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Privacy and Confidentiality

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*Included in the student enrolment declaration. As part of the enrolment procedure, students have already provided permission for Strategix to collect and distribute information to parties directly involved in their training and assessment.

These organisations may access students' information free of charge and distribute it without any further permission from the student.

Where the student is no longer engaged with the service, department or employer; permission must be obtained from the student.

Policy:

Strategix Training Group (Strategix) ensures the best practice with regard to the collection; handling and maintenance; storage; and access, release and destruction of personal information. Strategix is bound by and complies with the Privacy Act 1988 (Cth), and the Australian Privacy Principles (APPs) as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

Privacy Statement

Your privacy is important to us. Any personal information collected from you is kept secure and confidential. It is important that we have current contact details if you are attending classes and activities. Please contact the office if you need to update your details. All participants have the right to access their personal records. Where you attend publicly funded courses and/or accredited courses, we have a responsibility to record and report your details and related information to the relevant government departments (e.g. Department of Education and Small Business Training (DESBT), Australian Government – Department of Home Affairs). This reporting is used for proof of attendance and results in compliance with national standards. Other than for reporting purposes, your personal information will not be passed onto any third party without your written consent. It is your right not to give us your full personal details, on the understanding that you may not be entitled to the full services provided with our accredited training. Your information is kept secure in our archives for reporting purposes and current information is used only by Strategix Training Group in our operations of providing you with appropriate, quality services.

Privacy

Privacy is the control you have over the extent, timing, and circumstances of sharing oneself (physically, behaviourally, or intellectually) with others.

What information does Strategix collect?

For students wishing to undertake a VET accredit course, the personal information which is stipulated for Strategix to obtain can be found on the following regulatory authority’s websites/information sheets:

Commonwealth and State or Territory government departments and authorised agencies

Australian Skills Quality Authority (ASQA)

National Centre for Vocational Education Research Ltd (NCVER)

The Student Identifiers Registrar

Australia Government – Department Home Affairs

Employees at Strategix need to supply personal information relevant to employment and their job role. This information includes, but is not limited to:

• Employee, referee and emergency contact details

• Applications for employment and supporting documents (Resume etc.)

• Employment contracts, and other records relating to terms and conditions of employment

• Superannuation details and contributions

• Qualifications and certificates

• Medical and health related information

• Taxation details

• Identification documents

How does Strategix collect information?

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Provided by

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How Provided

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Student Information

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Student

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Phone

In person

Email

Via Strategix website

Recognition of Prior Learning (RPL) Kit

Enrolment Form

Identity Document (e.g. Drivers Licence, Medicare Card)

Vocational Placement Agreement

Police Check

Working with Children Check

Student Surveys

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The Department of Education and Small Business Training (QLD funded students)

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Apprenticeships Info Self Service (AISS check)

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Australian Apprenticeship Support Network (Apprentices)

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Supervising Registered Training Organisation (SRTO) Notification

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Community Organisation

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Funding Approval Letter

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Workplace (existing worker students)

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Training Plan

Employer Resource Agreement

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Debitsuccess (students on a payment plan)

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Information on the Debitsuccess portal which is shared with Strategix:

Transactions

Scheduled Payments

Debitsuccess Call History with student

Contract and details entered/completed

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International Education Agents

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Email

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Tuition Protection Service

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Email

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School (VET in School)

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Student Letter/s

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Employee and/or Contractor’s Information

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Employee or Contractor

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Seek.com.au

Email

Resume

FORM 14.001 - New Staff Form

FORM 14.011 - Human Resources Information Sheet (HRIS)

FORM 14.033 - Application for employment

Qualification/s

Superannuation Choice Form

Tax File Number Declaration Form

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Current/Previous Employer

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Employee’s performance information

What if I don’t wish to provide personal information?
Students – Generally, with the exception of nationally recognised training, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with the products and services that depend on the collection of your information.

Where a student does not wish their personal data and details reported to the third parties listed, they must first apply for an exemption from NCVER and supply a letter verifying their approval. They must then contact the individual State Education Authority and verify the requirements for any funding.

Employees – Information is collected relevant to your job roll and employment. If you choose to withhold personal information, you may not meet employment requirements and therefore, not be able to be employed at Strategix or complete your role.

Monitoring and Surveillance

CCTV

For security purposes and the protection of staff and or students, some of Strategix’ locations may have CCTV. Signage is displayed if this applies in your location, this is usually displayed prior to entering the premises.

Phone Calls

In some instances phone calls with Strategix may be recorded, you will be informed at the beginning of your call if your call is to be recorded or monitored. This is so you have the option of either ending the call or asking to be transferred to another line where monitoring or recording does not take place, if this is available.

Reasons why we monitor or record conversations could include:

• To protect you in your dealings with the Strategix

• To provide a record in the event of a dispute about a transaction

• To improve customer service and for staff training.

Employees – For details around monitoring and surveillance of staff please refer to Strategix Employee Handbook and Employee Induction.

Confidentiality

Confidentiality pertains to the treatment of information that an individual has disclosed in a relationship of trust and with the expectation that it will not be divulged to others without permission, in ways that are inconsistent with the understanding of the original disclosure.

Strategix maintains confidentiality at all times. No personal details, addresses or phone numbers of students, tutors or staff are given out to the general public. Information is only collected where necessary to carry out the functions of the organisation.

What is the purpose for collecting my information and how will it be used?

Strategix only obtains information relevant to the nature of the request and and/or as stipulated by governing and regulatory authorities. Your personal information will be used in accordance with APP 6.

Students – If you wish to undertake a Vocational Education and Training (VET) accredited course, you are required to provide specific personal information to your chosen VET approved training provider in order to undertake the training. While maintaining compliance with Privacy Act requirements, Strategix has additional regulatory requirements for the collection and use of information, outlined by:

Commonwealth and State or Territory government departments and authorised agencies

Australian Skills Quality Authority (ASQA)

National Centre for Vocational Education Research Ltd (NCVER)

The Student Identifiers Registrar

Australia Government – Department Home Affairs

In addition to meeting the requirements mentioned above, Strategix collects your information for the following reasons:

Identifying you

Processing your enrolment

Issuing invoices and processing payments

Determining funding eligibility

Making contact with you

Providing services to you

Sending system generated notifications to you

Issuing you with your VET accredited certificate or statement of attainment

Updating and keeping our records

Submitting data to and meeting requirements of regulating authorities

Complying with any Australian law, orders of courts or tribunals or, in co-operation with any government authority of any country

• Marketing analysis

• Strategic company planning

• Auditing purposes.

Employees – Strategix employees are required to provide Strategix with appropriate information relating to their general employment requirements and the role in which they are applying. This enables Strategix to:

Identify and contact the appropriate candidate

Determine suitability for their role

Process and complete the employment process

Maintain their employment.

Who will have access to my information?

Students – Strategix may disclose your personal information for these purposes to relevant third parties, including:

• School – if you are a secondary student undertaking VET, including a school-based traineeship

• Employer – if you are enrolled in training paid by your employer

• Commonwealth and State government departments and agencies

• VET-related bodies

• The National Centre for Vocational Education Research

• The Student Identifiers Registrar – All Students conducting VET courses

• Australia Department Home Affairs – International Students

• International Education Agents – International Students

• Authorised organisations conducting student surveys and researchers

• Financial Auditors – May view only, during a financial audit

• Any organisation for any reason that you agree to.

Employees – Staff HR information is stored on MyStaffInfo and may be disclosed to Strategix’ chosen HR consultant, chartered accountant and financial auditor. Staff can find additional information in the Privacy Policy section located in the Employee handbook.

Under 18 years of age

• Students over 18 years of age – information will not be released without prior consent from the student except in extraordinary circumstances

• Students under 18 years of age – privacy laws give the student the right to consent to disclosure without parental consent and information will not be released without prior consent from the student except in extraordinary circumstances

• Where a student has an Intellectual Disability and is unable to judge the consequences of disclosure the guardian or parental consent will be obtained prior to information release

How does Strategix keep my information secure?

Strategix ensures your personal information is kept confidential and avoids misuse, loss, unauthorised access, inaccurate modification and unauthorised disclosure through the following:

• Information on the Student Management System has restricted user access

• Records containing personal information are kept in secure databases, and/or filing cabinets, in locked offices after hours

• Persons requesting access to their information may only be given access to their own information

• Personal information is only disclosed where necessary to carry out the service and is not to be given out to any other party (without written consent)

• During office hours records will be kept out of public view and removed from desks when not in use

• Computer screens will be kept out of public view

• Access to computer files is assigned according to job function

• Personal information is only photocopied or printed when essential

• Emails containing personal information will only be sent to approved individuals or regulatory authorities

• Identification information and/or documents no longer needed will be disposed of securely

• Media consent forms are to be signed by individuals (and their parents, if under age) before an image of themselves or their work can appear on Strategix’ publications or on websites

• All staff are made aware of privacy laws and compliance requirements

• All individuals who have given personal information to Strategix must be advised of availability and location of this Privacy Policy

• Secure bank payment gateways are used for student payments made via phone and/or internet

• Staff HR information is held on local servers and MyStaffInfo, both of which require user and password access.

Marketing

Strategix does not sell your personal information for any purpose, including marketing. Strategix may use your information for internal marketing and analysis. If you do not wish to receive marketing materials you can contact Strategix and request to opt out of our marketing or you can unsubscribe from our marketing emails when you receive them. Refer to the Student Handbook for more information on marketing. Please inform Strategix if you are listed on the official Do Not Call Register.

If you are enrolled in and completing a VET accredit course, Strategix is required to disclose your personal information to the regulatory authorities mentioned previously. Below is a link to their Privacy Policies which contains information about the use of your personal information, including their marketing practices.

• Australian Skills Quality Authority (ASQA)

• National Centre for Vocational Education Research Ltd (NCVER)

• The Student Identifiers Registrar

• Australia Government – Department Home Affairs

Strategix’ enrolment forms contain information around the disclosure and use of your personal information by the regulatory authorities. It also contains a declaration for students to agree to the sharing of their information with the regulatory authorities.

How do I access my information?

Students – If you require access to your personal information you can contact Strategix via:

• Website: Request Access to Student Information (Form)

• Email: enquiries@strategix.edu.au

• Phone: 1300 872 464

• Visit us: 3946 Pacific Highway, Loganholme QLD 4129

Full details about how to request student information and any associated costs (where applicable) are located in Strategix’ Student Information Release Policy and Procedure.

Employees – Access information through MyStaffInfo and request staff files through their manager.

Can access to my personal information be declined?

As per the APP 12.3, Strategix is not required to give the individual access to the personal information to the extent that:

1. Strategix reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety

2. Giving access would have an unreasonable impact on the privacy of other individuals

3. The request for access is frivolous or vexatious

4. The information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings

5. Giving access would reveal the intentions of the entity in relation to negotiations with the individual in such a way as to prejudice those negotiations

6. Giving access would be unlawful

7. Denying access is required or authorised by or under an Australian law or a court/tribunal order

8. Both of the following apply:

   1. the entity has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to the entity's functions or activities have been, is being or may be engaged in;

   2. giving access would be likely to prejudice the taking of appropriate action in relation to the matter

9. Giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body

10. Giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.

If Strategix refuses to give access to personal information because of APP subclause 12.3, or to give access in the manner requested by the individual, Strategix will give the individual a written notice that sets out:

1. The reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so

2. The mechanisms available to complain about the refusal

3. Any other matter prescribed by the regulations.

If the Strategix refuses to give access to the personal information because of paragraph 12.3(j), the reasons for the refusal may include an explanation for the commercially sensitive decision.

How do I correct or update my information?

As a current student, staff member or contractor you must ensure the personal information Strategix holds is kept correct and current. In some situations, international students may receive a notice of intention to report for visa breaches if they do not notify Strategix of changes to personal details. The APP states, if:

1. an APP entity (Strategix) holds personal information about an individual; and

2. either:

   1. the entity (Strategix) is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading; or

   2. the individual requests the entity (Strategix) to correct the information;

3. the entity (Strategix) must take such steps (if any) as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

Students can update their personal information via:

• Email: enquiries@strategix.edu.au

• Phone: 1300 872 464

• Visit us: 3946 Pacific Highway, Loganholme QLD 4129

When processing requests for information, Strategix:

• Ensures, through confirmation of identity that the request is made by the individual concerned, or by another person who is authorised to make a request on their behalf. Challenge questions will be asked prior to any personal information being divulged

• Responds to a request for access:

  • Within 14 calendar days when notifying our refusal to give access, including providing reasons for refusal in writing, and the complaint mechanisms available to the individual; or

  • Within 30 calendar days, by giving access to the personal information that is requested and in the manner in which it was requested.

Employees – Must ensure they maintain their personal information which is on MyStaffInfo and inform your manager of any changes to your personal information. You must ensure your personal information which is held by Strategix is accurate, up to date, complete, relevant and not misleading.

Disclosure of personal information to overseas recipients

International Student’s information may be disclosed to the following recipients overseas:

International Education Agents (if/where applicable)

The countries in which such recipients are likely to be located are:

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China

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Japan

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Korea

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Hong Kong

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Indonesia

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Philippines

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Vietnam

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Malaysia

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Brazil

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Mexico

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Colombia

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Venezuela

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Chile

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USA

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Mongolia

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Tibet

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India

What to do if you think your privacy was breached

If you think we have breached your privacy, please tell us about the problem so that we can investigate it.

Strategix has policies and procedures in place to work through complaints, these can be accessed and used when needed by staff and students:

• Student Complaints and Appeals Policy and Procedure

• Staff Complaints Grievance Policy and Procedure

Data Breaches through unauthorised access

A data breach is an unauthorised access or disclosure of personal information, or loss of personal information. In the unlikely event of an occurrence data breach, Strategix has a data breach response plan to ensure fast and effective action is taken to reduce the impact and limit any negative consequences. If the data breach is likely to result in serious harm to one or more individuals, Strategix will inform all relevant parties and individuals involved.

Related Documents:

Records Management Policy and Procedure

Strategix Quality Management System

Confidentiality Policy

Communications Procedure

Strategix Data Breach Response Plan

Students - Complaints and Appeals Policy and Procedure

Staff - Complaints Grievance Policy and Procedure

Student Information Release Policy and Procedure

Request Access to Student Information (Form)

Student Handbook

Employee Handbook

NCVER Privacy Notice

USI Privacy Notice

Glossary:

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Term/Statement

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Explanation

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Australian Privacy Principles (APPs)

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The Australian Privacy Principles (APPs), which are contained in schedule 1 of the Privacy Act 1988 (Privacy Act), outline how most Australian and Norfolk Island Government agencies, all private sector and not-for-profit organisations with an annual turnover of more than $3 million, all private health service providers and some small businesses (collectively called ‘APP entities’) must handle, use and manage personal information.

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Australian Skills Quality Authority (ASQA)

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The Australian Skills Quality Authority (ASQA) is the national regulator for Australia's vocational education and training sector. ASQA regulates courses and training providers to ensure nationally approved quality standards are met.

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National Centre for Vocational Education Research Ltd (NCVER)

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The National Centre for Vocational Education Research is an Australian non-profit owned by the Commonwealth and state and territory ministers responsible for vocational education and training.

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The Student Identifiers Registrar

The Student Identifiers Registrar is a Commonwealth statutory office established by the Student Identifiers Act 2014 and is responsible for administering the USI initiative nationally. The Registrar is appointed by the Commonwealth Skills Minister in consultation with the ministers responsible for skills in states and territories. Jason Coutts is the Student Identifiers Registrar

The USI Office located in the Federal Department of Education and Training assists the Registrar. The USI Office manages the USI Registry System which creates and stores the USIs.

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Australian Government Department Home Affairs

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The Department of Home Affairs is the Australian Government interior ministry with responsibilities for national security, law enforcement, emergency management, border control, immigration, refugees, citizenship, and multicultural affairs.

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Debitsuccess

Used by Strategix to provide students with access to flexible payment plans to suit their individual education journey.

Debitsuccess manages the payment plans, this involves processing all billing files, handling any student billing enquiries and following up any failed payments on behalf of Strategix.

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International Education Agent

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