

Direct Marketing and Fundraising

The School may use your personal information for marketing and promoting the School, or during School related fundraising activities. Your personal information may be disclosed to an internal organisation, such as the Hutchins Foundation, that assists with these tasks. An example of how your personal information may be used for marketing and promotion purposes is through School publications (including print or email publications). These publications may be provided to parents, staff, employees, independent contractors, and other members of the Tasmanian and wider Australian educational community.

If you do not want to receive any marketing correspondence from the School, you may opt-out by contacting the School.

3.3. Disclosure of personal information

The School will not use or disclose personal information held about you that was collected for a particular purpose for another purpose, unless:

  • you have consented to the use or disclosure of the information for another purpose; or
  • the use or disclosure is otherwise permitted under the Privacy Act (for example, you would reasonably expect the School to use or disclose the information for another purpose or the use and disclosure of the information is required or authorised by law or a court/tribunal order).

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

  • teachers and sport coaches;
  • medical practitioners;
  • specialist visiting personnel including teachers from other schools, sports coaches and other people who provide services to the School;
  • parents;
  • other schools;
  • government departments;
  • recipients of school publications, such as newsletters or magazines;
  • Old Boys’ Association and affiliated bodies;
  • Parents’ Association;
  • external sporting bodies with a connection to the School;
  • police;
  • lawyers; and
  • anyone to whom the individual authorises the School to disclose the information.

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

  • another school;
  • government departments;
  • medical practitioners;
  • specialist visiting personnel including teachers from other schools, sports coaches and other people who provide services to the School;
  • police; and
  • anyone to whom the individual authorises the School to disclose the sensitive information.

Disclosure of personal information to overseas recipients

The School may disclose personal information to overseas recipients if it has taken such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles contained in the Privacy Act, or as otherwise may be permitted under the Privacy Act.

If you provide your consent to the disclosure of your personal information to an overseas recipient, you acknowledge that the School is not required to take the steps referred to in the paragraph above.

If your personal information is disclosed to an overseas recipient in accordance with this Privacy Policy, it is likely that such overseas recipients will be located in one of the following locations: China, Hong Kong, Germany, Thailand, Taiwan, Singapore, Indonesia, Spain, France, Italy, Korea or Scotland.

Overseas recipients may include parents and carers, and other schools and their agents (for example, to facilitate an overseas student exchange).

3.4. Management and security of personal information

The School has in place steps and procedures to prevent personal information held by it from being misused, interfered with, lost, modified or accessed or disclosed other than with appropriate authority. For example, the School implements as a minimum the following steps and procedures to ensure the protection of personal information:

  • use of secure storage for both paper and computer records (paper records relating to students are kept in locked rooms and/or filing cabinets);
  • computer records are stored on a dedicated server (computer server is isolated from student networks so as to minimise the risk of unauthorised access);
  • past student files are kept in a secure storage area;
  • regular shredding of documents.

If the School no longer needs personal information it holds about an individual and it is not required to retain the information under Australian law, the School will take reasonable steps to destroy the personal information or to ensure that the personal information is de-identified.

3.5. Access, updating and correction of personal information

Access to personal information

Under the Privacy Act, you have a right to access personal information about you which the School holds. In some circumstances, this right of access may be denied. Examples of these circumstances are where release of the information would have an unreasonable impact on the privacy of others, or where the request for access is frivolous or vexatious. These exceptions to access are set out in the Privacy Act.

If you would like to access your personal information, you may request such access by contacting the School. Any access request must be in writing, identify the nature of the information requested, and be addressed to the Privacy Officer.

The School will respond to such requests in a reasonable time (usually within 30 days). The School may charge a fee to cover its costs in relation to assessing the request and providing the information to the individual. The School will consider any fee on a case-by-case basis.

If the personal information sought relates to a student, or past student, the School generally expects the relevant access request to be undertaken by the student’s parents. The School may, in special circumstances, allow students access to information about them held by the School independently of their parents. The School may also allow a student to give or withhold consent in relation to the use or disclosure of their personal information, particularly sensitive information, where the School considers this to be in the best interests of the student. This may include consideration of whether certain sensitive information should not be disclosed to a parent. In relation to issues of independent access to information and consent, the School will consider the following factors:

  • the age and best interests of the student;
  • the nature of the information;
  • the student’s understanding and expectation about what information might be disclosed;
  • the need for parents to be informed; and
  • the School’s duty of care to the student.

Updating and correcting personal information

The School takes all reasonable steps to ensure that the personal information it holds is accurate, up to date, complete, relevant, and not misleading.

An individual may contact the School requesting that it update any personal information held by the School.

The School will respond to such requests in a reasonable time (usually within 30 days). Any refusal by the School to correct personal information will be in writing and set out the reasons for the refusal, to the extent that it is reasonable to do so. The School will also provide you with information with how you may make a complaint about the refusal.

3.6. Enquiries and complaints

If you would like further information regarding the way the School manages the personal information it holds or wish to make a complaint on the basis that you believe the School has breached an Australian Privacy Principle, please submit your request or complaint in writing to the school’s privacy Officer.

The School will investigate any complaint and will notify you of the outcome in relation to your complaint as soon as is practicable after it has been made.

Enquiries and complaints can be made to:

Privacy Officer

Telephone: 6221 4200
Email: privacyofficer@hutchins.tas.edu.au
Postal Address: PO Box 254, Sandy Bay 7006

If you are not satisfied with the outcome of the Privacy Officer’s investigation or we have not replied to you within a reasonable time, then you can raise your concern with:

The Office of the Australian Information Commissioner

Telephone: 1300 363 992
Email: enquiries@oaic.com.au
Mail: Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001
Online: https://forms.business.gov.au/aba/oaic/privacy-complaint

To learn more about how Hutchins provides opportunities for boys to become their best, we invite you to contact our Enrolments Assistant on 03 6221 4236 who will be delighted to assist you with your enquiry, provide you with further details or arrange a tour so that you may see our school in action. Read more…