Our policy is consistent with National Privacy Principles (NPPs) and abides by the provisions of the Privacy Act 1988.
- Collecting Information
Training Management Pty Ltd only collect personal information that is necessary for one or more of our functions or activities.
We collect personal information only by lawful and fair means and not in an unreasonably intrusive way.
At or before the time (or, as soon as practicable after) we collect personal information about an individual from the individual, we take reasonable steps to ensure that the individual is aware of:
- who we are and how to contact us;
- he fact that they are able to gain access to the information;
- the purposes for which the information is collected;
- the organisations (or the types of organisations) that we usually disclose information of that kind;
- any law that requires the particular information to be collected;
- the main consequences (if any) for the individual if all or part of the information is not provided.
If it is reasonable and practicable to do so, we collect personal information about an individual only from that individual.
- Use and disclosure
We do not use or disclose personal information about an individual for a purpose (the secondary purpose) other than the primary purpose of collection unless:
- the individual has consented to the use or disclosure;
- if the information is not sensitive information and the use of the information is for the secondary purpose of direct marketing:
- it is impracticable for us to seek the individual’s consent before that particular use;
- the individual has not made a request to us not to receive direct marketing communications;
- in each direct marketing communication with the individual, we draw to the individual’s attention, or prominently display a notice, that he or she may express a wish not to receive any further direct marketing communications;
- each written direct marketing communication by us to the individual (up to and including the communication that involves the use) sets out our business address and telephone number and, if the communication with the individual is made by fax, email or other electronic means, a number or address where we can be directly contacted electronically;
- we have reason to suspect that unlawful activity has been, is being or may be engaged in, and use or disclose the personal information as a necessary part of an investigation of the matter or in reporting concerns to relevant persons or authorities;
- the use or disclosure is required or authorised by or under law;
- we reasonably believe that the use or disclosure is necessary for the protection of public revenue.
- Data quality
We take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date.
- Data security
We take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure.
We take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed.
We have a document that clearly summarises our privacy obligations to individuals and organisations. We include this with information we provide to our clients when offering our services.
On request by a person, we take reasonable steps to let the person know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information.
- Access and correction
If we hold personal information about an individual, we will provide the individual with access to the information on request, except to the extent that:
- providing access would have an unreasonable impact upon the privacy of other individuals; or
- the request for access is frivolous or vexatious; or
- providing access would be unlawful.
We do not charge fees for providing access to personal information.
If we hold personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date, we will take reasonable steps to correct the information so that it is accurate, complete and up-to-date.
If we disagree with the individual about whether the information is accurate, complete and up-to-date, and the individual asks us to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, we will take reasonable steps to do so.
We will provide reasons for denial of access or a refusal to correct personal information.
Wherever it is lawful and practicable, individuals must have the option of not identifying themselves when entering transactions with us.
- Sensitive information
We do not collect sensitive information about an individual unless:
- the individual has consented; or
- the collection is required by law.
- Definition of Key Terms
Access – this involves us giving an individual information about themselves that we hold. Giving access may include allowing an individual to inspect personal information or giving them a copy.
Collection – we collects personal information if we gather, acquire or obtain personal information from any source and by any means. Collection includes when we keep personal information that we come across by accident or have not asked for.
Consent – consent means voluntary agreement to release information. It has two elements: knowledge of the matter agreed to, and voluntary agreement. Consent can be express or implied. Express consent is given explicitly, either orally or in writing. Implied consent arises where consent may reasonably be inferred in the circumstances from the conduct of the individual and us. Consent is invalid if there is extreme pressure or coercion.
Contractors – the Privacy Act treats the acts and practices of employees (and those in the service of Training Management Pty Ltd) in performing their duties of employment as those of Training Management Pty Ltd. Contractors performing services for us are not considered to fall within this provision unless our relationship with them means that the actions of the contractor could be treated as having been done by us.
Disclosure – in general terms we disclose personal information when we release information to others outside of Training Management Pty Ltd. It does not include giving individuals information about themselves (this is “access” see above).
Personal information – personal information is information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. It includes all personal information regardless of its source.
Our policy applies to the collection of personal information by us for inclusion in a record or a generally available publication, but apart from this, our policy applies to personal information we have collected and hold in a record.
Sensitive information – sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record or health information about an individual.
Use In general terms, use of personal information refers to our handling of personal information, including “the inclusion of information in a publication”.
- Records and Associated Material
Client Enrollment Form
Internal Quality Review Procedure
Evaluation and Review
Employee and Contractor Details