Become Content Privacy Statement
Become Content, an online learning unit of VETASSESS ABN 74 802 942 886 (“VETASSESS”) aims to comply with the Privacy and Data Protection Act 2014 (Vic), the Health Records Act 2001 (Vic) and all other applicable privacy legislation and to implement practices and procedures to ensure compliance. The Information Privacy Principles as set out in Schedule 1 of the Privacy and Data Protection Act 2014 (Vic) and the Health Privacy Principles as set out in Schedule 1 of the Health Records Act 2001 (Vic) are incorporated in this Privacy Statement.
At Become Content we respect the rights of individuals (our employees, contractors, business partners and clients) to security, privacy and service and we wish them to have confidence that the personal information they supply to Become Content will be stored and used appropriately
This Statement applies to personal information you provide to us in whatever manner you deal with us. Your rights set out in this privacy statement are in addition to any other rights you may have. Except to the extent expressly set out below, nothing in this statement should be read as an attempt to restrict or exclude any right that you are entitled to by law. We will observe the below principles in the collection, storage and use of the personal information and health information we collect.
For employees, any personal or health information we collect is dealt with pursuant to the terms of their employment agreement and is not subject to this policy.
1. Collection of Information
We will only collect personal information that is relevant to our dealings with the person to whom that personal information relates. We may collect personal information (including sensitive information) about individuals, including prospective employees, clients, independent contractors and various representatives of the customers and suppliers we deal with. The kind of information we collect depends on the purpose for which it is collected. In relation to prospective employees and clients we may collect name and home contact details, including addresses, phone numbers and email addresses. We may also collect details of their next of kin for emergency contact purposes. We may be required to collect some sensitive information in relation to clients for the purpose of monitoring and reporting on participation in education and our performance as an education provider. For customers' and suppliers' representatives, we typically collect name, telephone and email contact details.
Wherever reasonably possible, we collect personal information from the person to whom it relates (you). That is not always possible or appropriate and we do collect and use personal information from publicly available sources and from third parties. Some of the services we provide involve the provision of educational services to employers and in collaboration with other training organisations. In the performance of those services, we are frequently provided with personal information which has been collected by an employer or other training provider.
In all situations where we obtain personal information from a third party, we are careful to seek confirmation from those providing us with the information that it was acquired in accordance with the requirements of the Privacy Laws, that they are entitled to provide it to us and that they are able to authorise us to use it for the purposes for which they are supplying it.
2. Use and Disclosure
We will not divulge any personal information to a third party for any reason other than the uses outlined above unless the disclosure is required by law. We may, however, in relation to that use:
- engage third parties to act on our behalf, including, for example, information technology suppliers, marketing and advertising agencies, mailing and logistics providers and professional advisors; and
- co-operate with researchers engaged in research into matters such as the delivery of educational services and researchers we engage to assist in the assessment of our services.
We may disclose personal information we have collected to these third parties for the purposes of their work and, equally, they may provide us with personal information they have collected from you in the course of providing products or services to us. In all cases where the information was collected by us, or on our behalf by those service providers, it will be stored, accessed and used in accordance with this policy and we will ensure that all such third parties to whom we disclose personal information comply with this policy. We may also disclose personal information to the Commonwealth government and tuition assurance scheme operators.
We may disclose information we collect to third parties engaged in relevant research. Where we are requested to provide information for research purposes we will:
- if reasonably practicable, provide that information in an aggregated and/or de-identified format;
- require the recipient to store that information securely, not disclose it to any other person and return or destroy it when it is no longer required;
- require that the recipient update or delete any part of the information disclosed where we have agreed to update or delete our corresponding records; and
- if the recipient proposes to publish or otherwise share the outcome of their research, require that neither the published or shared report nor any supporting information made available in relation to that report contains any personally identifiable information or, if it includes de-identified data, is sufficiently aggregated or otherwise presented such that it cannot be re-identified.
If Become Content intends to disclose any personal information it collects from you in any other manner than those contemplated above, we will inform you at the time the information is collected.
Except as specifically contemplated in relation to Overseas Clients, below, Become Content will not disclose any personal information it collects to any person located outside Australia unless:
- we have obtained the consent of the person to whom the information relates to that disclosure;
- the recipient of the information is subject to a law or binding scheme, that provides at least a substantially similar level of protection in respect of the use of personal information to that available under Australian law and the person to whom the information relates is directly able to enforce their rights in respect of that protection; or
- the disclosure is otherwise in compliance with our obligations under the Privacy Laws.
3. Data Quality
We will take all reasonable steps to ensure the personal information that is collected, used or disclosed is complete, accurate and current. If you wish to access or update your personal information, we will provide all reasonable assistance to do so. Any request to update or correct the information we hold should be addressed to the email address given for “further information” below.
4. Data Security
Personal information is held by us in printed documents and on electronic databases. We have taken all reasonable steps to ensure that information is protected from misuse, unauthorised access, modification or disclosure including website protection measures, security restrictions on access to our computer systems, controlled access to our corporate premises and policies on document storage. However, while we make all attempts to secure the personal information you may electronically transmit to us, the nature of electronic transmissions is such that there is a possibility that a third party may observe this information whilst it is in transit.
All information not required will be destroyed in accordance with privacy legislation or as required by other legislation or as required under guidance from the Public Records Office.
6. Access and Correction
If you wish to obtain a copy of any personal information we hold which relates to you, request that we correct that information, request that we delete that information or make a complaint relating to our collection or use of your personal information, please contact The Privacy Officer at email@example.com. Please note that we will require you to adequately identify yourself when requesting a copy of your personal information.
In some circumstances, in particular where the volume of information you have requested is substantial or extends beyond solely the personal information of yours that we hold, we may require that you submit your request in the form of an application under the Freedom of Information Act. Our provision of access to information under this policy is in addition to any rights of access you may have under the Freedom of Information Act.
We aim to provide any requested information and respond to any complaint within 30 days. Where you request the correction of any information, we aim to correct our records within five days of receiving your written request to do so.
We aim to act reasonably in resolving all complaints, but if you are not satisfied with the response from Become Content, you may wish to address your complaint to either:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
(Responsible for the administration of the Privacy Act 1988 (Cth))
Commissioner for Privacy and Data Protection, PO Box 24014, Melbourne VIC 3001
(Responsible for the administration of the Privacy and Data Protection Act 2014 (Vic))
7. Unique Identifiers
Sometimes we have to collect unique identifiers such as Centrelink numbers or Tax File Numbers. If we do need this information the purposes for collecting these numbers will be explained at the time the information is collected.
We will not use these unique identifiers for any other purposes than those for which they were collected.
If we ascribe a unique identifier to you for our internal use that identifier will not be shared with any other body or person without your consent.
So far as is reasonably possible, Become Content is able to deal with you anonymously or under a pseudonym. If you do deal with us under a pseudonym, we request that you inform us accordingly so as to avoid collecting inaccurate information. Similarly, if you have provided us with your contact details, and those details subsequently change, we request that you inform us of the change so that we can ensure our records are kept up to date.
9. Transborder Data Flows
Our services are provided on-line and may be made available to clients located outside Australia (Overseas Clients). Where we offer services to Overseas Clients we will, at minimum, store and manage their personal information in accordance with this policy and the Privacy Laws applicable in Victoria, Australia. If the laws of the country in which the Overseas Client is located afford the Overseas Client additional protections or rights with respect to the use and management of their personal information, we will, so far as reasonably practicable, afford the Overseas Client the benefit of those additional protections or rights, provided that doing so does not conflict with our legal obligations with respect to the handling and retention of their personal information.
If we are unable to reasonably comply with an Overseas Client’s requirements with respect to the use and management of their personal information, we may elect instead to cease providing services to the Overseas Client.
By indicating their acceptance of this policy, and by registering to use our services, each Overseas Client consents to our collection of their personal information and to our storage and use of that information in Australia in accordance with this policy. In addition, to the extent that any permitted use of their personal information requires us to engage an agent or representative in the country in which the Overseas Client is located, each Overseas Client consents to our disclosure of their personal information to such agents or representatives.
10. Sensitive Information
We collect sensitive information about an individual only with consent of the person or if required or permitted by law. ‘Sensitive information’ is information or an opinion about an individual's:
- racial or ethnic origin
- political opinions
- membership of a political association
- religious belief or affiliations
- sexual preferences
- criminal record
- membership of a trade union
- membership of a professional or trade association.
11. Website Usage and Cookies
Cookies are pieces of information that a website downloads to your computer to record your preferences while you browse. Other technologies that may be used by us include web beacons (which may operate in conjunction with cookies). The information collected through these technologies may be used by us to improve and customise your experience on our website. In addition, we may collect aggregated non-personally identifiable data from our website to help us maintain and improve delivery of our services and to provide a consistent experience. This aggregated information assists us in improving content and website navigation. You can configure your web browser to reject and block cookies. If you decide to delete or block certain cookies, your experience on our website may be limited. When you visit any of our websites, our site’s server may record information about your visit, including:
- IP address;
- A top-level domain name (for example .com, .au, etc.);
- the date and time of your visit to the site;
- the pages you accessed and documents downloaded during your visit;
- the previous site you visited;
- if you’ve visited our site before; and
- the type of browser used.
All of this information is collected for statistical purposes, which enables us to assess the number of visitors to the different sections of the site and assists us to make the website more useful to visitors.
There are ways for you to opt out of third-party cookies; (i) by contacting us; or (ii) visiting youronlinechoices.com.au that allows you to opt out of some online behavioural advertising. These services provided by third party vendors generally operate without the collection or use of any personal information. In many cases, the information relates only to a device or is of a statistical nature, and we will not be able to identity the user.
Please contact Become Content for further information about this policy.