Privacy Policy

Purpose:

To protect the privacy of all stakeholders in accordance with relevant legislation.

Definition/s:

Privacy is a key value which underpins human dignity and other key values such as freedom of association and freedom of speech. Privacy is a basic human right and the reasonable expectation of every person. Privacy can pertain to information privacy, bodily privacy, privacy of communications, and territorial privacy.

Personal information is defined within the Act as information or an opinion (including information or an opinion forming part of a database) about an identified individual who is reasonably identifiable. This may include the name, email address, contact numbers and address; and credit card information of an individual. The type of personal information that Habitat Early Learning collects will depend on the dealings that relevant individual may have with the company.

Sensitive Information is a type of personal information about an individual’s health, racial or ethnic origin, political opinions, religion or affiliations and etc. Beyond the aforementioned data collection, it is unlikely that Habitat Early Learning collect sensitive information and unless consent is obtained.

Eligible data breach means unauthorised access, disclosure or loss of personal information that is likely to result in serious harm to any individuals to whom the information relates.

Position Statement:

Habitat Early Learning protects the privacy and confidentiality of all individuals by ensuring that all records and information (held at the Centre or elsewhere) about individual children, families, Educators and management are kept in a secure place and are only accessed by or disclosed to authorised personnel of the Centre, Centre management or another authority authorized under the Education and Care Services National Law 2010. Educators have a legal and ethical responsibility to maintain confidentiality and to respect and be sensitive to the rights of children and their families at all times. This responsibility applies to all forms of communication including, but not limited to, oral, written and digital forms of communication.

Habitat Early learning will act to respect the privacy of children and families in relation to content and photographs used for social media purposes.

Principles:

General:

Habitat Early Learning is committed to protecting the privacy of all stakeholders and abides by the National Privacy Principles contained within the Privacy Act. The Centre collects information to satisfy the legal obligations specified within the Education & Care Services National Law 2010 and Education & Care Services National Regulations 2011.

Under regulation 181, the approved provider of an education and care service must ensure that information kept in a record under these Regulations is not divulged or communicated, directly or indirectly, to another person other than—

a. to the extent necessary for the education and care or medical treatment of the child to whom the information relates; or
b. a parent of the child to whom the information relates, except in the case of information kept in a staff record; or
c. the Regulatory Authority or an authorised officer; or
d. as expressly authorised, permitted or required to be given by or under any Act or law;
e. with the written consent of the person who provided the information.

The National Quality Standard requires administrative systems enable the effective management of a quality service. Habitat Early Learning ensures that records and information are stored appropriately to ensure confidentiality and are available from the service. All records are maintained in accordance with legislative requirements.

All records remain the property of the Approved Provider and cannot be removed from the Centre without prior authorisation.

Website and online content

Collection of Personal Information

Personal information may be used for purposes including managing trends and demographics to assist service improvement, and to facilitate internal business operations, such as quality assurance and administration purposes.

There are many aspects of the company website that can be viewed without providing personal information. However, personal information will also be collected for access to future Habitat Early Learning customer support features. This may include but not be limited to a unique username and password. In the case of recovery of a lost password, sensitive information may be requested.

Collection of Other’s Personal Information

Through the use of the services provided by Habitat Early Learning, information about another person maybe collected. Where a person elects to provide Habitat Early Learning with personal information about another person, authority to disclose that information to Habitat Early Learning should be obtained by the person providing the information. Without Habitat Early Learning taking any further steps required by applicable data protection or privacy laws, Habitat Early Learning may collect, use and disclose such information for the purposes described in this Policy.

This means that the user must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information and Habitat Early Learning’s identity.

Where requested to do so by Habitat Early Learning, a user must assist Habitat Early Learning with any requests by the individual to access or update the personal information collected from them and entered into the services provided by Habitat Early Learning.

Storage and Security of Personal Information

Habitat Early Learning holds personal information in hard copy and electronic formats and implements the following processes to protect this information:

Staff education and training to ensure staff are aware privacy obligations when handling personal information
Administrative and technical controls to restrict access to personal information to only those people who need access
Technological security measures, including fire walls, encryption and anti-virus software
Physical security measures, such as laptop cable locks and the use of privacy screens where appropriate.

Habitat Early Learning will take reasonable steps to notify users and report to the Australian Information Commissioner in the event of an eligible data breach.

Remarketing and Use of Cookies

Habitat Early Learning uses remarketing features to track, optimize and serve online advertising based on the users’ browsing history of the Website. Such activities are performed by collecting information based on a user’s past website visits through the use of cookies and other technologies. The information collected may include but not limited to the browser type, version and language, operating system, pages viewed while browsing the website, page access times and referring website address. The information collected is not personally identifiable, but such information will be shared with service providers and third-party ad servers for the purposes of showing the user more relevant advertising on the Habitat Early Learning website or partner sites.

By using the Website, users consent to Habitat Early Learning placing cookies on personal computers or devices and using the cookies as described in this statement. If a user does not wish to receive any cookies, browsers should be set to refuse cookies. However, this may affect the usage of certain parts of the Website.

Where a user does not wish a third-party advertisement servers to use cookies for targeted advertising purposes, the user can opt-out by clicking on the links below:

Google Analytics: https://marketingplatform.google.com/about/
Adobe: http://www.adobe.com/privacy/opt-out.html

Habitat Early Learning may also use tracking technologies to determine whether users have read, clicked on or forwarded certain email communications. If user does not want responses tracked there is an unsubscribe option outlined in email communication. Alternatively, a user may contact us to update communication preferences.

Habitat Early Learning uses external web services on the website to display content within the web pages of this Website. Habitat Early Learning cannot prevent these sites or external domains from collecting information on consumer use of this embedded content.

Information about Website and Events

Habitat Early Learning may contact users via email, SMS or other means to provide updated information about the Website and services as well as events. Users not wanting to receive such information, can advise Habitat Early Learning via the relevant method provided in electronic marketing messages (e.g. via an ‘unsubscribe’ link) or to write to the company Privacy Officer. Habitat Early Learning will act and amend records promptly.

Changes to this Privacy Policy

Habitat Early Learning reserves the right to make amendments to this Privacy Policy at any time. Habitat Early Learning will notify any changes to this Policy by posting an updated version of the policy on the Habitat website. Where a user has an objection to the Privacy Policy, the Website should not be utilized or accessed.

Accessing, Correcting or Updating Personal Information

Users have a right to access, correct or update personal information, subject to exceptions allowed by the Act. Users may be required to put any request in writing for security reasons. Habitat Early Learning will require evidence to verify a user’s identity. Habitat Early Learning reserves the right to charge a fee for searching for, and providing access to, a user’s information on a per request basis and the right to refuse access if the Act permits.

The Habitat Early Learning Privacy Officer will consider any requests and provide a prompt response. If a user believes the Habitat Early Learning Privacy Officer has not adequately handled a query, a complaint may be lodged with the Office of Australian Information Commissioner at [email protected] or by phoning 1300 363 922.

Policy Implementation:

Management will:

notify any changes to this Policy by posting an updated version of the policy on the Habitat website
take reasonable steps to notify users and report to the Australian Information Commissioner in the event of an eligible data breach
collect personal information from the parent/parents of the enrolling child, about the child/children and authorized nominees
only collect personal information that is necessary for the functioning of the Center
use fair and lawful ways to collect personal information
ensure individuals are aware of the purpose of the Center collecting the personal information
inform individuals if the Center needs to disclose such personal information to any other organisation
inform individuals of the consequences of not disclosing their personal information
only disclose the personal information to personnel within the service whom are authorized to seek the information. In some circumstances under the Education and Care Services National Regulations, personal information can be disclosed to specified authorities
endeavor to ensure that the information collected remains accurate and correct and requires clients to ensure information is updated if changes are made
endeavor to take all reasonable steps to protect the personal information obtained from misuse and loss and from unauthorized access, modification or disclosure. This will include (but is not limited to) ensuring that all sensitive information is stored in locked cupboards and that tiered permissions exist for accessing information
allow individuals to access any personal information that the Center holds about them when asked unless the information is restricted by emergency, law enforcement or public interest situations
not hold any personal information on individuals without the consent of such individual
collect details from parents including names, address, date of birth, phone contacts, medical details, health, routines, and other information which will contribute to the child’s personal profile
hold information regarding the Family’s Child Care Subsidy entitlements
take steps to ensure the personal information collected, used or disclosed, is accurate, complete and up to date. Parents will be required to update their enrolment details at least annually, or whenever they experience a change in circumstances
ensure that information about employees is only accessed by the Centre Management and other authorised personnel. Personnel files can be accessed by individuals, if requested, under supervision by Management
conduct sensitive conversations in a private area away from children and other persons. Such conversations will be documented and stored a confidential manner

Educators will:

maintain confidentiality at all times and under no circumstances provide information or evidence on matters relating to children and/or their families to anyone other than the custodial parent/guardian unless prior written approval by the custodial/guardian is obtained. Exceptions apply in extreme circumstances when requested by law enforcement, public health or public safety officials (this is outlined in the Centre’s obligations under the National Privacy Principles)
maintain the same privacy principles regarding other employees and not relate personal information about another employee to anyone either within or outside the Centre
protect the privacy of families and children in regard to the use of social media

Students and Visitors will:

uphold privacy principles contained within this policy
not disclose family names in course work materials or discussions, unless prior written consent is obtained from the custodial parent/guardian
avoid using Centre related content including photographs in electronic and social media.

It is the Responsibility of the Parent Body / Website Users to:

update enrolment details at least annually, or whenever circumstances change
be aware of avenues to take where the user does not want information collected or used by a third party
not use or access the Habitat Early Learning website where an objection to the Privacy Policy exists
When providing personal information about another person, obtain authority to disclose that information to Habitat Early Learning
direct any query to the Habitat Early Learning Privacy Officer and failing resolution, lodge a complaint with the Office of Australian Information Commissioner:
support the implementation of this policy