Privacy and Health Information Management Statement
This Privacy and Health Information Management Statement sets out how Gowrie Victoria collects, stores, uses, discloses and destroys personal information about children and their families, and about adult learning students and clients.
Personal information is any information or an opinion about an identified individual, or about an individual who can reasonably be identified from the information or opinion (Privacy Act s6, Privacy and Data Protection Act s3, Health Records Act s3).
There are two special categories of personal information:
|Sensitive information||Information about a person’s origins, opinions, associations, beliefs, criminal record, and genetic and biometric information.
Sensitive information also includes health information (Privacy Act s6, Privacy and Data Protection Act Sch 1).
|Health information||Information about a person’s health, treatments and services (Privacy Act s6FA, Health Records Act s3).|
Personal information Gowrie Victoria collects and uses
Information for Early Learning Programs
(APP 5.1, 5.2 and IPP 1.3)
Gowrie Victoria collects and holds personal information required by the Education and Care Services National Law 2010, the Education and Care Service Regulations 2011 and the family assistance law. Gowrie Victoria also collects personal information required by the Department of Education and Training as part of its kindergarten funding system, and other personal information reasonably necessary to carry on its activities.
Some of the personal information we collect is classified as sensitive information and health information. Gowrie Victoria only collects sensitive and health information which is reasonably necessary (APP 3.3, IPP 10.1, HPP 1.1). It will always obtain consent for collection of sensitive and health information from the person involved or their families (APPs 3.3, 3.4, IPP 10.1, HPP 1.1).
Information for Adult Learning Programs
Gowrie Victoria collects and holds personal information from registered training organisation students (RTO students) required by the Victorian VET Student Statistical Collection Guidelines applicable to all registered training organisations.
Information collected from adult learning clients (AL clients) taking part in other adult learning programs is limited to that required to allow Gowrie Victoria to contact them as required.
Marketing and Promotion
Gowrie Victoria may collect and hold personal information to maintain a mailing list as part of its marketing and promotion activities. For these purposes Gowrie Victoria may collect information about people who wish to receive emails, including their name, email address and some demographic information such as location and interests. This information may be collected through Gowrie Victoria’s website or other channels.
Users who choose to sign up to Gowrie Victoria’s mailing list can unsubscribe at any time.
Gowrie Victoria may use log files to track visitors to its web site. The information Gowrie Victoria might collect includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the site, track user’s movements, and gather broad demographic information for aggregate use.
This data is not linked to personally identifiable information.
When and how Gowrie Victoria collects personal information
When Children are Placed on Waiting Lists for Gowrie Victoria’s Early Learning Programs
Gowrie Victoria receives personal information directly from families or from local councils if they operate a central registration system for childcare and kindergarten services.
When Children are Enrolled into Gowrie Victoria’s Early Learning Programs
Gowrie Victoria collects personal information, including sensitive and health information, directly from families.
When Children are being Educated and Cared For at a Service
Further personal information about children, including sensitive and health information, is collected by Gowrie Victoria while children are being educated and cared for at a service.
Gowrie Victoria considers that notifying families each time any personal information is collected is unreasonable and impractical (APP 3.6). Instead, Gowrie Victoria obtains authorisation to collect this information when children are enrolled.
Persons Given Authority by Children’s Families
Families must get permission for Gowrie Victoria to collect personal information from each person they nominate to give authorisations for their children enrolled in an early learning program. Gowrie Victoria assumes that this permission has been granted.
When there is Risk to the Wellbeing and Safety of a Child
In accordance with the Child Wellbeing and Safety Act 2005, a prescribed information sharing entity may give Gowrie Victoria personal information, including sensitive and health information, about a child whose safety and wellbeing is at risk which is reasonably necessary to assist Gowrie Victoria to promote the well-being and safety of that child and to provide informed support (Child Wellbeing and Safety Act 2005 s41W, APP 3.3, 3.6).
When a Child or a Member of a Child’s Household is at Risk of Family Violence
In accordance with the Family Violence Protection Act 2008, an information sharing entity prescribed at law may give Gowrie Victoria information about a child or a member of that child’s household if the child or household member is at risk from family violence to enable Gowrie Victoria to assist with reducing the risk of violence.
When Adult Learning Students are Enrolled in an Adult Learning Program
Information for RTO students is collected from students themselves when they enrol. Further information is collected as RTO courses progress. Information for AL clients is collected as part of their program.
When People Subscribe to Gowrie Victoria’s Newsletters or Promotional Material
Information is collected directly from people wishing to subscribe to Gowrie Victoria’s newsletters and promotional materials through Gowrie Victoria’s website or from other sources.
Non-identification and pseudonyms
It is impractical for Gowrie Victoria to deal with individuals who do not identify themselves or who use a pseudonym.
How Gowrie Victoria holds personal information
Information Collected for Early Learning Programs
Gowrie Victoria takes reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Gowrie Victoria uses Qikkids as its childcare management system and its interface with government agencies to administer childcare subsidies.
Qikkids (part of Transaction Services Group Ltd) holds all personal information collected by Gowrie Victoria, using secure servers in Brisbane. It does not use any of this information itself.
All payments for education and care services due to Gowrie Victoria are handled by DebitSuccess (also part of Transaction Services Group Ltd) Families complete a DebitSuccess form on enrolment that contains relevant payment details. DebitSuccess holds the highest level of Payment Card Industry Data Security Standards (PCI DSS) compliance certification. Gowrie Victoria is satisfied that this data is properly secured.
Some compliance information is held by 1Place, a specialist compliance system manager for early learning, on servers in Australia.
Gowrie Victoria retains paper records of all personal information as a back-up. These paper records are securely stored in Gowrie Victoria’s services.
Information Collected for Adult Learning Programs
All information from RTO students is stored in VETtrak. VETtrak is owned and operated by ReadyTech, an ASX-listed provider of student management systems. RTO student data is hosted on ReadyTech’s servers. ReadyTech’s data handling operations are certified to comply with ISO 27001.
Information about AL clients is stored in Zoho’s servers based in Australia.
Gowrie Victoria holds paper copies of RTO student records and AL clients’ details in locked cabinets.
Gowrie Victoria’s use of personal information
Gowrie Victoria uses the personal information it collects:
- to provide its early learning programs
- to safeguard the health and well-being of children enrolled in its early learning programs
- to inform families about the progress of their children enrolled in its early learning programs
- to reduce risks to a child’s wellbeing and safety
- to provide its adult learning programs
- to inform adult learning students of their course work and assessments
- to carry out all administrative functions associated with its activities, including billing, and reporting to government authorities and regulators
- to inform families, RTO students and AL clients about developments, programs and activities at Gowrie Victoria which might affect or be of interest to them
- to evaluate and improve programs and activities
- to promote its service to prospective families, RTO students, AL clients and other interested parties
Gowrie Victoria does not use personal information for any other purpose.
Gowrie Victoria’s disclosure of personal information
Information about Children Enrolled in Early Learning Programs and Their Families
Where required or permitted by law, contractual arrangements with government authorities and in the event of emergencies, Gowrie Victoria may provide personal information about children and their families to:
- Services Australia
- the Commonwealth Department of Education, Skills and Employment
- the Victorian Department of Health and Human Services and its agencies
- the Victorian Department of Education and Training
- an information sharing entity prescribed by law to receive information about a child and their family/household members
- health service providers
- courts and tribunals
- Victoria Police and other law enforcement agencies
- local councils
- insurance providers, both for obtaining cover and in connection with claims
- a child’s intended primary school
Gowrie Victoria may also disclose personal information to any other person or organisation after getting approval from families.
Gowrie Victoria does not disclose any personal information to overseas recipients unless:
- this is required for Gowrie Victoria’s own operational reasons
- Gowrie Victoria is satisfied that after disclosure personal information remains fully protected in accordance with Australian legal requirements
- Gowrie Victoria retains contractual control over the personal information
Information about Adult Learning Students Enrolled in Adult Learning Programs
Personal information about RTO students is shared only with the Australian Skills and Quality Authority as the RTO regulator.
Personal information about AL clients may be shared with AL clients’ employers and with government entities, dependent on the terms of any relevant training contracts. Personal information is not shared with any other entity.
Information about People on Gowrie Victoria’s Mailing List
Personal information about people on Gowrie Victoria’s mailing lists is not shared with any other organisation.
Who at Gowrie Victoria has access to personal information?
Staff members at Gowrie Victoria, and students-on-placement only have access to personal information which is required to fulfil their employment duties. Volunteers are not given access to personal information.
Research partners who wish to use data for study purposes must obtain written permission from the families concerned. Any personal information used must first be de-identified.
Personal information about children or their families, RTO students and AL clients will only be given to the Board without first being de-identified in exceptional circumstances.
How can a person access their personal information?
Families of children enrolled in an early learning program, RTO students and AL clients can write to the Secretary at Gowrie Victoria asking:
- what sort of personal information Gowrie Victoria holds about themselves or their children, why the information is held, and how it collects, holds, uses and discloses that information
- for a copy of any or all of their own personal information and personal information about their children
After satisfying itself of the identity of the person requesting access, Gowrie Victoria will normally provide any personal information requested in a reasonable period of time (APP12). Gowrie Victoria will tell inquirers if there are lawful reasons, including reasons relating to the well-being and safety of children and their families (APP12.3(a)(g), Child Wellbeing and Safety Act 2005 s41ZF), why some or all of the information will not be provided.
Gowrie Victoria will not make any charges for accessing personal information.
Will Gowrie Victoria correct personal information?
Corrections Initiated by Gowrie Victoria
If Gowrie Victoria becomes aware that personal information it holds about a family, a child, an RTO student or an AL client is inaccurate, out of date, incomplete, irrelevant or misleading, then it will take reasonable steps to correct and update that information.
If Gowrie Victoria has disclosed any personal information to another person or organisation, then it will if reasonably required notify that other person or organisation that the information has been corrected.
Corrections at the Request of Families or Adult Learning Students
If families, RTO students or AL clients become aware that the personal information held about them or their children is inaccurate, out of date, incomplete, irrelevant or misleading, then they can make a written request to Secretary at Gowrie Victoria asking to have their information corrected or updated.
Gowrie Victoria may at its absolute discretion refuse to correct or update the personal information. If it does so it must give a written notice to the individual setting out its reasons for refusal, the mechanisms available to make a complaint about the matter and how the person may make a statement to be attached to the person’s personal information or their children’s personal information.
Gowrie Victoria will not make any charges for correcting personal information.
What happens when personal information is no longer needed?
Gowrie Victoria will destroy or de-identify any personal information which it no longer requires for its functions and activities, and which is not required to be kept by laws and regulations.
How can a person make a complaint?
If a person wishes to complain about Gowrie Victoria’s collection, storage, use or disclosure of personal information, they should in the first instance make the complaint in writing to the Secretary at Gowrie Victoria.
The Secretary will investigate the complaint and determine if Gowrie Victoria should take any action to address the complaint. The Secretary will inform the person in writing about the investigations made and the proposed actions, if any.
An individual may at any time also make a complaint to the Office of the Australian Information Commissioner. Procedures for making a complaint are set out in the Office for the Australian Information Commissioner’s website.
How can a person get a copy of this Privacy and Health Information Management Statement?
This Privacy and Health Information Management Statement can be downloaded from Gowrie Victoria’s website as a pdf document. A copy can be made available in other forms on request.
Will Gowrie Victoria make changes to this Privacy and Health Information Management Statement?
Gowrie Victoria reserves the right to make changes to this Privacy and Health Information Management Statement at any time.
Gowrie Victoria’s contact details
For all inquiries relating to this Privacy and Health Information Management Statement, please contact:
36 Newry Street
Carlton North, VIC 3054
Tel: 1300 446 974
© 2022 Gowrie Victoria