Privacy Policy (Unofficial Draft)
Suggestions for Developing a School Privacy Policy
Ó Department of Education and Training
It is recommended that a School privacy policy include the following:
1. Scope
This policy applies to members of school staff and the school council at Brentwood Secondary College. This policy will be made available on request.
2. Authorisation
This policy was adopted at the Brentwood Secondary College School Council meeting on (Day/Month/Year).
3. Review Date
This policy shall be reviewed on (insert time line) and updated if required.
4. Background
All staff of Brentwood Secondary College are required by law to protect the personal and health information the School collects and holds.
The Victorian privacy laws, the Information Privacy Act 2000 and Health Records Act 2001, provide for the protection of personal and health information.
The privacy laws do not replace any existing obligations Brentwood Secondary College has under other laws. Essentially this policy will apply when other laws do not regulate the use of personal information.
5. Definitions
Personal information means information or opinion that is recorded in any form and whether true or not, about an individual whose identity is apparent, or can be reasonably be determined from the information or opinion. For example this includes all paper and electronic records, photographs and video recordings.
Health information is defined as including information or opinion about a person’s physical, mental or psychological health, or disability, which is also classified as personal information. This includes information or opinion about a person’s health status and medical history, whether recorded or not.
Sensitive information is defined as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union, or other professional, or trade association membership, sexual preferences, or criminal record that is also classified as personal information about an individual.
In this policy personal information refers to personal information, health information and sensitive information unless otherwise specified.
Parent in this policy in relation to a child, includes step parent, an adoptive parent, a foster parent, guardian, or a person who has custody or daily care and control of the child.
Staff in this policy is defined as someone who carries out a duty on behalf of the School, paid or unpaid, or who is contracted to, or directly employed by the School or the Department of Education and Early Childhood Development (DEECD). Information provided to a School through job applications is also considered staff information.
6. Policy Context
Personal Information is collected and used by Brentwood Secondary College to:
· provide services or to carry out the School statutory functions,
· assist the School services and its staff to fulfil its duty of care to students,
· plan, resource, monitor and evaluate School services and functions,
· comply with DEECD reporting requirements,
· comply with statutory and or other legal obligations in respect of staff,
· investigate incidents or defend any legal claims against the School, its services or its staff, and
· comply with laws that impose specific obligations regarding the handling of personal information.
7. Collection of Personal Information
The School will generally collect and hold personal information about students, parents and staff by ways of paper documents, electronic systems or verbal communications.
8. Use and disclosure of the personal information provided
Students and Parents:
8.1 The purposes for which the School uses personal information of students and parents include:
· keeping parents informed about matters related to their child’s schooling,
· looking after students’ educational, social and health needs,
· celebrating the efforts and achievements of students,
· day-to-day administration,
· satisfying the School’s legal obligations, and
· allowing the School to discharge its duty of care.
Staff
8.2 The purposes for which the School uses personal information of job applicants, staff members and contractors include:
· assessing the suitability for employment,
· administering the individual’s employment or contract,
· for insurance purposes, such as public liability or WorkCover,
· satisfying the School’s legal requirements, and
· investigating incidents or defending legal claims about the School, its services or staff.
8.3 The School will use and disclose personal information about a student, parent and staff when:
· it is required for general administration duties and statutory functions,
· it relates to the purposes for which it was collected, and
· for a purpose that is directly related to the reason the information was collected and the use would be reasonably expected by the individual and there is no reason to believe they would object to the disclosure.
8.4 The School can disclose personal information for another purpose when:
· the person consents, or
· it is necessary to lessen or prevent a serious or imminent threat to life, health or safety or
· is required by law or for law enforcement purposes.
9. Where consent for the use and disclosure of personal information is required, the school will seek consent from the appropriate person. In the case of a student’s personal information, the school will seek the consent from the student and/ or parent depending on the circumstances and the student’s mental ability and maturity to understand the consequences of the proposed use and disclosure.
10. Accessing personal information
Personal Student Information is provided to parents with each School semester report for verification purposes. A parent, student or staff member may seek access to their personal information, provided by them, that is held by the School at any other time by contacting the school office staff.
Access to other information maybe restricted according to the requirements of laws that cover the management of school records. These include the Public Records Act and the Freedom of Information Act.
11. Updating personal information
The School aims to keep personal information it holds accurate, complete and up-to-date. A copy of all Student Information is sent home twice a year with each semester report for parents to check, verify and if necessary inform the school of any new changes or possible errors of any the information held on record. A person may update/be required to update any personal information that may have changed by contacting the school office staff.
12. Security
12.1 Physical Security of Information
All personal information held on paperwork are secured behind restricted lock doors and cabinets.
All physical access to our servers is restricted to Technical and Management Staff through means of Special lock doors and cabinets.
12.2 Electronic Security of Information
Personal electronic information is secured behind the schools firewall to prevent unauthorised network access. Staff Usernames and passwords are required to access personal student information.
13 Web Sites
Brentwood Secondary College provides general information about the school through the use of our College website, which is available to all members of the community.
In addition to our website, Brentwood provides staff, students and school council members with access to our Internal Intranet and Webmail exchange services.
13. 1 Information Collected (statistical purposes):
Brentwood Secondary College internal web servers and external web site services provided by Netspace Australia may record and log the following information for statistical purposes:
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the Internet Protocol (IP) address of the machine from connecting to the website
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the top level domain name (for example .com, .gov, .au, .uk etc)
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country of origin
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User’s Web browser and Operation system information.
13. 2 Information Collected (Voluntary purposes):
Brentwood Secondary College provides an online electronic subscription service to all our college Newsletter. This service is available to any member of the community and as measure of protecting the identities of our students, all students photos will be removed before uploading onto our website.
The subscription is completely voluntary, members wishing to subscribe may be requested to provide personal information such as their name and email address. Members may opt out of this service at anytime.
13. Complaints under Privacy
Should the school receive a complaint about personal information privacy this will be investigated in accordance with DEECD Privacy Complaints Handling Policy.