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In this policy:

• Personal information means information or an opinion that is recorded, whether true or not, about an individual whose identity is apparent, or can reasonably be identified, from the information or opinion. Personal information includes information such as: contact details, enrolment information, residential information, and emergency information.

• ·Sensitive Information means personal information that is also information or an opinion about an individual’s: racial or ethnic origin; religious beliefs or affiliations; philosophical beliefs; political opinions; membership of a political or professional association; membership of a trade union or association; sexual preferences or practices; or criminal record.

• Health information means:

  • information or an opinion about:

    • the physical, mental, or psychological health (at any time) of an individual; or a disability (at any time) of an individual;

    • an individual’s expressed wishes about health services to be provided in the future to them; or a health service provided or to be provided to an individual where the information or opinion is also personal information.

  • Other types of personal information collected:

    • to provide or in providing a health service;

    • in connection with the donation, or intended donation, by the individual;

    • that is genetic information about an individual in a form which is or could be predictive of the health (at any time) of the individual.

       

The type of personal information that we may collect and hold about you will depend on the nature of our dealings with you. This may include:

• identity and contact information (for example, your name, contact details, date of birth, emergency contacts, driver’s licence, passport, birth certificate, Medicare card)
• financial information (for example your tax file number, bank details and superannuation information)
• residency and citizenship status
• education and training information
• employment history
• background checks required for employment or enrolment in a course of study (for example Working with Children Checks and Police Checks)
• location information
• images recorded by security and surveillance systems
• records of complaints, appeals and disciplinary matters
• other personal information that may be required to facilitate your dealings with us, including types of personal information or health information set out in a collection notice.

Sensitive information

We will not collect sensitive information about you unless:

• you have consented
• collection is required under law
• collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns is either physically or legally incapable of giving consent to the collection or physically cannot communicate consent to the collection.

Despite the above, we may collect sensitive information about you if the collection:

• is necessary for research, or the compilation or analysis of statistics, relevant to government funded targeted health, welfare, support or educational services
• is of information relating to your racial or ethnic origin and is collected for the purpose of providing government funded targeted welfare or educational services
• there is no reasonably practicable alternative to collecting the information for that purpose
• it is impractical for us to seek your consent to the collection.

We will collect health information about an individual:

• only if the information is necessary for one or more of our functions or activities and with the consent of the individual
• pursuant to an exception specified in the Health Records Act 2001 (Vic).

The types of health information we may collect and hold about you may include:

• information collected by us in providing counselling and other support services to you
• information collected in providing emergency responses including first aid
• evidence of your vaccination status where required to undertake or supervise practical placement or work-integrated learning as required by the host employer
• occupational health records for employees exposed to high-risk environments
• evidence to support return to work arrangements, WorkCover or other insurance claims
• health insurance information for overseas learners
• other health information you provide to us from your health practitioner including medical certificates and reports.

We take all reasonable steps to ensure that information collected is:

• necessary for our purposes
• relevant to the purpose of collection
• collected in a lawful and fair way, with consent where reasonably possible and without unreasonable intrusion
• as up to date and complete as reasonably possible.

Notice of collection

Where we collect your personal information or health information directly from you, we will take reasonable steps to ensure that you are aware of:

• our identity and contact details
• the fact that you can gain access to the information
• the purpose for which the information is collected (“the primary purpose”)
• to whom (or the types of individuals or organisations to which) we usually disclose information of that kind, including to parents / guardians (where relevant)
• any law that requires specific information to be collected
• the main consequences (if any) for you if all or part of the information is not collected.

Sources of personal information or health information

Important sources of personal information or health information collected by us include the following.

Learners:

• schools, Victorian Tertiary Admissions Centre (VTAC), its successors and equivalent interstate and overseas bodies
• other tertiary education institutions and providers
• domestic and international education recruitment agencies
• health practitioners and other agencies supporting learners.

Employees and volunteers:

• previous employers and referees nominated by prospective and current employees
• health practitioners and rehabilitation providers
• employment review assessors
• other government bodies for the purposes of employment eligibility.

Other persons:

• Parents’, guardians’ and/or care providers’ personal information may be collected from learners, as relevant to the learner’s enrolment.
• Contractor personal information may be collected where required by legislation or where goods and services are provided to Holmesglen.

We will not collect personal information other than from you or one of the sources outlined above unless:

• prior consent is provided by you
• we are required or authorised to collect the information under legislation or by a court/tribunal order
• it is impractical or unreasonable to obtain your consent.

Notification of collection through a third party

We will take all reasonable steps to ensure you are aware that personal information has been collected about you and the circumstances of collection if the:

• information has been collected from another person or entity
• you could not reasonably be expected to know that the information has been collected.

The Notice of Collection above sets out the information that will be provided to you, where practicable. 

We use or disclose personal information and health information for the reason it was collected (the primary purpose). In some situations, we may use or disclose personal information or health information for a secondary purpose. This may occur in the following circumstances.

• You have given your consent for us to use or disclose your personal information or health information (as applicable) for that secondary purpose.
• The secondary purpose is related to the primary purpose, and a person in a similar situation would reasonably expect the information to be used or disclosed for that secondary purpose (provided that, for Sensitive Information or health information, the secondary purpose must be directly related to the primary purpose).
• Use or disclosure of the personal information or health information is required or authorised by or under law, such as relevant legislation or a court/tribunal order.
• The use or disclosure is necessary for research or the compilation or analysis of statistics, which is in the public interest, other than where the information will be disclosed in a publication in a form that identifies any individual, where:

o    it is impracticable for us to seek your consent before the use or disclosure

o    in the case of disclosure, we reasonably believe that the recipient will not disclose the information

o    for health information, the purpose of the research or compilation or analysis of statistics cannot be served by information that does not identify you or from which your identity is not reasonably able to be ascertained and in accordance with the Statutory Guidelines on Research February 2002 issued under the Health Records Act 2001 (Vic).

• We reasonably believe that the use or disclosure is necessary to lessen or prevent a serious threat to:

o    your life, health, safety or welfare

o    public health, public safety or public welfare.

• We have reason to suspect that unlawful activity has been, is being or may be engaged in, and we use or disclose the personal information or health information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities.
• We reasonably believe that the use or disclosure of personal information or health information is reasonably necessary for specified types of law enforcement functions conducted by, or on behalf of, a law enforcement agency.

Learner identity document verification

We are required to check your eligibility to receive government funding, a government student loan scheme and/or a concession fee. This involves us verifying your identity and other personal information such as your age, citizenship and concession entitlements. We use the Australian Government Document Verification Service to check whether the biographic information on your identity document (eg information on your driver’s licence, passport, birth certificate, Medicare card, Centrelink concession card etc) matches the original record. We receive a simple ‘yes’ or ‘no’ to the match request.

Using the Document Verification Service means we do not have to make and store copies of these identity documents, which reduces information security risks and the potential for identity crime.

We make sure you are aware when we collect your identification information that it will be handled for this purpose through a specific collection notice displayed in the online my.Holmesglen platform that you use to manage your enrolment. You will also provide your consent to use and disclosure your identification information in my.Holmesglen. If you do not provide the requested information and your consent, we will need to sight and retain a copy of your identity document/s for us to comply with government funding or contractual agreements. You will be required to attend in person at the Information Office at one of our campuses to do this. If you do not verify your identity either online or on campus, we will need to reject your enrolment and will not be able to provide, or continue to provide, any education, training or support services.

Where you provide identity document information and consent to identity document verification, this information is disclosed to:

• GBG ANZ (GreenID), an Australian Government approved Gateway Service Provider, who accesses and uses the Document Verification Service on our behalf and returns the match information
• government bodies and database owners to confirm whether the identity information provided matches the information they hold. Where the provided information is from an identity document issued by a New Zealand government body, information will be transferred between Australia and New Zealand to make an information request and receive an information match result.

We then store a unique identifier provided by the Gateway Service Provider in our student management system. This is used for audit purposes to evidence we have verified your identity or to follow up with you if the information is not verified/fails for any reason. We do not store the original identification document number (eg a concession card, license, Medicare, birth certificate or passport number) in our systems.

You can get further information about our use of the Document Verification Service and how to make a complaint relating to our collection, use and disclosure of the identification information by contacting our Privacy Officer (privacy@holmesglen.edu.au). Further information about the Document Verification Service is also available at the IDMatch website.

Other disclosures

We may also disclose learners’ information to third parties in the following circumstances:

• academic progress information may be disclosed to another tertiary institution or related body as required where a learner is transferring to a new institution
• personal and enrolment information, including academic results, where learners are undertaking cross-institutional study, may be disclosed to the relevant institution as required to confirm the learner’s enrolment or qualification
• personal information may be disclosed to contractors engaged by Holmesglen where this is required for the services being acquired eg debt recovery services
• personal and enrolment information, including academic results, of apprentices and trainees may be disclosed to their employer
• personal information and health information may be disclosed to government and regulatory bodies where this is required under legislation, a court/tribunal order or in compliance with regulatory, funding or loan arrangements (including HELP and VET Student Loans)
• personal information and health information may be disclosed to external organisations such as professional bodies or licensing agencies in connection with your studies
• personal information and health information may be disclosed to a third party, including a parent, guardian or care giver, where learners have provided consent. Current learners can provide consent for us to disclose information to a third-party by completing our Disclosure of Information Permission Form.

Third parties requesting access to information held about a current, former or prospective learner are requested to complete the Request to Disclose Student Information Form.

We may use or disclose personal information about you for direct marketing activities if:

• we collected the information from you
• you have consented to receive direct marketing or would reasonably expect us to use or disclose your information for that purpose
• we provide a simple means for you to request that we stop sending direct marketing (also known as opting out)
• you have not made such a request to us.

We will not use sensitive information for direct marketing without your consent. We will not use health information for direct marketing.

We will take reasonable steps to make sure that the personal information and health information we collect, use or disclose is accurate, complete and up to date. To ensure quality and accuracy of personal information and health information, we request that you provide relevant and accurate information and notify us where that information requires updating as follows:

• prospective domestic learners – Student Recruitment info@holmesglen.edu.au
• prospective overseas learners – International Students and Programs intladmissions@holmesglen.edu.au
• Open Day attendees and other individuals attending Holmesglen events – Marketing Department marketing@holmesglen.edu.au
• enrolled learners – self-service through MyHolmesglen or Holmesglen Assist assist@holmesglen.edu.au
• learners engaged with support services (eg counselling, welfare, disability, or First Nations support) – Student Wellbeing or Student Engagement and Equity studentwellbeing@holmesglen.edu.au
• employees – self-service through ADP or Human Resources hrservices@holmesglen.edu.au
• contractors – Procurement Department procurement@holmesglen.edu.au
• creditors and debtors – Finance Department finance@holmesglen.edu.au
• employers of apprentices and trainees – Apprentice Central appcentral@holmesglen.edu.au
• all other individuals – Privacy Officer privacy@holmesglen.edu.au.

We will take reasonable steps to ensure that the personal information and health information we hold is protected from misuse, loss, or unauthorised access, modification or disclosure.  We incorporate information security controls to minimise the risk of data loss or misuse by:

• implementing industry-standard security measures, including encryption, firewalls, and access control mechanisms, to protect information
• ensuring that data creation, storage, and processing occur on approved ICT systems
• providing induction and ongoing information security training for staff
• documenting and assigning security roles and responsibilities to employees with specific information security functions
• classifying data in accordance with the current Victorian Protective Data Security Guidelines
• conducting risk assessments on information assets containing personally identifiable information
• ensuring that the disposal of personal information and health information is authorised and complies with the Privacy and Data Protection Act 2014 (Vic) and the Health Records Act 2001 (Vic)
• requiring that Holmesglen’s partners, contractors, and service providers be bound by Victoria’s privacy principles, and ensuring that information exchanged is handled in accordance with security standards, privacy principles, and contractual agreements.

When handling personal information received from third parties, we do so according to the originator’s instructions.

If we become aware that your personal information or health information has been inappropriately handled, we will inform you of the incident and take appropriate action to ensure such mishandling does not occur again.

We will also take reasonable steps to destroy or permanently de-identify personal information and health information if it is no longer needed for any purpose. This obligation is subject to the Public Records Act 1973 (Vic), which requires us to keep full and accurate records and to retain them for periods of time. Destruction of personal information and health information will be carried out according to our records management policy.

We will only transfer personal information or health information about you to someone (other than ourselves or you) who is outside Victoria if:

• we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Information Privacy Principles set out in the Privacy and Data Protection Act 2014 (Vic) or Health Privacy Principles set out in the Health Records Act 2001 (Vic) (as relevant)
• you consent to the transfer
• the transfer is necessary for the performance of a contract between us or for the implementation of pre-contractual measures taken in response to your request
• the transfer is necessary for the performance of a contract concluded in your interest between us and a third party
• all the following apply:
  • the transfer is for your benefit;
  • it is impracticable to obtain your consent to that transfer
  • if it were practicable to obtain that consent, you would likely give it
• we have taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the personal information inconsistently with the Information Privacy Principles or Health Privacy Principles (as relevant)
• for health information, the transfer is authorised or required by law.

This privacy policy is available on our website and upon request to our Privacy Officer (privacy@holmesglen.edu.au).

If requested, our Privacy Officer will take reasonable steps to let you know, generally, what sort of personal information and health information we hold, for what purposes, and how we collect, hold, use and disclose that information.

We are subject to the Freedom of Information Act 1982 (Vic) and are required to manage requests for access to and correction of personal information and health information under that legislation. Please refer to our Freedom of Information policy or contact the Freedom of Information Officer for further assistance on foi@holmesglen.edu.au.

We assign unique identifiers to employees and learners, which are necessary for us to carry out our functions efficiently.

All learners undertaking study in a nationally recognised course will need to have a Unique Student Identifier (USI), as required by the Australian Government. More information is accessible from the Australian Government USI Website

We will not adopt a unique identifier of an individual that has been assigned by another organisation. However, we may collect and store unique identifiers used by other organisations. These may be included in reports to relevant Commonwealth and Victorian departments and agencies.

You may, in some circumstances where it is lawful and practicable, be able to request and receive information from us anonymously.

We will not be able to offer anonymity if:

• we are required or authorised by law, including by a court or tribunal order, to deal with certain individuals; or
• it is impractical for us to deal with individuals who have not identified themselves.

This section describes what cookies are; how we use cookies, and how to manage cookies.

We use cookies, web beacons and similar technologies (collectively, "cookies") to improve your experience with us. We use cookies on our website and to automatically collect information from you.

What are cookies?

Cookies are small text files consisting of letters and numbers. These are sent from Holmesglen's or our partners’ web servers and stored on your device as described below. We use several types of cookies:

• session cookies are temporary cookie files that expire when you close your web browser
• persistent cookies are cookie files that remain until you erase them or they expire
• first-party cookies are cookies that are used by Holmesglen
• third-party cookies are cookies set by a third-party site.

Web beacons are small transparent graphic images that may be in emails we send to you.

Other similar technologies that we use are technologies that store information in your browser or on your device in a manner similar to cookies and web beacons.

Cookies enable our website and services to remember your actions and preferences (such as login, language and other preferences) over time, so you don’t have to keep re-entering them whenever you come back or browse from one page to another.

What types of cookies do we use?The cookies we use typically enhance our services to you.  Some of our services need cookies to work, others simply make our services easier for you. In general, we use the following types of cookies:

• essential cookies, which are essential to provide you with services you have requested. For example, these include the cookies that make it possible for the website to deliver fast webpage loading speeds and enhance security for users. If you set your browser to block these cookies, these functions and services will not work for you
• performance cookies, which measure how often you visit our sites and how you use them. We use this information to get a better sense of how our users engage with our website, and to improve our website, so that users have a better experience. For example, we collect information about which of our pages are most frequently visited, and by which types of users. We also use third-party cookies to help with performance, such as Google Analytics, which gives us information on your journey between pages, our website performance and the effectiveness of our digital campaigns. Other examples of third-party cookies we may use include Microsoft Clarity and Hotjar, which help us understand how you interact with our pages and improve our website
• preference cookies, which are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience. A mix of first-party and third-party functionality cookies are used
• security related cookies, which keep our services and your data safe and secure, such as by helping us detect fraud and guarding your data
• marketing cookies, which are used to collect information about your visit to our website, the content you have viewed, the links you have followed and information about your web browser, device and IP address. We have set out more details on these types of cookies below.

Marketing cookies

Holmesglen uses marketing cookies to personalise and improve your experience on our website, in marketing emails, and in third-party advertising.  These cookies allow us to display more relevant advertising to people who visit our website by showing you advertisements that are based on your browsing patterns and the way you have interacted with our website.

The advertising techniques we use do not collect information such as your name, email address, postal address or phone number. We sometimes use information such as your IP address and browser type. We may also share some limited aspects of this information with third parties for advertising purposes.

We may also share online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website or app (for example, Facebook and Instagram), you may be shown advertising based on your browsing patterns on our website.  We may also show you advertising on our website based on your browsing patterns on other websites or apps (including Facebook and Instagram) that we have obtained from our advertising partners.

How can you control Holmesglen's use of cookies?

Your browser or device will typically offer settings regarding the use and scope of cookies, as well as cookies currently stored. Please see your browser’s or device’s reference information to learn how to adjust your settings.  For example, you may be able to block all cookies, accept only first-party cookies, or delete or uninstall all cookies upon exiting your browser.

Please be aware that you may not benefit from some of our website services if you uninstall a cookie or prevent cookies from being installed on your browser or device.

If you would like more information about any aspect of this policy, please contact our Privacy Officer via email: privacy@holmesglen.edu.au or writing to the Privacy Officer, PO Box 42, Holmesglen, VIC, 3148.

In the first instance, alleged privacy breaches or complaints about the way we have handled your personal information and/or health information should be referred to the area where you initially lodged the information.

If a satisfactory resolution cannot be reached at this level, the alleged breach or complaint should be submitted in writing to our Privacy Officer (privacy@holmesglen.edu.au ). All matters received through this process will be managed in accordance with Holmesglen’s complaint resolution process.