Privacy and personal information policy and procedure
Purpose of the policy
This policy describes the practices and procedures by which Allara will ensure the compliance with the relevant privacy legislation to protect the personal information and right to privacy of those who are detailed within this policy.
Definitions
Allara – Allara Investments Pty Ltd, trading as Allara learning and is inclusive of; Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG) and W G learning Pty Ltd, RTO Provider No: 91178 (WGL).
TTG - Tactical Training Group Pty Ltd, RTO provider No: 91054 (TTG)
WGL– W G learning Pty Ltd, RTO Provider No: 91178 (WGL)
Scope
The policy applies to all participants, clients, staff and stakeholders of Allara Learning (Allara) inclusive of those seeking to be enrolled with TTG and WGL.
Policy
Allara will ensure that it respects the privacy of staff, prospective staff, participants, prospective participants and employers by implementing the National Privacy Principles.
The Privacy Act 1988 and Australian Privacy Principles Guidelines set out how private sector organisations should collect, use, keep secure and disclose personal information. The principles give individuals a right to know what information an organisation holds about them and a right to correct that information if it is wrong.
Allara will ensure it operates consistently with the Privacy Act and only collects the personal information that is necessary for the conduct of its business, and that it will use that information in the manner for which it was intended.
Purpose of collecting information
The purposes for which Allara collects personal information of participants include satisfying legal obligations, administration, to keep employers informed of the participant’s progress during study, and to allow Allara to discharge its duty of care.
The purposes for which Allara collects personal information of job applicants, staff members and contractors include satisfying legal obligations, insurance purposes, and administering the individual’s contract of employment.
Release of information
Allara must have the participant’s permission in writing with reference to release of information. This is primarily collected via declaration upon enrolment. Additional permission shall be sought as required.
Allara is required to ask for the staff member’s permission in writing with reference to release of information; this is included in the staff employment agreement, which must be signed prior to employment.
Information collected
Allara collects personal information solely for the purpose of its subsidiary companies TTG and WGL operating as a Registered Training Organisation under the VET Quality Framework administered by the Australian Skills Quality Authority who is the National VET Regulator (NVR). The requirements of the NVR may mean the release of participants’ or staff members’ personal information for the purposes of an audit.
The type of information Allara collects and holds includes (but is not limited to) personal information, including sensitive information. This may be, participants and parents and/or guardians before, during and after the course of a participant’s enrolment, job applicants, staff members and contractors, and other people that come into contact with Allara.
The information media may take the form of interviews, feedback surveys, email correspondence, telephone calls, third party information, and application forms.
Data will be uploaded to Allara’s Student Management System (SMS) and/or Learning Management System (LMS).
Provision of information
Participant, client or staff information will not be provided to anyone unless Allara has the permission from the participant or staff member or is specifically required to provide the information by law. For example, participant information is only given to the following bodies where required:
- ASQA (Australian Skills Quality Authority)
- STA (State Training Authorities)
- Employers, where the participant is a registered trainee or apprentice.
While participants are undertaking the training program, there will be times when Allara and/or its Training facilitators, Client Relations Manager, Administration Officer or other members of staff may need to discuss the participant’s program with internal RTO staff and the National VET Regulator (ASQA) and the participant’s employer.
Access to information
Under the Australian Privacy Principles, the participant, client or staff member can access his/her personal information and may correct inaccurate or outdated information about them.
Participants and clients
Participants and clients will have access to all information held on them. Allara will store and use the information appropriately and limit access to only those who have a legal reason to have access to that information, or whom the participant or client has given permission.
Participants and clients who request access to their information will be given full access to the details they want. No cost will be charged for them accessing their information whilst they are enrolled participants.
To access records, participants and clients must submit the appropriate form to the National General Manager. The appropriate form is titled “Records access request form” and may be requested from the Administration department.
For access to records, the participant or client must meet with the National General Manager and provide identification (such as license, passport) and the completed form.
Staff
Staff will have access to all information we hold on them, and we will store and use the information appropriately and limit access to only those who have a legal reason to have access to that information, or whom the staff member has given permission.
Staff members who request access to their information will be given full access to the details they want. No cost will be charged for them accessing their information whilst they are employed by Allara. If the person is no longer an employee of Allara and they request access of information, there may be a fee involved, which must be paid in advance of access.
Australian Privacy Principles
Allara abides by the Australian Privacy Principles (AAP’s) and will not pass on participants’ or other staff members’ information to anyone in any way that may be considered as breaching the Privacy Principles.
The Australian Privacy Principles fact sheet can be viewed and downloaded from: