Policy Statement
TrainSmart Australia is a Registered Training Organisation providing a range of nationally accredited Certificate and Diploma courses recognized by Australian employers, training organisations and universities. In providing these services, we collect, use and disclose personal information. Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable. TrainSmart Australia is bound by the National Privacy Principles contained in the Commonwealth Privacy Act 1988 and Australian Privacy Principles (2014) for the collection, use and storage of this information. 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. We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation, the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). 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.
POLICY DETAIL
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:
- The individual’s name, date of birth and gender;
- Citizenship status;
- Driver’s license and/or passport details;
- Contact details (address, email, phone);
- Prior education and qualifications;
- English language literacy and numeracy;
- Skills and career interests.
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:
- Is of Aboriginal or a Torres Strait Islander origin;
- Considers themselves to have a disability, impairment or long-term condition.
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.
To assist us in understanding your engagement with TrainSmart and to ensure the communication you have with TrainSmart is relevant we may also record your IP address and history of engagement with the TrainSmart website and documents accessed. To help us improve our services, we may collect your responses to surveys and details about how, when and why you access our services.
Our method of collection of personal information
We will collect personal information by lawful and fair means as required by the Privacy Act. We will also collect personal information directly from you where this is reasonable and practicable.
Information is collected directly from you 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.
Our method of collection of non-personal information
When you visit our website, some of the information that is collected about your visit is not personal information, because it does not reveal your identity. We use this information to help us improve our services. We may aggregate this information for our own statistical purposes. Provided that it remains anonymous, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
Site visit information
We may record your server address, the date, time and duration of your visit, search terms you used, the pages you viewed, any documents you downloaded and the type of device, browser and operating system you used.
Cookies
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users. We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our websites.
We may remarket your information. Remarketing is a way for us to connect with users, based upon your past interactions with the Upskilled website. Third-party marketing vendors may be hired by TrainSmart to perform remarketing services. As a result, third party vendors, including Google, may show TrainSmart ads on sites on the internet. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to TrainSmart’s website.
To opt out of customized Google Display Network ads click here. To find out more about how Google uses any data it collects please visit http://www.google.com/privacy_ads.html. Any information collected is used only for remarketing purposes and will not be used by them for any other purpose.
Use and Disclosure
We will use personal information provided by an individual for the primary purpose of collection. This will generally include:
- Verification of the individual’s identity;
- Administration in regard to enrolment records and payment for services;
- Relevant information provided to our Trainers, Assessors and administrative support staff for the purpose of looking after the individual’s educational well-being to ensure we discharge our duty of care.
As a Registered Training Organisation, TrainSmart Australia may also need to disclose an individual’s personal information to:
- Our registering body (ASQA);
- State Training Departments for the purpose of AVETMISS reporting, relevant to our contractual obligations;
- The Commonwealth and tuition assurance scheme operators.
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 the services 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:
- School – if you are a secondary student undertaking VET, including a school-based apprenticeship or traineeship;
- Employer – if you are enrolled in training paid by your employer;
- Commonwealth and State or Territory government departments and authorised agencies;
- Financial Institutions;
- Third party debt collection agencies
- NCVER;
- The Police, where an alleged breach of the Student Code of Conduct may involve criminal behaviour
- Our contracted Trainers, assessors and tutors;
- Information technology service providers (including cloud services providers);
- Organisations conducting student surveys; and
Personal information that has been disclosed to NCVER may be used or disclosed by NCVER for the following purposes:
- Issuing statements of attainment or qualification, and populating authenticated VETtranscripts;
- facilitating statistics and research relating to education, including surveys and data linkage;
- pre-populating RTO student enrolment forms;
- understanding how the VET market operates, for policy, workforce planning and consumer information; and
- administering VET, including program administration, regulation, monitoring and evaluation.
You may receive a student survey which may be administered by a government department or NCVER employee, agent or third party contractor or other authorised agencies. Please note 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 National VET Data Policy and all NCVER policies and protocols (including those published on NCVER’s website at www.ncver.edu.au).
For more information about NCVER’s Privacy Policy go to https://www.ncver.edu.au/privacy
Where TrainSmart Australia have your express or implied consent, or where we are otherwise permitted by law, we may use your personal information to send you information about the services we offer, as well as other information. We may send this information by mail, email, SMS and telephone. You can opt out of receiving these communications at any time by contacting us directly or by using the unsubscribe facility that we include in our commercial electronic messages.
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.
If you post comments or otherwise communicate publicly with other users via our website, any information about yourself that you include in the communication may be stored on the website and accessed by other users. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you.
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.
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, which is 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).
Further Information:
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for privacy queries are set out below.
Privacy Officer
TrainSmart Australia
Mail: Level 12, 251 Adelaide Terrace, Perth WA 6000
Email: [email protected]
Telephone: 1300 855 517
Version
Date
Reviewed By
Amendments
2.1
May 2012
National Compliance Manager
Updated 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
5
August 2019
Executive Officer
Policy Update
6
August 2019
National RTO Operations Manager
Policy Update
