TrainSmart Australia is a Registered Training Organisation and is bound by the National Privacy Principles contained in the Commonwealth Privacy Act 1988 and Australian Privacy Principles (2014). This policy outlines how TrainSmart 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. As part of our continuous improvement program, we will review and update this Policy to take account of new laws and technology, changes to our operations and practices and to ensure it remains appropriate to the changing education and training environment.
|Collection||Under the Data Provision Requirements 2012, TrainSmart Australia is required to collect personal information about you and to disclose that personal information to the National Centre for Vocational Education Research Ltd (NCVER).|
TrainSmart Australia will collect only the information necessary for one or more of its functions. The type of personal information collected will depend on the type of engagement an individual has with our organisation, and may include:
In the instance where an individual undertakes training via a government VET Student Loan the individual’s Tax File Number (TFN) is also collected at the time of enrolment. Once recorded according to strict protocol, the individual’s TFN data can be unlocked and viewed only by the Australian Taxation Office.
Additionally, for the purposes of VET-specific statistical data personal information is collected on whether an individual:
Commonwealth Government identifiers (e.g. Medicare number, TFN or Commonwealth Higher Education Student Support Number) will only be used for the purposes for which they were issued. TrainSmart Australia will first attempt to source unique identifiers directly from the students. Where the student does not know or have a USI, the student will be asked to provide authority to TrainSmart Australia to search for or create a USI on their behalf.
|Our method of collection of personal information||Information is collected by way of forms completed by the individual, interviews, telephone calls, face-to-face meetings, responses to surveys conducted by our organisation and employment applications. Personal information is collected only with the individual’s consent, and they will also be told the purposes for which the information is collected and used.|
TrainSmart Australia will amend the student profile to bring it up to date;
where inconsistencies are identified in the student data. (The student will be contacted to confirm the accuracy of their data); or, where the student contacts TrainSmart to provide new and correct details.
|Sensitive information||TrainSmart Australia will seek the consent of an individual when collecting sensitive information about their health, racial/ethnic background, or criminal record. Sensitive information may be collected only when it is necessary for purpose of looking after the individual’s educational well-being to ensure we discharge our duty of care.|
|Use and Disclosure||We will use personal information provided by an individual for the primary purpose of collection. This will generally include:|
As a Registered Training Organisation, TrainSmart Australia may also need to disclose an individual’s personal information to:
TrainSmart Australia does not disclose personal information other than for the purpose for which it was collected. Personal information will not be used or disclosed for a secondary purpose unless the individual has consented, or a prescribed exception applies. In circumstances where an individual has consented to receive communication for the purposes of direct marketing regarding theservices we offer, the individual can easily choose to opt out of receiving these communications by informing us directly or using the unsubscribe process.
Your personal information (including the personal information contained on enrolment form and your training activity data) may be used or disclosed by TrainSmart Australia for statistical, regulatory and research purposes. TrainSmart Australia may disclose your personal information for these purposes to third parties, including:
Personal information disclosed to NCVER may be used or disclosed for the following purposes:
You may receive an NCVER student survey which may be administered by an NCVER employee, agent or third-party contractor. You may opt out of the survey at the time of being contacted.
NCVER will collect, hold, use and disclose your personal information in accordance with the Privacy Act 1988 (Cth), the VET Data Policy and all NCVER policies and protocols (including those published on NCVER’s website at www.ncver.edu.au).
TrainSmart Australia does not sell its lead lists to third-parties for marketing purposes.
TrainSmart Australia does 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.
|Data Quality||TrainSmart Australia will take all reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date. Upon enrolment or employment with TrainSmart Australia, individuals are requested to advise management of any changes to their personal information by using the Confidential Records form.|
|Data Security||TrainSmart Australia will take all reasonable steps to protect the personal information it holds from misuse, loss, unauthorised access, modification or disclosure. Paper records are maintained in locked storage, and rights to computerised records are password protected. Backups of all electronic files held in TrainSmart Australia’s systems are kept in the event of system failure or loss. All backup copies of system files are secured.|
At such a time that an individual’s personal information is no longer needed, we will take steps to destroy the information or ensure that it is de-identified if retained.
|Openness||During the enrolment process, the Enrolment Administrator will explain the type of information we hold and for what purpose we collect, use and disclose the information.|
|Access||Individuals will be given access to their information held by contacting the enrolment officer at any time to obtain a Confidential Records form.|
In the exceptional circumstance that we are authorised by law to refuse an individual access to information (e.g. releasing the information may have an unreasonable impact on the privacy of other individuals), we will advise the individual of the reasons for our decision.
|Unique Identifiers||Commonwealth Government identifiers (e.g. Medicare number, TFN or Commonwealth Higher Education Student Support Number) will be used only for the purposes for which they were issued. TrainSmart Australia will not assign unique identifiers except where it is necessary to carry out its functions efficiently.|
The Australian Government requests from us certain encoded student information for statistical research purposes to be supplied to the National Centre for Vocational Education Research (NCVER). With the exception of the NCVER, no personal details identifying individuals is requested or will be divulged.
|Anonymity||Wherever possible, TrainSmart Australia will provide the opportunity for the individual to interact with them without identifying themselves.|
|Sensitive Information||TrainSmart Australia will seek the consent of the individual when collecting sensitive information about the individual such as health information, or information about the individual’s racial or ethnic background, or criminal record.|
|Complaints Process||If an individual has a complaint regarding the handling of their personal information by our organisation, they should contact the Compliance Manager in writing, by completing and submitting the Complaints and Appeals form. The Compliance Manager will then take the appropriate steps to respond to the complainant within a reasonable time frame and no later than 15 working days.|
For further details please refer to our Complaints and Appeals Policy and Procedure, available on our website.
This policy is made publicly available on the TrainSmart Australia website: www.tsa.edu.au. The Student Handbook also contains reference to this policy and all students are informed of privacy issues through the enrolment and induction processes.
All staff are informed of this policy during their induction process and the information is made available in writing within the Employee Handbook. All staff are responsible for observing the guidelines stated in this policy.
This policy is approved by the CEO of TrainSmart Australia (RTO Code 51771).
|2.1||May 2012||National Compliance Manager||Update process|
|2.2||January 2017||National RTO Manager||Replace SMR with TrainSmart Australia|
|2.3||August 2018||National RTO Manager||Update process|
|3||September 2018||National RTO Manager||Policy update|
|4||November 2018||CEO||Policy update|