All members of the Mentone Girls’ Grammar School (“the School”) staff, contractors and volunteers must comply with this Policy. This Policy describes :
• who we collect information from;
• the types of personal information collected and held by us;
• how this information is collected and held;
• the purposes for which your personal information is collected, held, used and disclosed;
• how you can gain access to your personal information and seek its correction;
• how you may com plain or inquire about our collection, handling, use or disclosure of your personal information and how that complaint or inquiry will be handled; and
• whether we are likely to disclose your personal information to any overseas recipients.
2. Who do we collect personal information f rom?
At the School we collect personal information from students, parents, prospective parents, job applicants seeking employment , staff, volunteers and others including alumn ae , contractors , visitors and others that come into contact with the S chool .
It is noted that employee records are not covered by the Australian Privacy Principles or the Health Privacy Principles where they relate to current or former employment relations between the S chool and the employee.
3. What kinds of personal information do we c ollect?
The kinds of personal information we collect is largely dependent upon whose information we are collecting and why we are collecting it , however in general terms the S chool may collect:
• Personal Information including name s , address es and other contact details , date s of birth , next of kin details , marital status, billing details, financial information , photographic images and attendance records.
• Sensitive Information is a subset of personal information (particularly in relation to student and parent records) including health, religious beliefs, government related identifiers, nationality, country of birth, languages spoken at home, professional or union memberships, family court orders and criminal records.
• Health Information is a subset of sensitive information (particularly in relation to student and parent records) including medical records, disabilities, immunisation details, individual health care plans, counselling reports, prescription and other pharmaceutical purchases, nutrition and dietary requirements.
4. How do we collect your personal information?
How we collect personal information will largely be dependent upon whose information we are collecting.
If it is reasonable and practical to do so, we collect personal information directly from you.
Where possible the school has attempted to standardise the collection of personal information by using specifically designed forms (e.g. an Enrolment Form or a Health Information Disclosure Form). However , given the nature of our operations , we often also receive personal information by email, letters, notes, ove r the telephon e, in face - to - face meetings , through financial transactions and through surveillance activities such as the use of CCTV security cameras or email monitoring .
We may also collect personal information from other people (e.g. a personal reference) or independent sources (e.g. white pages online ) , however w e will only do so where it is not reasonable and practical to collect the information from you directly.
Sometimes we may be provided with your personal information w ithout having sought it through our normal means of collection. We refer to this as “unsolicited personal information”. Where we collect unsolicited personal information we will only hold, use and / or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited personal information could not have been collected by normal means then we will destroy, permanently delete or de - identify the information as appropriate.
5. How we use personal information
We only use personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented .
Our primary uses of personal information include but are not limited to:
• providing education, pastoral care, extra - curricular and health services ;
• satisfying our legal obligations including our duty of care and child protection obligations;
• keeping parents informed as to school community matters through correspondence, newsletters and magazines ;
• direct marketing, promotional and fundraising activities . All direct marketing communications which the School sends includes an easy opt - out procedure if at any time you wish the School to stop sending you information ;
• supporting the activities of school associations such as Parents’ Association, Old Girls’ Club including Reunions ;
• supporting the activities of the School F oundation ;
• supporting community based causes and activities, charities and other causes in connection with the School’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 ;
• school administration including for insurance purposes;
• the employment of staff ;
• t he engagement of volunteers .
W e only collect sensitive information reasonably necessary for one or more of these functions or activities , if we have the consent of the individuals to whom the sensitive information relates , or if the collection is necessary to lessen or prevent a serious threat to life, health or safety , or another permitted g eneral situation (such as locating a missing person) or permitted health situation (such as the collection of health information to provide a health service) exists.
If we do not have the relevant consent and a permitted health situation or permitted gene ral situation does not exist , then we may still collect sensitive information provided it relates solely to individual s who have regular contact with the school in connection with our activities. These individuals may include students, parents , volunteers , former students and other individuals with whom the S chool has regular contact in relation to our activities .
We will only use or disclose sensitive information for a secondary purpose if you would reasonably expect us to use or disclose the information and the secondary purpose is directly related to the primary purpose.
We will not adopt, use or disclose a go vernment related identifier of an individual (e.g. Medicare Numbers, Passport Numbers, etc.) unless an exception applies such as the use or disclosure is reasonably necessary for the School to verify the identity of the indi vidual for the purposes of the School’s activities .
6. Storage and Security of Personal Information
We store personal information in a variety of formats including on databases, in hard copy files and on personal devices including laptop computers, mobile phones, cameras and other recording devices.
The security of your personal information is of importance to us and we take all reasona ble steps to protect the personal information we hold about you from misuse, loss, unauthorised access, modification or disclosure.
The se steps include :
• Restricting access to information on the S chool databases on a need to know basis with different levels of security be ing allocated to staff based on their roles and responsibilities and security profile.
• Ensuring all staff are aware that they are not to reveal or share personal passwords.
• Ensuring where sensitive and health information is stored in hard co py files that these files are stored in lockable filing cabinets in lockable rooms. Access to these records is restricted to staff on a need to know basis.
• Implementing physical security measures around the S chool buildings and grounds to prevent break - i ns.
• Implementing ICT security systems, policies and procedures , designed to protect personal information storage on our computer networks.
• Implementing Human R esources policies and procedures, such as email and internet usage, confidentiality and document security policies , designed to ensure that staff follow correct protocols when handling personal information .
• Undertaking due diligence with respect to third party service providers who may have access to personal information, including c loud service prov iders, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
Personal information we hold that is no longer needed is destroyed in a secure manner , deleted or de - identified as appropriate .
Our website may contain links to other websites. We do not share your personal information with those websites and we are not responsible for their privacy practices. Please check their P rivacy policies.
7. When we disclose personal information
We only use personal information for the purposes for which it was given to us, or for purposes which are related (or directly related in the case of sensitive information) to one or more of our functions or activities. We may disclose your personal information to government agencies, other parents, other schools, recipients of school publications, visiting teachers, counsellors and coaches, our service providers, agents, con tractors, business partners and other recipients from time to time , only if one or more of the following apply:
• you have consented ;
• you would reasonably expect us to use or disclose your personal information in this way ;
• we are authorised or required to do so by law ;
• disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety ;
• where another permitted general situation or permitted health situation exception applies ;
• disclosure is reasonably neces sary for a law enforcement related activity .
8. Personal Information of Student s
The Privacy Act does not differentiate between adults and children and does not specify an age after which individuals can make their own decisions with respect to their personal information.
At Mentone Girls’ Grammar School we take a common sense approac h to dealing with a student’s personal information and generally will refer any requests for personal information to a student’s parents/carers. We will treat no tices provided to parents/guardians as notices provided to students and we will treat consents provided by parents/ guardians as consents provided by a student.
We are however cognisan t of the fact that children do have rights under the Privacy Act , and that in certain circumstances (especially when dealing with older students and especially when dea ling with sensitive information) , it will be appropriate to seek and obtain consents directly from students. We also acknowledge that there may be occasions where a student may give or withhold consent with respect to the use of their personal information independently from the ir parents/guardians .
There may also be occasions where parents/carers are denied access to information with respect to their children , because to provide such information would have an unreasonable impact on the privacy of others , or result in a breach of the S chool’s duty of care to the student.
9. Disclosure of personal information to overseas recipients
We may disclose personal information about an individual to overseas recipients in certain circumstances, such as when we are orga nising an overseas excursion, facili tating a student exchange . We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:
• We have the individual’s consent (which may be implied); or
• We have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime ; or
• We form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an i ndividual or to public safety ; or
• We are taking appropriate action in relation to suspected unlawful activity or serious misconduct
10. How we ensure the quality of your personal information
We take all reasonable steps to ensure the personal information we hold , use and disclose is accurate, complete and up - to - date. These steps include ensuring that the personal informati on is accurate, complete and up - to - date at the time of collection and when using or disclosing the personal information. On an ongoing basi s , we maintain and updat e personal information when we are advised by individuals or when we become aware through other means that their personal information has changed .
It is your responsibility to contact us if any of the details you have provided change. You should a lso contact us if you believe that the information we have about you is not accurate, complete or up to date.
11. How to gain access to your personal information we hold
You may request access to the person al information we hold about you, or request that we c hange the personal information by logging onto the Parent Portal and advising the School of any updates or changes that may be required .
If we do not agree to provide you with acces s , or to amend your personal information as requested , you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision. If the rejection relates to a request to change your personal information , you may make a st atement about the requested change and we will attach this to your record.
12. Privacy Complaints
If you wish to make a complaint about a breach by us of the Australian Privacy Principles or the Health Privacy Principles you may do so by providing your written complaint by email, letter or by personal delivery to any one of our contact details as noted below . You may also make a complaint verbally.
We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we ma y seek further information from you in order to provide a full and complete response.
Your complaint may also be taken to the Office of the Australian Information Commissioner.
13. How to Contact Us
You can contact us about this Policy or about your personal information by:
• Calling 03 9581 1200; or
• Writing to our Privacy Officer at 11 Mentone Parade, Mentone, 3194
If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.
14. Changes to our privacy and information handling practices