Seymour College Privacy Policy

1. Context
Pursuant to The Privacy Act 1988 & Privacy Amendment (Enhancing Privacy Protection) Act 2012, Seymour College is required to have a privacy policy which is available to all of our Community. These laws regulate the way organisations can collect, use, keep and disclose personal information. Seymour College will handle personal information in accordance with the legislation. The College may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the College’s operations and practices and to make sure it remains appropriate to the changing environment.

2. Application
This policy applies to all employees, students, staff, volunteers, parents/guardians, Old Scholars (hereinafter collectively referred to as ‘Community’) contractors including international agents and visitors and other people who are associated with or come in contact with Seymour College.

3. Personal information
The College collects personal information from students, parents and guardians in the course of a student’s enrolment and after their enrolment. Other details are collected through interaction with members of the wider College Community. The College will advise its Community why, when and how it collects information. The School collects personal information arising from emails or from visitors to the School’s website. It may also acquire information from agents or service providers or from other public sources, published information or publicly available documentation. In some circumstances the College may be provided with personal information about an individual from a third party, for example, a report provided by a medical practitioner, an educational professional or authority, or a student’s record from another school.

4. Definitions
4.1. Personal Information: means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

Sensitive Information is a subset of personal information: the College may collect personal information which is “sensitive information”. Such information includes but is not limited to information or an opinion (that is also personal information) about an individual’s:
4.1.1. racial or ethnic origin
4.1.2. political opinions
4.1.3. membership of a political association
4.1.4. religious beliefs or affiliations
4.1.5. philosophical beliefs
4.1.6. membership of a professional or trade association
4.1.7. membership of a trade union
4.1.8. sexual orientation or practices
4.1.9. criminal record
4.1.10. financial information
4.1.11. health information about an individual

In relation to sensitive information, Seymour College will only collect that information with the consent of the individual to whom the information relates or as otherwise permitted by the Privacy Act or at law.

If a third party provides personal information to us without us asking which is also sensitive information, Seymour College will take steps to verify the relevant individual’s consent to collect that information.

5. Collection of Information
Seymour College collects personal information, including sensitive information, about:

  • Students;
  • Parents;
  • Old Scholars;
  • Board Members and Sub-Committee members and their prospective members;
  • Employees and prospective employees;
  • Contractors and prospective contractors;
  • Volunteers
  • Visitors; and
  • Any other person who comes into contact with Seymour College.

The information collected by Seymour College about students and parents may be collected before, during or after the student is enrolled at the College. The primary purpose of collecting this information is to enable Seymour College to provide schooling and educational services for the student or prospective student. If Seymour College is unable to obtain the required information in relation to prospective students, an enrolment may not proceed.

The information collected by Seymour College about job applicants and employees may be collected during the recruitment phase and during the course of employment.

Information may be collected in various forms and may be provided to Seymour College by third parties such as medical practitioners or other health professionals or other schools or government authorities.

6. Use and Disclosure of Information
Seymour College only uses personal information for the purposes of which the information was collected. Seymour College may use or disclose personal information for a secondary purpose for which the information was collected if the secondary purpose is related to the primary purpose, and where the individual to whom the information relates could reasonably expect Seymour College to use the information for that purpose.

Seymour College may also use or disclose personal information for any other purposes for which the College has received consent from the person to whom the personal information relates or otherwise as permitted by legislation.

In relation to personal information which is “sensitive information”, Seymour College will not use or disclose that information for a purpose other than a primary purpose for which it has been collected unless:

  • Seymour College has the consent of the individual to whom the information relates to disclose or use the information for some other purpose;
  • the secondary purpose is directly related to the primary purpose of collection and the individual would reasonably expect Seymour College to use or disclose that information for the secondary purpose; or
  • otherwise as permitted by legislation.

6.1. Use
Students and parents
Seymour College may use personal information collected about students and parents for the following purposes:

  • to make contact with the parents in relation to their child’s schooling;
  • internal accounting;
  • day to day administration;
  • to enable parent groups to effectively interact and fundraise;
  • looking after the students’ education, and social, health and well-being;
  • seeking donations and marketing for Seymour College;
  • to satisfy legal obligations; 
  • credit assessment; and
  • for any other purposes that would be reasonably expected.

6.2. Notwithstanding the scope of the relevant privacy legislation and the APPs, Seymour College maintains the right and notes its legal obligation to provide mandated reports to relevant authorities under the following South Australian legislation:

  • Children’s Protection Act 1993 (SA);
  • Criminal Law Consolidation Act 1935 (SA)
  • Teacher Registration and Standards Act 2004 (SA)

6.3. Prospective Employees, Employees, Contractors and Others
Seymour College may use personal information collected about Prospective Employees, Employees, Contractors, and Board members for the following purposes:

  • to properly assess whether an individual is suitable for employment or to undertake contracted work;
  • administering the individual’s employment or contract;
  • to ensure that information Seymour College has collected is accurate and up to date;
  • internal accounting and administration;
  • insurance;
  • seeking funds and marketing for Seymour College;
  • for reporting to educational and Government authorities;
  • to satisfy legal obligations; and 
  • for any other purposes that would be reasonably expected.

6.4. Exception in relation to employee records
Seymour College is not bound by the Australian Privacy Principles, and this Privacy Policy does not apply, in relation to the College’s treatment of an “employee record”, where the treatment is directly related to a current or former employment relationship between the College and the employee.

7. Disclosure
Seymour College may disclose personal information, including sensitive information for administrative and educational purposes. This may include disclosing information to:

  • other schools;
  • government departments;
  • credit reporting bodies;
  • medical or other health practitioners;
  • people involved in providing services to Seymour College;
  • recipients of Seymour College publications;
  • parents and guardians; and 
  • any other parties to whom Seymour College is authorised to disclose information.

Seymour College will not send personal information overseas about an individual outside of Australia without obtaining the consent of the individual or otherwise complying with privacy laws.

8. Credit Information
Credit information and credit eligibility information is information which according to the Act, is personal information about individuals or organisations/businesses that is:

  • identification information;
  • consumer credit liability information;
  • repayment history information;
  • a statement that an information request has been made about you by a credit provider, mortgage insurer or trade insurer;
  • the type of consumer credit or commercial credit, and the amount of credit, sought in an application:
  • that has been made by you to a credit provider; and
  • in connection with which the provider has made an information request in relation to you;
  • default information;
  • payment information;
  • new arrangement information;
  • court proceedings information;
  • personal insolvency information;
  • publicly available information:
  • that relates to your activities in Australia or the external Territories and the individual's credit worthiness; and
  • that is not court proceedings information about you or information about the individual that is entered or recorded on the National Personal Insolvency Index; or
  • the opinion of a credit provider that you have committed, in circumstances specified by the provider, a serious credit infringement in relation to consumer credit provided by the provider to you.

How does Seymour College collect credit information? The College will collect credit information through a number of methods including:

  • directly from the parent/guardian
  • •from credit reports obtained from credit reporting bodies;
  • internally through the College’s own records;
  • credit references from another credit provider with which the parent/guardian has or had a credit account; and
  • from publicly available information including personal insolvency information about the parent/guardian entered or recorded in the National Personal Insolvency Index

Seymour College collects this information for the purpose of:

  • Internal management in assessing the credit eligibility of parents/guardians;
  • Assessing whether it will consent to provide education services to parents/guardians for their daughters on deferred payment (credit) terms; 
  • to manage the payment and recovery of amounts payable to us by parents/guardians for education services; and 
  • to ensure the College keeps adequate records of amounts outstanding and payable to it from time to time. 

If a parent/guardian fails to make payments to the College when they are due or commits a credit infringement it may disclose details of such events to a CRB, which may use such information provided by the College in reports given to other credit providers.

9. Information Quality
Seymour College will take reasonable steps to ensure that the personal information that is collected, used and disclosed is accurate and up to date. Seymour College will update its records within seven business days when an individual provides any new information or information that has changed.

10. Storage and Quality of Information
Employees are required to treat the information received from others confidentially. Seymour College will take reasonable steps to protect personal information from:

  • misuse, interference and loss; and
  • unauthorised access, modification or disclosure.

Seymour College may store information either electronically or physically in a range of ways including:

  • on electronic databases with password and firewall protection; or
  • in a secure location, including lockable cabinets with access only to authorised personnel.

Seymour College will take reasonable steps to ensure that information is destroyed when it is no longer required by law save and except for information retained for archival/historical records subject to clauses 5 and 6 above

11. Access to Information
11.1. Parents may seek access to personal information collected about their daughter by contacting the Principal of Seymour College. It is the responsibility of the College to ensure that they do not disclose information which would have an unreasonable impact on the privacy of others, where access may result in a breach of the College’s duty of care to the student and its legal obligations.

11.2. Individuals, except students subject to clauses 9.1 and 11, may contact the College to request access to their personal information. Subject to the points below, Seymour College will provide access to that information by supplying copies of the information requested or by allowing inspection of the information requested, or by providing an accurate summary of the information requested. Proof of identity will be required before the College may comply with such requests.

11.2.1 Seymour College will not provide access to personal information if:

  • Providing access would pose a threat to the life or health of any person;
  • Disclosure of information would have an unreasonable impact on the privacy of others;
  • Disclosure of information would prejudice any negotiations in which the College was involved; 
  • The information was privileged or may become privileged during actual or anticipated legal proceedings; 
  • Disclosure of the information is unlawful;

11.3. Any refusal to supply requested information will be provided by the College in writing with an explanation for that refusal.

12. Complaints

  • If an individual has a complaint about how Seymour College has collected, stored or used personal information, please contact the Business Manager. Seymour College will endeavour to deal with your complaint and take any steps necessary to resolve the matter within 7 business days. 
  • If your complaint is unable to be resolved within 7 business days, Seymour College will advise you in writing including letting you know when it expects to provide a response. 
  • If you are unhappy with the College’s response, you can refer your complaint to the Office of the Australian Information Commissioner.
  • Please contact the Director of People and Policy at Seymour College if you have any queries about the personal information that the College holds about you or the way that it uses or discloses that personal information. The College’s contact details are set out below.

The Privacy Officer
Seymour College
546 Portrush Road
GLEN OSMOND SA 5064

13. Consent
Seymour College will treat consent given by parents as consent given on behalf of the student, and notice given to parents will act as notice given to the student.
Consequences of a Breach of this Policy

Seymour College emphasises the need to comply with the requirements of this policy. Any employee found to be in breach of the requirements of this policy may be subject to disciplinary action in accordance with the Performance Management Policy.

14. Implications for Practice
14.1 At Board Level
To properly implement this policy, Seymour College, the Board, and/or the Principal must ensure:

  • That this policy is endorsed on an annual basis;
  • That a Privacy Compliance Plan is implemented to ensure that Seymour College adheres to all aspects of the Privacy Policy;
  • That copies of this policy are made available to parents, students, prospective employees, Board and Committee members and prospective members, contractors, volunteers or any other individual the College holds information about, for example on the Seymour Online Collaboration System (SOCS) site;
  • That copies of this policy are made available to employees, for example on the SOCS site
  • That this policy is incorporated into the Board’s/College’s record of current policies;
  • That this policy is incorporated into the College’s induction program, to ensure that all employees are aware of the policy, have read and understood the policy, and acknowledge their commitment to comply with the policy;
  • That periodic training and refresher sessions are administered to all employees in relation to this policy; and 
  • Parents are informed that if certain information is not obtained, their child may not be able to enrol.

14.2 At other levels
To properly implement this policy, all of the College’s employees, prospective employees, parents/guardians, Board and Committee members and prospective members, students, contractors, volunteers or other individuals about whom the College holds information must agree:

  • to abide by this policy and assist Seymour College in the implementation of this policy; and
  • If information is not obtained, Seymour College may not be able to enrol or continue the enrolment of the student.