Privacy Policy - Think Education

Purpose of collecting and holding personal information

THINK collects and holds personal information for the purpose of providing educational products and services and requests information to manage and administer those products and services. When THINK collects personal information about individuals who are not students, THINK generally does so for the purposes for which the information was provided. All appropriate personal information will be held by THINK to satisfy record-keeping obligations.

Anonymity

THINK will provide individuals with the option of remaining anonymous or using a pseudonym in their dealings with THINK where it is lawful and practicable (for example, when making an enquiry). Generally is it not practicable or lawful for THINK to deal with individuals anonymously or pseudonymously on an ongoing basis (for example, if the individual wishes to enrol in a course of study).

Security of Information

THINK maintains personal information in paper-based and electronic records and systems. Personal information may be collected in paper-based documents and converted to electronic form for storage (with the paper-based document either being archived or securely destroyed). Archived records are stored at an external storage facility in Australia and information held in electronic form is generally held on servers controlled by THINK in Australia. THINK uses physical security, password protection and other measures to ensure that all personal information is protected from misuse, interference and loss; and from unauthorised access, modification and disclosure.

Use and disclosure of personal information

THINK uses and discloses personal information for the purposes disclosed at the time of collection, or otherwise as set out in this Policy. Personal information will not be used or disclosed for any other purposes, unless consent has been given or THINK is authorised or required to do so by law.

Personal information will generally only be used or disclosed as follows:

• To provide the products, services or information requested from THINK (including enrolment, assessment and issuing certificates of completion and testamurs).
• • Personal information may also be disclosed to third parties (where applicable) to assist THINK with functions such as recruitment of students, work integrated learning placements or providing overseas student health cover
• To register and administer events, promotions or competitions
• To verify personal information details upon request from third parties, such as completion of courses, a request from a potential employer verifying a qualification and further enrolment into another institution
• To comply with THINK’s legal and regulatory obligations, including disclosure and reporting to Commonwealth, State and Territory government agencies for planning, evaluative, administrative and funding purposes. This may include:
• • disclosure and reporting to Commonwealth and State government agencies (including State Training Authorities) for the purpose of administrating entitlements to financial assistance under Commonwealth and State government programs for supporting students, such as FEE-HELP and VET FEE HELP/VET Student Loans
  • disclosure to government agencies responsible for administrating and regulating education and training providers in Australia, such as Tertiary Education Quality and Standards Agency (TEQSA), Australian Skills Quality Authority (ASQA), Tuition Protection Service (TPS), and
  • disclosure to government agencies with responsibility for administering immigration and student visa arrangements (including disclosure of suspected breaches of student visa conditions)
• For students under 18, information regarding attendance, progress and general well-being may be provided in order to keep parent(s) and/or guardian(s) adequately informed
• To assist THINK to make its sites, service and products more accessible and valuable to students
• To perform various administrative or management functions including administering billing and debt recovery; training of staff and contractors and managing their work performance and career progression, quality assurance and evaluation; maintenance and testing of information technology systems; obtaining advice from consultants and professional advisers; management of legal liabilities and claims (including liaising with legal representatives and insurers)

Direct Marketing

THINK uses and discloses the personal information it collects for direct marketing purposes.

Individuals may contact THINK to request not to receive direct marketing communications. Direct marketing may include providing individuals with information regarding products, services and new developments. If an individual does not wish to receive marketing material, please note THINK will still contact them in relation to the ongoing relationship. For example, THINK will still send individuals invoices and information that are relevant to their course of study.

Disclosure of information to overseas recipients

Unless consent has been given or an exception to the Australian privacy principles apply, THINK will only disclose personal information to overseas recipients where reasonable steps have been taken to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

Access and Correction of Personal Information

For simple enquiries regarding personal information (such as confirming current contact details or confirming results) please contact the relevant Student Services team. To request access to personal information, please contact THINK’s designated Privacy Officer at privacy@think.edu.au. In limited circumstances, access to personal information may be declined in accordance with the Australian Privacy Principles.

THINK endeavours to keep all personal information accurate, up-to-date and complete; however, if information held by THINK is considered to be inaccurate, out-of-date, incomplete, irrelevant or misleading, a request can be made for a correction of the information. Please contact THINK’s designated Privacy Officer at privacy@think.edu.au. After receiving such a request, THINK will take reasonable steps to correct the information.

A request to remove or delete personal information may not be possible to comply with where the personal information must be retained by THINK for a period specified by applicable legislative and regulatory requirements. THINK may refuse a request to access, correct or delete personal information in certain circumstances. In such instances, THINK will provide a reason for the decision.

Enquiries and Complaints

All privacy enquiries and complaints should be directed in writing to the Privacy Officer using the Request for Access to Personal Information form. THINK will respond to a complaint within a reasonable period of time. The contact details for THINK are:

Privacy Officer
Think Education Group
Level 24, 680 George Street, Sydney NSW 2000
www.think.edu.au
privacy@think.edu.au

If THINK’s response to a complaint is unsatisfactory or it is believed that THINK may have breached the Australian Privacy Principles or the Privacy Act, a complaint can be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

DATA PROTECTION AND PRIVACY

Hani Skaf is our Data Protection and Privacy Officer (DPO). As DPO, Hani will be responsible for encouraging, training and advising on compliance with privacy laws, liaising with the respective Privacy Commissioners or supervisory authorities (as required) and monitoring data protection impact assessments where requested. Please direct any queries to him at hskaf@laureate.net.au.