Who we are
Our website address is: http://aiel.com.au.
Standards for Registered Training Organisations 2015
National Code 2018
SECTION 1 – INTRODUCTION
CONTEXT
From 12 March 2014, the Australian Privacy Principles (APPs) replaced the
National Privacy Principles and Information Privacy Principles. The APPs
were established under the Privacy Amendment (Enhancing Privacy
Protection) Act 2012, which amends the Privacy Act of 1988, is designed to
protect your rights with respect to personal information that organisations
may hold, to ensure you are aware of your rights and of what information is
held.
PURPOSE
This Privacy Policy and Procedure ensures you are aware of what
information we hold about you and your rights regarding access to this
information.
SCOPE
This policy and procedure applies to all students enrolled with the ANIBT or
AIEL(Sydney). SECTION 2 – POLICY
PRINCIPLES
The Privacy Policy and Procedure is committed to and guided by the
principles of:
• access
• equity
• fairness
• ethical behaviour
LEGISLATION
The follow policy and procedure is written in accordance to the following
Australian Government legislation:
• Privacy Act 1988 and Australian Privacy Principles (2014)
POLICY
The Australian National Institute of Business and Technology (ANIBT) is a
Registered Training Organisation with responsibility for delivering
vocational education and training. The Australian Institute for Education
and Learning is delivering ANIBT courses under license. ANIBT and AIEL
collect and store personal information on its learners and industry clients.
ANIBT and AIEL complies with the Privacy Act 1988 (Commonwealth). This
policy describes how ANIBT and AIEL collects, manages, uses, discloses,
protects, and disposes of personal information in accordance with the
thirteen Australian Privacy Principles (APPs) outlined in Schedule 1 of the
Privacy Amendment (Enhancing Privacy Protection) Act 2012.
DEFINITIONS
Under the Privacy Act 1988 and Privacy Amendment (Enhancing Privacy
Protection) Act 2012 (s6(1)), personal and sensitive information is defined
as follows:
• Personal information: “information or an opinion about an identified
individual, or an individual who
is reasonably identifiable: (a) whether the information or opinion is true or
not; and (b) whether the information or opinion is recorded in a material
form or not.”
• Sensitive information: “(a) information or an opinion about an
individual’s: (i) racial or ethnic origin, or (ii) political opinions, or (iii)
membership of a political association, or (iv) religious beliefs or
affiliations, or (v) philosophical beliefs, or (vi) membership of a
professional or trade association, or (vii) membership of a trade
union, or (viii) sexual preferences or practices, or (ix) criminal record,
that is also personal information; or (b) health information about an
individual; or (c) genetic information about an individual that is not
otherwise health information; or (d) biometric information that is to be
used for the purposes of automated biometric verification or biometric
identification; or (e) biometric templates”.
SECTION 3 – PROCEDURE
AUTHORITY TO COLLECT AND STORE INFORMATION
ANIBT is an approved Registered Training Organisation by the Australian
Skills Quality Authority. This registration is issued under the authority of
the National Vocational Education and Training Regulator Act 2011. AIEL is
also bound by the same requirements. This legislation requires ANIBT and
AIEL to collect personal and sensitive information from its learners. This
requirement is specified in the Data Provision Requirements 2012 which is
one of five legislative instruments that ANIBT and AIEL must comply with
as a condition of ANIBT’s registration. The date provision requirements
require ANIBT and AIEL to collect data from learners in accordance with
the Australian Vocational Education and ANIBT Information Statistical
Standard (AVETMISS). This is a complex information standard that defines information about who the learner is, where the training is delivered and what they are studying. The Standards for Registered Training Organisations require ANIBT and AIEL to retain and store this information for up to 30 years and to report training activity to government agencies in accordance with mandatory reporting requirements.
Together these requirements form a statutory obligation to collect, store and report information of any learner participating in nationally accredited training. The publications referred to in this section can be accessed from the ASQA website.
COLLECTION AND USE
ANIBT and AIEL collect personal information, either directly or indirectly, that is reasonably necessary for, or directly related to its delivery of the services it offers. Some of the information collected may be regarded as ‘sensitive’ as defined by the Privacy Act. In broad terms the kinds of personal information and purposes for which it is collected are:
Solicited information
• Contact information such as name, organisation, position, address, telephone, and email are collected for marketing, support services, mandatory reporting and for communicating with stakeholders as part of our day to day operation.
• In addition to information collected training activity, ANIBT and AIEL will also collect, store and report information relating to satisfaction surveys, complaint handling and on our client employers.
• Names, addresses, phone numbers, emergency contact details, bank account details and other employment related information is collected from employees for the purpose of managing human resources. The management of staff personal information complies with this policy.
COLLECTION METHODS
• Learner personal and sensitive information as well as training activity information is prescribed by the AVETMIS Standard. This information is collected directly from learners using enrolment forms which may be paper based or electronic and other administrative forms including but not limited to complaint forms, recognition of prior learning applications, requests for refund, course transfer applications, etc..
• Survey responses are collected using our Employer and Learner Satisfaction Surveys which are issued in electronic format.
• Enquiry information from prospective learners including personal contact information is collected directly from individuals who make data requests either by telephone or email in person or via our website.
• ANIBT and AIEL personal information is collected from individuals on employment commencement.
SENSITIVE INFORMATION
• Personal information collected by ANIBT and AIEL that may be regarded as ‘sensitive’ under the Privacy Act includes:
- ‘Disability’ and ‘long-term impairment status’ (health); and ‘indigenous status’, ‘language spoken at home’, ‘proficiency in spoken English’, ‘country of birth’ (implies ethnic/racial origin). This information is specified in the AVETMISS data elements and is collected for the national VET data collections, national VET surveys, and may be collected for VET-related research.
- ‘Dietary requirements’ (health-related) are collected for event catering purposes only.
- Biographical information, which may contain information on ‘affiliations’ and ‘membership of a professional or trade association’ are obtained from key note speakers for event marketing purposes.
- ‘Memberships of professional associations’ and ‘health and work injury information’ is collected from ANIBT or AIEL employees for HR management purposes.
DIRECT MARKETING
ANIBT and AIEL respect an individual’s right not to receive marketing material, and provides an option within communications and on its website for individuals to unsubscribe from receiving marketing material. ANIBT and AIEL conducts its marketing communications and dissemination of service information in accordance with Australian Privacy Principle 7 (Direct marketing), the Spam Act 2003 (in respect of electronic communications), and the Do Not Call Register Act 2006. It is not, however, ANIBT’s practice to ‘cold call’ for the purpose of marketing its products and services.
GOOGLE ANALYTICS AND COOKIES
Google Analytics is a web service provided by Google Inc. Cookies are used to generate data on website activity and usage. The cookies, which include IP addresses, are transmitted to and stored in Google servers in the United States where they are used to compile web-use reports. Google may transfer this information to third parties, where required by law, or for information processing on its behalf. Google will not associate IP addresses with any other data held by Google. More information on Google’s privacy policy can be found at: https://www.google.com.au/intl/en/policies/privacy/. It is
possible to disable cookies by adjusting web-browser setting and to opt-out of Google Analytics (https://tools.google.com/dlpage/gaoptout). Doing so, however, may affect web-site functionality.
The ANIBT and AIEL web servers automatically log information such as server address, date and time of visit and web pages accessed. No personal information is recorded. These logs are used for website management and improvement.
UNSOLICITED PERSONAL INFORMATION
If ANIBT or AIEL should receive unsolicited personal information, it will be treated and managed according to the Australian Privacy Principles.
NOTIFICATION OF COLLECTION
ANIBT and AIEL aim to notify individuals of the collection of their personal information before, or at the time of collection, or as quickly as possible thereafter. Notifications are usually in writing, but may be verbal for telephone help-desk services, or research conducted by telephone interview. • Marketing – notification is provided on our website course application page. Individuals are also notified at the time of collecting personal information for events. A privacy notice is provided in all ANIBT and AIEL marketing communications.
• Quality Indicator surveys – this is a mandatory requirement for all Registered Training organisations and participants are informed of their invitation to participate via email along with a link to the survey.
• ANIBT and AIEL staff – Notification is provided on employment commencement.
DISCLOSURE OF PERSONAL INFORMATION
ANIBT and AIEL do not disclose personal information other than for the purpose for which it was collected, or an individual has consented to a secondary purpose, or an individual would reasonably expect this (such as receiving communications about upcoming events), or if required by law.
ANIBT and AIEL may share personal information with the Commonwealth government in accordance with Commonwealth contractual obligations. In these circumstances ANIBT and AIEL will take reasonable steps to inform and seek consent from the individuals concerned and take all reasonable steps to ensure that the recipient handles the personal information according to the APPs.
ANIBT and AIEL do not sell its lead lists to third-parties for marketing purposes.
ANIBT and AIEL do not disclose personal information to overseas recipients. While people around the world can access material published on our website, no statistical or research publications contain identifiable personal information.
MANAGEMENT OF PERSONAL INFORMATION
ANIBT and AIEL endeavour to ensure the personal information it collects and uses or discloses is accurate, up to date, complete and relevant. ANIBT and AIEL routinely updates the information held in its customer relationship management system. In addition to periodically checking with stakeholders if their personal contact details have changed.
ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Individuals may, subject to the exceptions prescribed by the Australian Privacy Principles, request access to and correction of their personal information where this is collected directly from individuals by ANIBT and AIEL.
ANIBT and AIEL do not charge for giving access to or for correcting personal information.
Requests for access to or correction of personal information should be made in writing. Requests will be answered within 14 business days.
INFORMATION RETENTION AND DISPOSAL
Personal information is held in electronic format:
• Information collected from learner enrolment applications and survey responses is held in databases.
• Names and contact details of stakeholders are held in the Student Management System and email contact lists.
• Names and contact details collected during the delivery of services may be held either in electronic form in ANIBT’s or AIEL’s document management system.
• Personal staff information is held in the HR management, pay roll database.
• Backup copies of all electronic files held in ANIBT’s or AIEL’s systems are kept in the event of system failure/loss. All backup copies of system files are secured.
ANIBT and AIEL retains personal information for 30 years. When personal information is no longer necessary for ANIBT’s and AIEL’s business functions, and it is lawful to do so, ANIBT and AIEL destroy the information.
INFORMATION SECURITY
ANIBT and AIEL take active steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
• ANIBT’s and AIEL’s systems and internal network are protected from unauthorised access using appropriate technologies. Most system data transferred over the internet is protected by Secure Socket Level protocol (SSL). The inherent risks associated with data transmission over the internet are, however, commonly acknowledged. Individuals, who do not wish to provide their personal information via the online website forms have the option of mailing this information to ANIBT or AIEL.
• Access to the Student Management System is protected through user log-on and password, and assignment of user access rights.
• Third-party providers used by ANIBT or AIEL for the delivery of services are required to be compliant with the Australian Privacy Principles and offer appropriate safeguards to protect personal information.
• ANIBT’s and AIEL’s premises and data storage systems are fully secured. ANIBT and AIEL practices clean-desk policy and locking workstations when working with personal information. Paper documents containing names and addresses are required to be locked away and shredded when destroyed. All hardware is properly ‘sanitised’ before disposal.
COMPLAINTS AND CONCERNS
Complaints or concerns about ANIBT’s management of personal information should be directed in writing to info@anibt.edu.au ANIBT will respond in writing within 14 business days.
Complaints or concerns about AIEL’s management of personal information should be directed in writing to enquiry@aiel.com.au AIEL will respond in writing within 14 business days.