Privacy Policy for Edmund Barton College

Effective from and last updated: 30th December 2019.
Edmund Barton College of Business Education is a trading name for Edmund Barton College Pty Ltd. As such, references to Edmund Barton College Pty Ltd in this Privacy Policy can be considered to mean Edmund Barton College of Business Education.

Introduction

Edmund Barton College and its associated companies ("us", "we", or "our") provides access to online tertiary education and related services and operates via the https://www.edmundbartoncollege.edu.au website (the "Service").
We are required to comply with the 13 Australian Privacy Principles (APPs) for organisations from 12 March 2014. Section references throughout this document may refer to the Privacy Act 1988 (Cth) unless otherwise noted.
Edmund Barton College gathers general and sensitive personal information, stores this information, shares this information with other organisations, aligns information to government identifiers and reports on personal information. This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. It also tells you how you can ask to access and correct the personal information we hold about you or complain about a suspected privacy breach.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Consent
Consent’ is defined as express consent or implied consent. By agreeing to our Terms & Conditions, you also agree to our Privacy Policy.

What types of information do we collect?
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Information"). Personally identifiable information may include, but is not limited to Email address, Mobile phone number, First name and last name, Cookies and Usage Data.
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may use your Personal Data to contact you regarding important information that could impact your usage of Edmund Barton College and its related services (Critical Updates). Due to the nature of the Critical Updates, it is not possible to opt-out of these communications.
Under the Data Provision Requirements 2012, Edmund Barton College is required to collect personal information about you and to disclose that personal information to the National Centre for Vocational Education Research Ltd (NCVER).
Your personal information (including the personal information contained on this enrolment form), may be used or disclosed by Edmund Barton College for statistical, administrative, regulatory and research purposes. Edmund Barton College may disclose your personal information for these purposes to:

  • Commonwealth and State or Territory government departments and authorised agencies; and
  • NCVER.

Personal information that has been disclosed to NCVER may be used or disclosed by NCVER for the following purposes:

  • populating authenticated VET transcripts;
  • 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.

How do we collect 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*.
We collect personal information in a number of ways, including:

  • directly from you in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on our websites;
  • from third parties, including other education providers, direct marketing database providers, government agencies, our related companies and your authorised representatives;
  • from our own records of your use of our services.

*Edmund Barton College Pty Ltd must collect personal information about an individual only from the individual, unless it is ‘unreasonable or impracticable’ for the RTO to collect personal information only from the individual. Contact us about these exceptions.

Collection notices
Where we collect personal information directly from you, we will take reasonable steps to notify you of certain matters in a collection notice. We will do this at or before the time of collection, or as soon as practicable afterwards.
Where we collect information about you on behalf of the Australian Government, the collection notice may explain how the Australian Government will use and disclose your personal information. You should note that the Australian Government may use and disclose your personal information in ways that are different from how we use and disclose your personal information.
Where we collect information about you from your authorised representative, we will take reasonable steps to make sure that you are made aware of the collection.
If you provide to us personal information about someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.

Personal Information
The type of personal information that we collect and hold about you depends on the type of dealings that you have with us.

  • In order to access our free unit(s) for trial, then we need to collect your email address, phone number and full name. The information for this service alone can be provided as anonymous, or you can use a pseudonym.
  • Once enrolled in a fee-paying unit or course with Edmund Barton College Pty Ltd, we are required by law to deal with authentically identified individuals only.
  • If we need to identify you or verify your identity, we may collect your name, gender, date of birth, driver’s licence and/or passport details, student ID number, username, password, security question and answer.
  • If we need to communicate with you, we may collect your email, residential and postal addresses and telephone numbers. If you apply to enrol in a unit of study or full qualification or otherwise access our services, we may collect and hold details of your educational qualifications, full enrolment details as required by ASQA and NCVER, academic results, banking and payment details.
  • To help us improve our services, we may collect your responses to surveys and details about how, when and why you access our services.

Unsolicited Information
Any information that is sent to Edmund Barton College Pty Ltd on an unsolicited basis (e.g., you apply to us for a job) may be retained for an indefinite period of time, as long as that information is potentially useful to the business.
Any unsolicited information that Edmund Barton College Pty Ltd receives will be destroyed or de-identified once Edmund Barton College Pty Ltd no longer needs the information.

Sensitive information
Sensitive information is personal information such as health information and information about racial or ethnic origin that is generally afforded a higher level of privacy protection.
In order to comply with our obligations under Australian law, we may request, collect and retain sensitive information on behalf of the Australian Government, including your language background, citizenship status, status as an indigenous Australian, disability status and health information.
We only collect sensitive information where it is reasonably necessary for our business functions and you have consented, or we are required to do so by law. Edmund Barton College Pty Ltd may collect sensitive information if the collection is required or authorised by or under an Australian law. For example, but not limited to, AVETMISS data collection via NCVER. As such, Edmund Barton College Pty Ltd may collect information but the information will not be used for a secondary purpose unless an exception applies, and the security of the information will be protected, and an individual can apply for access to the information and to correct any inaccuracy in the information.

Usage Data
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.
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.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Why do we collect, hold, use and disclose your personal information?

General
Edmund Barton College Pty Ltd only collects personal information that is reasonably necessary for our business activities.
The main purposes for which we collect, hold, use and disclose personal information are:

  • to identify you and verify your identity.
  • to communicate with you about our services.
  • to provide our services to you, including obtaining payment for our services.
  • for purposes required or authorised by or under law (for example, for statistical purposes for ASQA and/or NCVER)
    to help us improve our services;
  • for any other purposes that you have consented to.

Direct marketing
Where we 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 may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. You can also opt out of receiving these communications at any time by contacting us via telephone or in writing.

Use of Data
Edmund Barton College Pty Ltd uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • To personalise your experience to your individual needs
  • For research into learning and/or teaching and/or on-line engagement

To whom do we disclose your personal information?
We may disclose your personal information to any of the organisations that we deal with in the ordinary administration of our business for the purposes, including:

  • the Australian Government and its agencies;
    Financial institutions
  • Our contracted service providers, including:
    • other RTO education providers;
    • information technology service providers (including cloud services providers);
    • marketing, communications and research agencies;
    • mailing houses, postal, freight and courier service providers;
    • printers and distributors of direct marketing material;
    • external business advisers (such as recruitment advisers, auditors and lawyers).
    • debt collecting agencies

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you.
We may de-identify and aggregate the personal information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.
If you apply for a job with us, we may discuss your application with your nominated referees.
If you have an online account via our website, you can access and change your privacy settings by logging in to your account and following the instructions on our website. Depending on the privacy settings that you chose, some of the personal information in your user profile may be disclosed to other users.
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.

Retention of Data
Edmund Barton College Pty Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Personal information is stored by a contracted third-party data storage provider. We will retain and use your Personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Edmund Barton College Pty Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Edmund Barton College Pty Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Business Transaction
If Edmund Barton College Pty Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement
Under certain circumstances, Edmund Barton College Pty Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements
Edmund Barton College Pty Ltd may disclose your Personal Data in good faith if it believes that such action is necessary under these circumstances:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Edmund Barton College Pty Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data
We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
Your private financial information (credit cards, social security numbers, financials, etc.) may not be stored on our servers.
The security of your data is important to us; however, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. The list of third-party providers below is not extensive, and we may use other third parties from time to time.

Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.
• Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Advertising
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
• Google AdSense & DoubleClick Cookie
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Behavioural Remarketing
Open Learning Global Pty Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Twitter
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook by using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Payments
We provide paid educational services within the Service. If you choose to enrol, we use third-party services for payment processing (e.g. payment processors) and/or EFTPOS and online technologies.
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

Cross border disclosure of personal information
It is our current policy not to disclose personal information to third parties located overseas.
If we change our policy at some time in the future, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information and this Privacy Policy will be amended accordingly. That is, if Edmund Barton College Pty Ltd discloses personal information about an individual to any overseas recipient, we undertake to take reasonable steps to ensure that the recipient does not breach any privacy matters in relation to that information.

Data quality and security
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in secure premises. Paper files may also be archived offsite in secure facilities. We take reasonable steps to:

  • make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
  • protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure;
  • destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.

Website security
Your data is protected via one or more of these security features;

  • Fortinet Hardware Firewall
  • Continuous protection that inspects every packet before it reaches your hosting server.
  • SSL Certificates issued by Comodo and automatically installed by cPanel.
  • Acronis Hourly Backups
  • Your data will be backed up by Acronis Cloud Backup and will be available to restore at any time.
  • Secure Hosting Environment
  • We use CageFS, CXS, LFD, CSF and dynamic mod_security rules to keep our website secure
  • Wordfence plugin with web application firewall

While we strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone.
You can also help to protect the privacy of your personal information by maintaining the confidentiality of your account (including your password), and by ensuring that you log out of your account on our website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.

How can you access and correct your personal information?

You can request access to the personal information that we hold about you and request corrections by contacting our Privacy Officer (see section 10 below).
If you have an online account via our website, you can access and change some of your personal information by logging in to your account and following the instructions on our website.

Complaints

Edmund Barton College Pty Ltd welcomes your complaints. While we try everything to provide a wonderful experience to you, we know that we are not perfect, and we see your complaints as opportunities to improve our service to you. So, please do let us know your complaint. You can do this by following these steps.
If you have a complaint about how we have handled your personal information, please contact us (details are below).

  • Our Customer Experience Team will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.
  • If your complaint can't be resolved at first instance, you can escalate your complaints to the CEO in writing.
  • We will endeavour to acknowledge receipt of your complaint within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner.
  • In most cases, we expect that complaints will be investigated, and a response provided within 30 days of receipt of your written complaint. If our investigation may take longer, we will let you know.
  • If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).
  • You have a right to put forward your complaint anonymously or by using a pseudonym if your complaint is of a general nature.
  • We may be required to refer complaints about breaches of privacy to the relevant Commonwealth Department.

Accessing and seeking correction of personal information

Individuals have a right to request access to their personal information and to request its correction, free of charge.

You can request access to and correct personal information by contacting us via the details set out below.

We will endeavour to respond to your request within 5 business days.

Duration of time your information will be kept by Edmund Barton College Pty Ltd

We will only keep your information for as long as it is required by ASQA or other relevant government departments, including NCVER. Once this time limit has expired, your information will be de-identified or deleted. This excludes information that has been sent to Edmund Barton College Pty Ltd on an unsolicited basis.

Changing your information that is inaccurate

Edmund Barton College Pty Ltd will take reasonable steps to ensure that the personal information it uses and discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.

If it comes to the attention of an Edmund Barton College Pty Ltd employee or contractor that the information you have provided to us is not accurate (i.e. the name you have given us is not the exact name as on your birth certificate or passport) then we are obliged to make the change to the correct version. We will also advise other parties who may have an interest in your studying with Edmund Barton College Pty Ltd.

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
Edmund Barton College
Mail: GPO Box 1142, NORTH SYDNEY, NSW, 2059
Email: [email protected]
Phone: (02) 9135 2966

Changes to this Policy
We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained from Edmund Barton College.