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S/T CONSTRUCTION TECHNIQUES

RTO CODE 30123

    PRIVACY POLICY

S/T Construction Techniques Registered Training Organisation Privacy Policy


S/T CONSTRUCTION TECHNIQUES takes the privacy of participants seriously and complies with all legislative requirements. These include the Privacy Act 1988 and the Australian Privacy Principles (APPs).


Information is only shared with external agencies such as the National VET Regulator to meet our compliance requirements as an RTO. All information is kept in the strictest confidence.


In some cases we are required by law or required by the Standards for NVR Registered Training Organisations to make learner information available to others such as the National Centre for Vocational Education and Research, Australian Skills Quality Authority (ASQA), Department of Education, Training and Employment, Construction Skills Queensland and any other funding body as required. In all other cases, we will seek the written permission of the learner for such disclosure. Where written permission is required, this will be gained by using the Information Release Form.


S/T CONSTRUCTION TECHNIQUES is committed to maintaining the privacy and confidentiality of its RTO personnel and participant records S/T Construction Techniques complies with the Privacy Act 1988 including the 13 Australian Privacy Principles (APPs) as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012.


S/T CONSTRUCTION TECHNIQUES manages personal information in an open and transparent way. This is evident in the implementation of practices, procedures and system we outline in this policy, that ensure our compliance with the APPs and any binding registered APP code, and provide suitable procedures for S/T CONSTRUCTION TECHNIQUES personnel to be able to deal with related inquiries and complaints that may be received from time to time.


Photography and Video privacy


At S/T CONSTRUCTION TECHNIQUES we recognise that there are sensitivities relating to the taking of photographs and video. S/T Construction Techniques has a comprehensive policy relating to photo and video permissions which is applied to all aspects of the S/T CONSTRUCTION TECHNIQUES activities. Learners undertaking Nationally Recognised Training with S/T CONSTRUCTION TECHNIQUES may include photographs, videos and examples of student’s work for assessment purposes.


Australian Privacy Principle 1 – Open and transparent management of personal information


Purposes for information collection, retention, use and disclosure


S/T CONSTRUCTION TECHNIQUES retains a record of personal information about all individuals with whom we undertake any form of business activity. S/T CONSTRUCTION TECHNIQUES must collect, hold, use and disclose information from our clients and stakeholders for a range of purposes, including but not limited to:

• Providing services to clients;

• Managing employee, auspicing arrangements and contractor teams;

• Promoting products and services;

• Conducting internal business functions and activities; and

• Requirements of stakeholders.


As a government registered training organisation, regulated by the Australian Skills Quality Authority, S/T CONSTRUCTION TECHNIQUES is required to collect, hold, use and disclose a wide range of personal and sensitive information on participants in nationally recognised training programs. This information requirement is outlined in the National Vocational Education and Training Regulator Act 2011 and associated legislative instruments. In particular, the legislative instruments:

• Standards for NVR Registered Training Organisations 2012; and

• Data Provision Requirements 2012.


It is noted that S/T CONSTRUCTION TECHNIQUES is also bound by various State Government Acts requiring similar information collection, use and disclosure (particularly Education Act(s), Vocational Education & Training Act(s) and Traineeship & Apprenticeships Act(s) relevant to state jurisdictions of S/T CONSTRUCTION TECHNIQUES operations).


It is further noted that, aligned with these legislative requirements, S/T CONSTRUCTION TECHNIQUES delivers services through a range of Commonwealth and State Government funding contract agreement arrangements, which also include various information collection and disclosure requirements.


Individuals are advised that due to these legal requirements, S/T CONSTRUCTION TECHNIQUES discloses information held on individuals for valid purposes to a range of entities including:

• Governments (Commonwealth, State or Local);

• Australian Apprenticeships Centres;

• Employers (and their representatives), Job Network Providers, Schools and Guardians.


Kinds of personal information collected and held


The following types of personal information are generally collected, depending on the need for service delivery:

• Contact details;

• Employment details;

• Educational background;

• Demographic Information;

• Course progress and achievement information; and

• Financial billing information.


The following types of sensitive information may also be collected and held:

• Identity details;

• Employee details & HR information;

• Complaint or issue information;

• Disability status & other individual needs;

• Indigenous status; and

• Background checks (such as National Criminal Checks or Working with Children checks).


How personal information is collected


S/T CONSTRUCTION TECHNIQUES’s usual approach to collecting personal information is to collect any required information directly from the individuals concerned. This may include the use of forms (such as registration forms or enrolment forms) and the use of web based systems (such as online enquiry forms).


S/T CONSTRUCTION TECHNIQUES does receive solicited and unsolicited information from third party sources in undertaking service delivery activities. This may include information from such entities as:

• Governments (Commonwealth, State or Local);

• Australian Apprenticeships Centres;

• Employers (and their representatives), Job Network Providers, Schools and Guardians.


How personal information is held


S/T CONSTRUCTION TECHNIQUES’s usual approach to holding personal information includes robust storage and security measures at all times. Information on collection is:

• Stored in secure, password protected systems, such as financial system, learning management system and student management system;

• Hard copies are stored in locked filing cabinets and archive facilities; and

• Monitored for appropriate authorised use at all times.


Only authorised personnel are provided with login information or keys to each system, with system access limited to only those relevant to their specific role. S/T CONSTRUCTION TECHNIQUES ICT systems are hosted internally with robust internal security to physical server locations and server systems access. Virus protection, backup procedures and ongoing access monitoring procedures are in place.


Individual information held across systems is linked through a S/T CONSTRUCTION TECHNIQUES allocated identification number for each individual. Once implemented, the National Unique Student Identifier will also apply.


Retention and Destruction of Information


S/T CONSTRUCTION TECHNIQUES retains information for periods as required. Specifically for our RTO records, in the event of our organisation ceasing to operate the required personal information on record for individuals undertaking nationally recognised training with us would be transferred to the Australian Skills Quality Authority, as required by law.


Accessing and seeking correction of personal information


S/T CONSTRUCTION TECHNIQUES confirms all individuals have a right to request access to their personal information held and to request its correction at any time. In order to request access to personal records, individuals are to make contact with:

S/T CONSTRUCTION TECHNIQUES

07 3624 2500

admin@stct.com.au


A number of third parties, other than the individual, may request access to an individual’s personal information. Such third parties may include employers, parents or guardians, schools, Australian Apprenticeships Centres, Governments (Commonwealth, State or Local) and various other

stakeholders.


In all cases where access is requested, S/T CONSTRUCTION TECHNIQUES will ensure that:

• Parties requesting access to personal information are robustly identified and vetted;

• Where legally possible, the individual to whom the information relates will be contacted to confirm consent (if consent not previously provided for the matter); and

• Only appropriately authorised parties, for valid purposes, will be provided access to the information.


Complaints about a breach of the APPs or a binding registered APP code


If an individual feels that S/T CONSTRUCTION TECHNIQUES may have breached one of the APPs or a binding registered APP Privacy Complaints Procedure below for further information.


Making our APP Privacy Policy available 


S/T CONSTRUCTION TECHNIQUES provides our APP Privacy Policy available free of charge, with all information being publicly available. In addition, this APP Privacy Policy is:

• Accessible at each of S/T CONSTRUCTION TECHNIQUES’s premises and auspiced sites.

• Included within our RTO Student Handbook;


Review and Update of this APP Privacy Policy


S/T CONSTRUCTION TECHNIQUES reviews this APP Privacy Policy:

• On an ongoing basis, as suggestions or issues are raised and addressed, or as government required changes are identified;

• Through our internal audit processes on at least an annual basis;

• As a part of any external audit of our operations that may be conducted by various government agencies as a part of our registration as an RTO or in normal business activities; and

• As a component of each and every complaint investigation process where the compliant is related to a privacy matter.


Where this policy is updated, changes to the policy are widely communicated to stakeholders through internal personnel communications, meetings, training and documentation, and externally through publishing of the policy on S/T CONSTRUCTION TECHNIQUES’s website and other relevant documentation (such as our Student Handbook) for clients.


Australian Privacy Principle 2 – Anonymity and pseudonymity


S/T CONSTRUCTION TECHNIQUES provides individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us in relation to a particular matter, whenever practical. This includes providing options for anonymous dealings in cases of general course enquiries or other situations in which an individuals’ information is not required to complete a request. 


Individuals may deal with us by using a name, term or descriptor that is different to the individual’s actual name wherever possible. This includes using generic email addresses that does not contain an individual’s actual name, or generic user names when individuals may access a public component of our website or enquiry forms.


S/T CONSTRUCTION TECHNIQUES only stores and links pseudonyms to individual personal information in cases where this is required for service delivery (such as system login information) or once the individual’s consent has been received.


Requiring identification


S/T CONSTRUCTION TECHNIQUES must require and confirm identification however in service delivery to individuals for nationally recognised course programs. We are authorised by Australian law to deal only with individuals who have appropriately identified themselves. That is, it is a Condition of Registration for all RTOs under the National Vocational Education and Training Regulator Act 2011 that we identify individuals and their specific individual needs on commencement of service delivery, and collect and disclose Australian Vocational Education and Training Management of Information Statistical Standard (AVETMISS) data on all individuals enrolled in nationally recognised training programs. Other legal requirements, as noted earlier in this policy, also require considerable identification arrangements.


There are also other occasions within our service delivery where an individual may not have the option of dealing anonymously or by pseudonym, as identification is practically required for us to effectively support an individual’s request or need.


Australian Privacy Principle 3 — Collection of solicited personal information


S/T CONSTRUCTION TECHNIQUES only collects personal information that is reasonably necessary for our business activities. We only collect sensitive information in cases where the individual consents to the sensitive information being collected, except in cases where we are required to collect this information by law, such as outlined earlier in this policy.


Australian Privacy Principle 4 – Dealing with unsolicited personal information


S/T CONSTRUCTION TECHNIQUES may from time to time receive unsolicited personal information. Where this occurs we promptly review the information to decide whether or not we could have collected the information for the purpose of our business activities. Where this is the case, we may hold, use and disclose the information appropriately as per the practices outlined in this policy. Where we could not have collected this information (by law or for a valid business purpose) we immediately destroy or de-identify the information (unless it would be unlawful to do so).


Australian Privacy Principle 5 – Notification of the collection of personal information


Whenever S/T CONSTRUCTION TECHNIQUES collects personal information about an individual, we take reasonable steps to notify the individual of the details of the information collection or otherwise ensure the individual is aware of those matters. This notification occurs at or before the time of collection, or as soon as practicable afterwards.


Our notifications to individuals on data collection include:

S/T CONSTRUCTION TECHNIQUES’s identity and contact details, including the position title, telephone number and email address of a contact who handles enquiries and requests relating to privacy matters;

• The facts and circumstances of collection such as the date, time, place and method of collection, and whether the information was collected from a third party, including the name of that party;

• If the collection is required or authorised by law, including the name of the Australian law or other legal agreement requiring the collection;

• The purpose of collection, including any primary and secondary purposes;

• The consequences for the individual if all or some personal information is not collected; and

• Other organisations or persons to which the information is usually disclosed, including naming those parties.


Where possible, we ensure that the individual confirms their understanding of these details, such as through signed declarations or in person through questioning.


Australian Privacy Principle 6 – Use or disclosure of personal information


S/T CONSTRUCTION TECHNIQUES only uses or discloses personal information it holds about an individual for the particular primary purposes for which the information was collected, or secondary purposes in cases where:

• An individual consented to a secondary use or disclosure (such as the learner consent form);

• An individual would reasonably expect the secondary use or disclosure, and that is directly related to the primary purpose of collection; or

• Using or disclosing the information is required or authorised by law.


Requirement to make a written note of use or disclosure for this secondary purpose


If S/T CONSTRUCTION TECHNIQUES uses or discloses personal information in accordance with an ‘enforcement related activity’ we will make a written note of the use or disclosure, including the following details:

• The date of the use or disclosure;

• Details of the personal information that was used or disclosed;

• The enforcement body conducting the enforcement related activity;

• If the organisation used the information, how the information was used by the organisation;

• The basis for our reasonable belief that we were required to disclose the information.


Australian Privacy Principle 7 – Direct marketing


S/T CONSTRUCTION TECHNIQUES does not use or disclose the personal information that it holds about an individual for the purpose of direct marketing. S/T CONSTRUCTION TECHNIQUES does not undertake any direct marketing activities.


An individual may also request us at any stage not to use or disclose their personal information for the purpose of direct marketing, or to facilitate direct marketing by other organisations. We comply with any request by an individual promptly and undertake any required actions for free. We also, on request, notify an individual of our source of their personal information used or disclosed for the purpose of direct marketing unless it is unreasonable or impracticable to do so.


Australian Privacy Principle 8 – Cross-border disclosure of personal information


Before S/T CONSTRUCTION TECHNIQUES discloses personal information about an individual to any overseas recipient, we undertake take reasonable steps to ensure that the recipient does not breach any privacy matters in relation to that information.


Australian Privacy Principle 9 – Adoption, use or disclosure of government related identifiers


S/T CONSTRUCTION TECHNIQUES does not adopt, use or disclose a government related identifier related to an individual except:

• In situations required by Australian law or other legal requirements;

• Where reasonably necessary to verify the identity of the individual;

• Where reasonably necessary to fulfil obligations to an agency or a State or Territory

• authority;

• Where required under the Standards for NVR Registered Training Organisations 2012; and

• Data Provision Requirements 2012 or 

• As prescribed by regulations.


Australian Privacy Principle 10 – Quality of personal information


S/T CONSTRUCTION TECHNIQUES takes reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal information we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.


This is particularly important where:

• When we initially collect the personal information; and

• When we use or disclose personal information.


Australian Privacy Principle 11 — Security of personal information


S/T CONSTRUCTION TECHNIQUES takes active measures to consider whether we are able to retain personal information we hold, and also to ensure the security of personal information we hold. This includes reasonable steps to protect the information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.


We destroy or de-identify personal information held once the information is no longer needed for any purpose for which the information may be legally used or disclosed.


Access to S/T CONSTRUCTION TECHNIQUES offices and work areas is limited to our personnel only - visitors to our premises must be authorised by relevant personnel and are accompanied at all times. With regard to any information in a paper based form, we maintain storage of records in an appropriately secure place to which only authorised individuals have access. 


Regular staff training is conducted with S/T CONSTRUCTION TECHNIQUES personnel on privacy issues, and how the APPs apply to our practices, procedures and systems. Training is also included in our personnel induction practices.


We conduct ongoing internal audits (at least annually and as needed) of the adequacy and currency of security and access practices, procedures and systems implemented.


Australian Privacy Principle 12 — Access to personal information


Where S/T CONSTRUCTION TECHNIQUES holds personal information about an individual, we provide that individual access to the information on their request.


In processing requests:

• You may access your records where necessary at any time. If you wish to access your records you must first contact the office administrator to obtain permission.

• You will be required to provide sufficient evidence of identification (preferably a driver’s licence or passport) before the office administrator will grant you access to your records.

• You will be able to view all records privately and take copies where necessary for a nominal charge.

• No other parties will have access to your records without your prior written permission.

• Should you wish to permit a third party access to your records, this will need to be clearly indicated.

• You will need to provide the details of the third party seeking to access your records and the third party will have to provide suitable identification prior to any records being released.


Australian Privacy Principle 13 – Correction of personal information


S/T CONSTRUCTION TECHNIQUES takes reasonable steps to correct personal information we hold, to ensure it is accurate, up-to-date, complete, relevant and not misleading, having regard to the purpose for which it is held.


Individual Requests


On an individual’s request, we:

• Correct personal information held; and

• Notify any third parties of corrections made to personal information, if this information was previously provided to these parties.


Correcting at S/T CONSTRUCTION TECHNIQUES’s initiative


We take reasonable steps to correct personal information we hold in cases where we are satisfied that the personal information held is inaccurate, out-of-date, incomplete, irrelevant or misleading (that is, the information is faulty). This awareness may occur through collection of updated information, in notification from third parties or through other means.


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