WEBSITE PRIVACY POLICY

Key 2 Learning Pty Ltd, is a Registered Training Organisation with responsibility for delivering vocational education and training. Key 2 Learning Pty Ltd collects and stores personal information on our students. Key 2 Learning Pty Ltd complies with the Privacy Act 1988 (Commonwealth). This policy describes how Key 2 Learning Pty Ltd collects, manages, uses, discloses, protects, and disposes of personal information in accordance with the thirteen Australian Privacy Principles outlined in Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

AUTHORITY TO COLLECT AND STORE INFORMATION

Key 2 Learning Pty Ltd is an approved Registered Training Organisation by the Australian Skills Quality Authority, RTO number 88191. This registration is issued under the authority of the National Vocational Education and Training Regulator Act 2011. This legislation requires Key 2 Learning Pty Ltd to collect personal and sensitive information from its students. This requirement is specified in the Data Provision Requirements 2011 which is one of four legislative instruments that Key 2 Learning Pty Ltd must comply with as a condition of its registration.

The date provision requirements require Key 2 Learning Pty Ltd to collect data from students in accordance with the Australian Vocational Education and Training Management Information Statistical Standard (AVETMISS). This is a complex information standard that defines information about who the student is, where the training is delivered and what they are studying. The Standards for Registered Training Organisations require Key 2 Learning Pty Ltd to retain and store this information for up to 30 years and to report training activity to government agencies in accordance with mandatory reporting requirements. Together these requirements form a statutory obligation to collect, store and report information of any student participating in nationally accredited training.

COLLECTION AND USE

Key 2 Learning Pty Ltd collects personal information, either directly or indirectly, that is reasonably necessary for, or directly related to its delivery of the services it offers. Some of the information collected may be regarded as ‘sensitive’ as defined by the Privacy Act. In broad terms the kinds of personal information and purposes for which it is collected are:

• Contact information such as name, organisation, position, address, telephone, and email are collected for marketing, support services, mandatory reporting and for communicating with stakeholders as part of our day to day operation.
• In addition to information collected for training activity, Key 2 Learning Pty Ltd will also collect, store and report information relating to satisfaction surveys, complaint handling and our client employers.

COLLECTION AND USE

• Student’s personal and sensitive information as well as training activity information is prescribed by the AVETMISS Standard. This information is collected directly from our students using enrolment forms which may be paper based or electronic and other administrative forms including but not limited to complaint forms, recognition application, request for refund, transfer application, etc. Much of this information is entered into our student management software. Paper-based records are electronically scanned and retained within our student files.
• Survey responses are collected using SurveyMonkey, a surveying tool. Survey responses are also recorded in our student management system.
• Enquiry information from prospective students including personal contact information is collected directly from individuals who make data requests either by telephone or email, in person or via our website.

SENSITIVE INFORMATION

Personal information collected by Key 2 Learning Pty Ltd that may be regarded as ‘sensitive’ under the Privacy Act includes:

• ‘Disability’ and ‘long-term impairment status’ (health); and ‘indigenous status’, ‘language spoken at home’, ‘proficiency in spoken English’, ‘country of birth’ (implies ethnic/racial origin). This information is specified in the AVETMISS data elements and is collected for the national VET data collections, national VET surveys, and may be collected for VET-related research.

GOOGLE ANALYTICS AND COOKIES

Google Analytics is a web service provided by Google Inc. Cookies are used to generate data on website activity and usage. The cookies, which include IP addresses, are transmitted to and stored in Google servers in the United States where they are used to compile web-use reports. Google may transfer this information to third parties, where required by law, or for information processing on its behalf. Google will not associate IP addresses with any other data held by Google. More information on Google’s privacy policy can be found at: https://www.google.com.au/intl/en/policies/privacy/. It is possible to disable cookies by adjusting web-browser setting and to opt-out of Google Analytics (https://tools.google.com/dlpage/gaoptout). Doing so, however, may affect web-site functionality. The Key 2 Learning Pty Ltd web servers automatically log information such as server address, date and time of visit and web pages accessed. No personal information is recorded. These logs are used for website management and improvement.

UNSOLICITED PERSONAL INFORMATION

If Key 2 Learning Pty Ltd should receive unsolicited personal information, it will be treated and managed according to the Australian Privacy Principles.

NOTIFICATION OF COLLECTION

Key 2 Learning Pty Ltd aims to notify individuals of the collection of their personal information before, or at the time of collection, or as quickly as possible thereafter. Notifications are usually in writing, but may be verbal for telephone help-desk services, or research conducted by telephone interview.

• Marketing – notification is provided on our website course application page. Individuals are also notified at the time of collecting personal information for events.
• Quality Indicator surveys – notification is provided in the invitation to participate in the surveys.

DISCLOSURE OF PERSONAL INFORMATION

• Key 2 Learning Pty Ltd does not disclose personal information other than for the purpose for which it was collected, or an individual has consented to a secondary purpose, or an individual would reasonably expect this (such as receiving communications about upcoming events), or if required by law.
• Key 2 Learning Pty Ltd may share personal information with the Commonwealth government in accordance with Commonwealth contractual obligations. In these circumstances Key 2 Learning Pty Ltd will take reasonable steps to inform and seek consent from the individuals concerned and take all reasonable steps to ensure that the recipient handles the personal information according to the Australian Privacy Principles.
• Key 2 Learning Pty Ltd does not sell its mailing lists to third-parties for marketing purposes.
• Key 2 Learning Pty Ltd does not disclose personal information to overseas recipients. While people around the world can access material published on our website, no statistical or research publications contain identifiable personal information.

MANAGEMENT OF PERSONAL INFORMATION

Key 2 Learning Pty Ltd endeavors to ensure the personal information it collects and uses or discloses is accurate, up to date, complete and relevant. Key 2 Learning Pty Ltd routinely updates the information held in its customer relationship management system. In addition, Key 2 Learning Pty Ltd will periodically check with stakeholders to see if their personal contact details have changed.

ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

Individuals may, subject to the exceptions prescribed by the Australian Privacy Principles, request access to and correction of their personal information where this is collected directly from individuals by Key 2 Learning Pty Ltd.

Key 2 Learning Pty Ltd does not charge for giving access to or for correcting personal information. Requests for access to or correction of personal information should be made in writing. Requests will be answered within 14 business days.

INFORMATION RETENTION AND DISPOSAL

Personal information is held in electronic and paper format:

• Information collected from student enrolment applications, survey responses and during the delivery of services is held in our student management system.
• Names and contact details of stakeholders are held in our student management system and email contact lists.
• Backup copies of all electronic files held in Key 2 Learning Pty Ltd’s systems are kept in the event of system failure/loss. All backup copies of system files are secured.

Key 2 Learning Pty Ltd retains personal information for up to 30 years. When personal information is no longer necessary for Key 2 Learning Pty Ltd’s business functions, and it is lawful to do so, Key 2 Learning Pty Ltd destroys the information.

INFORMATION SECURITY

Key 2 Learning Pty Ltd takes active steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

• Key 2 Learning Pty Ltd’s systems and internal network are protected from unauthorised access using appropriate technologies.
• Access to the student management system is protected through user log-on and password, and assignment of user access rights.
• Third-party providers used by Key 2 Learning Pty Ltd for the delivery of services are all located within Australia and are required to be compliant with the Australian Privacy Principles and offer appropriate safeguards to protect personal information.
• Key 2 Learning Pty Ltd’s premises and data storage systems are fully secured. Paper documents containing names and addresses are required to be shredded when destroyed. All hardware is properly ‘sanitised’ before disposal.

COMPLAINTS AND CONCERNS

Complaints or concerns about Key 2 Learning Pty Ltd’s management of personal information should be directed in writing to Key 2 Learning Pty Ltd’s Chief Executive Officer. Key 2 Learning Pty Ltd will respond in writing within 14 business days.