Acceptable Use Policy
In dealing with personal and sensitive information about individuals, the Catholic Network Australia(CNA) is bound by the Privacy Act 1988 (Cth), the National Privacy Principles (NPPs) in the Privacy Amendment (Private Sector) Act 2000 (Cth) and the Health Records Act 2001 (Vic). This policy describes the way the CNA uses and manages personal information provided to or collected by it in accord with these principles and laws. In this policy a reference to 'information' is a reference to both personal and health information.
Personal information Information or an opinion (whether true or not) about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion. Examples includes names, addresses, telephone numbers, date of birth. Personal information does not include health information.
Health information Any information or opinion about the health or disability of an individual, an individual's expressed wishes about the future provision of health services to him or her or a health service provided, or to be provided to an individual. Examples include health records, certificates, details of medical background, health assessment results.
National Privacy Principles (NPPs) Principles established under the Privacy Amendment (Private Sector) Act 2000 (Cth) that set out minimum standards on how organisations deal with the collection, use and disclosure, transfer, handling and storage of personal information.
Sensitive information 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. Sensitive information includes health information about an individual.
Identifier A number assigned to an individual to identify uniquely that individual for the purposes of an organisation's work, e.g. a Medicare number. Unique identifiers are used to facilitate data matching. As data matching can reduce privacy, organisations are required under the NPPs to limit the creation and use of identifiers.
Privacy The CNA respects the right of an individual to have their personal and health information protected.
The following procedures describe the ways in which the CNA collects, protects and uses information about individuals that is collected by or supplied to it.
- Collection and storage of personal information
The CNA collects information from individuals to assist it in its work of advising and supporting Catholic schools in the Archdiocese of Melbourne. In compliance with the relevant legislation, the CNA only collects information that is necessary in order for it to perform one or more of its functions or activities.
The CNA collects information by way of forms filled out by an individual, face-to-face meetings, interviews or telephone calls. In accordance with the NPPs, the CNA will ensure that the individual supplying the information is told why the information is being collected and the organisations (or the types of organisations) to which it usually discloses the information it collects.
In some circumstances the CNA may be provided with information about an individual from a third party, for example, information provided by a health professional or from another employer or source.
The type of information that the CNA collects includes (but is not limited to) information, including sensitive information, about:
- students and parents and/or guardians (parents) before, during and after the course of a student's enrolment at a Catholic school in the Archdiocese of Melbourne
- job applicants, staff members, volunteers and contractors; and
- other people who come into contact with the CNA.
The CNA will take reasonable steps to protect information it holds from misuse, loss, unauthorised access, modification or disclosure. Internal procedures have been developed and staff training has been provided to ensure the privacy of this information.
In accordance with the NPPs, the CNA does not use identifiers assigned by another organisation or an agent of another organisation to identify individuals for the purposes of its work.
The NPPs do not apply to an employee record. As a result, this policy does not apply to the CNA's treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the CNA and an employee.
Use and disclosure of personal information
The CNA uses personal information about pupils and parents to:
- assist with pupils' wellbeing
- satisfy the CNA's accountability and legal obligations and allow the CNA to discharge its duty of care.
The CNA uses personal information about job applicants, staff members, contractors and volunteers for:
- assessing an individual's suitability for employment or for work as a volunteer
- administering the individual's employment or contract, as the case may be
- insurance purposes
- satisfying the CNA's legal obligations, for example, in relation to child protection legislation.
The CNA will use and disclose information only for the purpose for which it was collected (the primary purpose) or a related secondary purpose that the individual would reasonably expect, or to which they have consented. A secondary purpose may include the use of personal information to develop a case for funding increases for targeted groups of students.
- Access to personal information
- Access by the individual to information about them
Under the relevant privacy legislation, an individual may seek access to information held about him or her and parents may seek access to information held by the CNA about their child. The CNA may require verification of identity and details of the information required.
Generally, the CNA will refer any requests for consent and notices in relation to the personal information of a student to the student's parents. The CNA will treat consent given by parents as consent given on behalf of the student and notice to parents will act as notice given to the student.
There will be occasions when access is denied. Such occasions would include where release of information would have an unreasonable impact on the privacy of others, or where the release may result in a breach of the CNA's duty of care to a student.
The CNA may, at its discretion, on the request of a student, grant that student access to information held by the CNA about him/her, or allow a pupil to give or withhold consent to the use of his/her personal information, independently of his/her parents. This would normally be done only when the maturity of the student and or/the student's personal circumstances so warranted.
- Access by another organisation or individual to information held by the CNA.
Enquiries and complaints For information about the way CNA manages personal information, requests by an individual to access personal information, or complaints in relation to the collection or use of personal information or access to personal information held by the CNA please contact:
The CNA may disclose information, including sensitive information, held about an individual to:
- a school
- another Catholic education office
- government departments
- health practitioners
- professionals providing a service to the CNA
- recipients of CNA publications (such information being de-identified prior to use)
- anyone you authorise the CNA to disclose information to.
The CNA will not send personal information about an individual outside Australia without:
- obtaining the consent of the individual (may be implied) or
- otherwise complying with the relevant legislation.
The CNA endeavours to ensure that the personal information it holds is accurate, complete and up to date. A person may seek to update the information held by the CNA about them by contacting the CNA at any time.