Stewart House (ACN 127 072 100) is committed to complying with our obligations under the Australian Privacy Act 1988 (Cth) (the Privacy Act) (including the Australian Privacy Principles set out in the Privacy Act (the APPs)).
Stewart House is also committed to ensuring that its employees are aware of their obligations in relation to the protection of personal and sensitive information.
In this policy, “Personal Information” means information or opinion about an identified individual, or an individual who is reasonably identifiable.
COLLECTION OF PERSONAL INFORMATION
Stewart House only collects Personal Information to the extent necessary to fulfil one or more of its functions and activities, and will do so only by fair and reasonable means. Generally we will collect Personal Information directly from the individual to whom the Personal Information relates, but in some circumstances (including as outlined below), it may be necessary for us to collect information from a third party source.
How Personal Information is collected and held by Stewart House
Personal Information collected by Stewart House may include information you provide or volunteer when using the Website, when completing enrolment forms for student placement at Stewart House, when interacting with our commercial and/or marketing managers and information obtained from other sources, such as public records or bodies or schools. In a few areas on our Website, we ask you to provide information that will enable us to assist you with technical support issues or to follow up with you after your visit. It is completely optional for you to participate. For example, we request information from you when you:
- provide feedback
- submit your resume;
- request information from Stewart House; or
- submit comments via the “Contact Us” e-mail.
In limited circumstances, we may collect Personal Information about you from a third-party social media platform such as LinkedIn or Google+ in connection with our recruitment and HR processes.
We may also collect Personal Information from a third party where particular circumstances require it, for example if we need to obtain a reference from a previous employer prior to offering an individual employment or information regarding your child’s health or schooling from the local school, doctor, health care provider to better assist us in providing care across their stay with us. This would only occur with your express written consent contained within the enrolment forms required to be completed before a placement is offered.
What kinds of Personal Information does Stewart House collect and hold?
The kinds of Personal Information we collect will depend on the purpose(s) for which we are collecting it. For example, in each of the instances above, we may ask for:
- your name;
- e-mail address;
- phone number;
- postal address;
- position and contact telephone number;
as well as other similar Personal Information that is needed to register or subscribe your child to the services we provide. If we ever ask for significantly different information we will inform you.
If you do not provide certain requested Personal Information to Stewart House, Stewart House may not be able to provide you with access to and use of our primary service namely the 12-day program provided for students from public schools across NSW and the ACT, or to fulfil one or more of its functions and activities applicable to you or your children.
In certain circumstances, we also collect Personal Information which is classified as Sensitive Information under the Privacy Act including:
- criminal records; and
- police checks,
in respect of employees, sub-contractors, associates, volunteers and other relevant parties. We only collect such Sensitive Information where we are required to do so under Stewart House’s regulatory, probity and licensing requirements.
This Sensitive Information is only accessible by restricted staff within Stewart House and is only disclosed to an entity (generally the relevant regulatory or government authority or agency) where we have a legal or regulatory requirement or obligation to do so.
Stewart House’s practice is to destroy such Sensitive Information promptly after the relevant regulatory, probity or licencing requirement has been satisfied. In the case of employee Sensitive Information, our practice is to destroy such Sensitive Information no later than two years following termination or cessation of the employee’s employment. In the case of student information, we retain such confidential information electronically until the student reached the biological age of 25 years.
USE AND DISCLOSURE OF INFORMATION
The Personal Information you provide will be used to support your relationship with Stewart House. Among other things, we want to help you quickly find information and provide us with information which is beneficial to your child’s stay with us.
Stewart House is not in the business of selling Personal Information to third parties. We will only record your e-mail address if you send us a message. Your e-mail address will only be used for the purpose for which you have provided it and it will not be added to a mailing list or used for any other purpose without your consent.
The purposes for which information is collected, held, used and disclosed
Stewart House may use and disclose your Personal Information:
(a) for the primary purpose for which it was collected and any related purposes, including where necessary or desirable to:
(i) manage Stewart House’s relationship with you; and,
(ii) obtain professional, technical, administrative or other advice and services in connection to us ensuring quality care for your children during their stay.
(c) for any purpose to which you subsequently consent from time to time.
Third party service providers
Stewart House engages a range of third parties to provide services and perform support functions for us. Some of those third parties such as Stewart House School, the nurse, the dentists, optometrists and audiologists need access to Personal Information in order to provide the services or perform the functions Stewart House requires. Where we share your Personal Information with third-party service providers, they will be contractually bound to use the information only for the purposes of providing the services or performing the functions required by Stewart House and to store the information securely.
This Website does not provide facilities for the secure transmission of information across the internet. Users should be aware that there are inherent risks transmitting information across the internet.
STEWART HOUSE WILL NOT DISCLOSE YOUR PERSONAL INFORMATION TO ANY OUTSIDE ORGANISATION FOR USE IN MARKETING WITHOUT YOUR CONSENT
Your Personal Information (such as name, address and phone number) or your order and the products you purchase will not be given or sold to any outside organisation for its use in marketing or solicitation without your prior express consent.
SECURITY OF PERSONAL INFORMATION
Stewart House will take reasonable steps to protect and secure your Personal Information to ensure your Personal Information is protected from misuse, loss, theft, and unauthorised modification, access or disclosure.
Stewart House takes reasonable steps to destroy or permanently de-identify any Personal Information where:
- Stewart House no longer needs the Personal Information for any purpose for which the Personal Information may be used or disclosed by Stewart House; and
- Stewart House is not required by or under an Australian law, or a court/tribunal order, to retain the Personal Information.
ACCURACY OF PERSONAL INFORMATION
Stewart House will take reasonable steps to ensure that the Personal Information it collects, uses or discloses, is accurate, complete and up to date, and relevant to any proposed use or disclosure. We seek your assistance by asking you to contact us if your Personal Information changes or you believe the information held on file is incomplete.
ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Under the Privacy Act, individuals have a right to complete access to their records. You may (free of charge) request that Stewart House confirm whether it holds any Personal Information about you and, where applicable, request that Stewart House provide you with a copy of your Personal Information. Stewart House will make available to you, in most situations, any Personal Information it holds about you. Stewart House is permitted to charge you for reasonable costs incurred in providing you with access to your information.
In certain circumstances, Stewart House may not be able to provide access, such as where:
- access would have an unreasonable impact on the privacy of others;
- we are required by a law enforcement agency to withhold the information;
- the information may affect current legal proceedings; or
- the information may affect the health or safety of another individual.
If you are able to establish that your Personal Information is not accurate, complete or up to date, Stewart House will take reasonable steps to correct such Personal Information so that it is accurate, complete and up to date. If you and Stewart House are unable to agree about whether your Personal Information is accurate, complete and up to date and you request that Stewart House associate with your Personal Information a statement claiming that such Personal Information is not accurate, complete or up to date, Stewart House will take reasonable steps to do so.
Access to Personal Information collected
Stewart House will not make an attempt to identify users of our website or their browsing activities. However, in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect Stewart House’s or our internet service provider’s logs.
How to make a complaint
If you believe that we have breached this policy, or any of the APPs in the Privacy Act, then you should make a complaint to Stewart House in the first instance. You should address your complaint in writing to our Privacy Officer (contact details are set out below), and you should include as much detail as you can about the Personal Information affected, and the circumstances that you believe amount to a breach of this policy or the APPs.
If you are unhappy with our response to your complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to contact the OAIC are provided on its website at www.oaic.gov.au .
Contacting Stewart House
If you have any questions about Stewart House’s handling of Personal Information, or if you wish to make an access or correction request or complaint, you should contact the Stewart House Privacy Officer by one of the following methods:
02 9338 3100
PO Box 21 Freshwater NSW 2096, Australia