Privacy Statement

Administrator

Head of Human Resources

Last Reviewed Date

August 2016

Last Reviewer

Paul Horton

Positions Affected

National ~ All

OEG is committed to complying with the Australian Privacy Principles as detailed in the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988 and subsequent reforms to this act in March 2014 which now frames requirements for privacy provisions of all applicable legislation.

This Privacy Statement outlines how we may collect, use, hold, disclose and otherwise handle personal information in the course of our operations.

  1. What kinds of personal information does OEG collect and hold?
    “Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether recorded in a material form or not. This includes information we have collected from schools, other organisations, students and parents. It should be noted that where information is given by a guardian on behalf of a child that this information is treated as if it had been received from that child and the privacy of the information provided is therefore protected in the same way as for an individual. Generally, the kinds of personal information OEG collects are:

    • contact and identification information such as name, address, telephone number, email address and date of birth;
    • emergency contact details and next of kin;
    • banking and credit card details;
    • sensitive information (e.g. information about health, dietary requirements, injuries, medical history, specific conditions, criminal record) which will only be collected with the consent of the individual;
    • where it concerns an application for a position with OEG, information about an individual’s education and work history, qualifications and skills, and the opinions of others about work performance; and
    • other information required for OEG’s functions and activities.

In some circumstances OEG may also hold other personal information provided by an individual.

  1. How does OEG collect personal information?
    Personal information will be collected directly by an individual who:

    • completes an online or hard copy form in relation to OEG services;
    • in the course of applying for a position with OEG, complete an application for employment form or submit a resume, either online or in hard copy, and/or attends an interview; and
    • otherwise provide OEG with personal information in person or via telephone, email, sms, fax, post or other means, whether at OEG’s request or through an individual’s own initiative.

Personal information may also be collected from a source other than directly from an individual, such as from:

    • educational organisations, e.g. a school or from a child’s school;
    • family members and relatives (e.g. parents);
    • community groups and religious organisations;
    • an individual’s employer or the organisation that an individual works with;
    • sporting groups;
    • external recruitment agencies and background screening providers;
    • for recruitment purposes, from any of former or current employers and work colleagues, professional associations, registration bodies and educational institutions; and
    • agencies that undertake criminal history checks and working with children checks.

Generally, OEG will only collect personal information from sources other than an individual if it is unreasonable or impracticable to collect the personal information from that individual.

  1. Why does OEG need personal information?
    OEG collects, holds, uses and discloses personal information where it is reasonably necessary for the purposes of carrying out its functions and activities, including:

    • booking, organising and administering outdoor experiences for school students and community members, including assessing accommodation needs, catering requirements, and the like;
    • responding to health-related or dietary incidents that may arise;
    • conducting risk assessments and hazard identification;
    • accounting, billing and other internal administrative purposes; assessing an application for employment with OEG or otherwise for the purpose of engaging an individual as a contractor or consultant; and
    • any other legal requirement.

OEG may also use personal information for purposes related to the above purposes and for which an individual would reasonably expect OEG to do so in the circumstances, or where that individual has consented or the use is otherwise in accordance with law.

An individual is under no obligation to provide personal information to OEG. However, without certain information from that individual, OEG may not be able to provide its services. (For example, failing to provide certain information may preclude participation in camps or activities organised and administered by OEG, or in a recruitment context, may limit our ability to consider that individual for employment.)

  1. Disclosure of personal information
    OEG discloses personal information for the purpose for which we collect it. Generally, OEG will only disclose personal information for a purpose set out above. This may include disclosing personal information to:

    • third parties engaged to perform administrative or other business management functions;
    • OEG’s subcontractors, including activity specialists, venue owners, catering contractors, IT contractors and database designers;
    • doctors, hospital and/or police in the event of an emergency incident involving an individual;
    • OEG’s professional advisors and consultants;
    • insurance providers;
    • where an individual is applying for a position with OEG, referees, former employers and colleagues, and relevant bodies that conduct background checks;
    • any other entity with the individuals consent, or to whom disclosure is required or authorised by law.

OEG’s disclosures of personal information to third parties are made on a confidential basis or otherwise in accordance with law. OEG may also disclose personal information with an individual’s consent or if disclosure is required or authorised by law. As OEG is committed to protecting the privacy of individuals, we will view unauthorised disclosure or access to personal information by our employees, contractors or agents as a serious breach of this policy. Appropriate action (which may include disciplinary or legal action) will be taken in such cases.

  1. Overseas disclosure
    OEG may disclose personal information to overseas recipients in order to provide its services and for administrative, data storage (e.g. cloud service providers), recruitment activities or other business management purposes. Recipients of such disclosures are located in Singapore, United Kingdom, United States, Canada, Germany, New Zealand and Kenya but may also be located in other countries. Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, OEG will take reasonable steps in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme, unless an individual consents to the overseas disclosure or it is otherwise required or permitted by law. If an individual has any queries or objections to such disclosures, please contact OEG’s Privacy Compliance Officer (details below).
  2. Direct Marketing
    OEG may use and disclose personal information in order to inform an individual of services that may be of interest. In the event an individual does not wish to receive such communications, that individual can opt-out by contacting OEG via the contact details set out below or through any opt-out mechanism contained in a marketing communication.
  3. Security of personal information
    OEG takes reasonable steps to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. OEG holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff OEG will destroy or de-identify personal information in circumstances where it is no longer required, unless OEG is otherwise required or authorised by law to retain the information.
  4. How to access and correct an individual’s personal information
    OEG takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Act, an individual has a right to access and seek correction of that individual’s personal information that is collected and held by OEG. If at any time an individual would like to access or correct the personal information that OEG holds about that individual or more information on OEG’s approach to privacy is sought, please contact OEG’s Privacy Compliance Officer on the details set out below. OEG will grant access to the extent required or authorised by the Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access to an individual’s personal information:

    • That individual will need to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected; and
    • OEG requests that the individual is reasonably specific about the information required.

If OEG refuses a request to access or correct personal information, OEG will provide written reasons for the refusal and details of complaint mechanisms. OEG will also take steps reasonable in the circumstance to provide access in a manner that meets the individual’s needs and the needs of OEG.OEG will endeavor to respond to requests to access or correct personal information within 30 days from the date of the request.

  1. How to contact us
    For further information or enquiries regarding personal information, or if an individual would like to opt-out of receiving any promotional or marketing communications, please contact OEG’s Privacy Compliance Officer:
    Sara Gaudion
    Head of Human Resources
    The Outdoor Education Group
    109 Goulburn Valley Highway Eildon Vic 3713
    Email: gaudionss@oeg.edu.au
    Telephone: (03) 5770 8215
  2. Privacy complaints
    Please direct all privacy complaints to OEG’s Privacy Compliance Officer. At all times, privacy complaints:

    • will be treated seriously;
    • will be dealt with promptly;
    • will be dealt with in a confidential manner; and
    • will not affect existing obligations or affect the commercial arrangements between an individual and OEG.

OEG’s Privacy Compliance Officer will commence an investigation into each complaint. The individual concerned will be informed of the outcome of the complaint following completion of the investigation. In the event that an individual is dissatisfied with the outcome of the complaint, it can be referred to the Office of the Australian Information Commissioner.

  1. Availability and Review of Policy
    OEG will make its policy available on request and will provide access to this policy on our website. This policy may be amended from time to time at the discretion of OEG and does not form part of the employment contracts of OEG employees.