Privacy Policy

1. Purpose
Greenhouse Education is committed to providing quality training and assessment in accordance with
the Standards for Registered Training Organisations (SRTOs 2015). As such, Greenhouse Education is
required to comply with Federal law regarding Privacy and confidentiality of employees, clients and
contractors.
The purpose of this policy is to outline how Greenhouse Education complies with Privacy Act 1988
and Australian Privacy Principles (APPs).
2. Policy Statement
Greenhouse Education is committed to complying with obligation under Privacy Act 1988, and the
associated Australian Privacy Principles (APPs), specifically in the way it collects, uses, secures and
discloses personal information. Greenhouse Education is committed to safeguarding any confidential
information obtained by the RTO.
Greenhouse Education will ensure :
• It maintains and provides a current Privacy Policy;
• Information gathered for the express purpose of training and assessment matters will not
be disclosed to a third party unless prior written consent is provided by the individual
concerned, except that required by law;
• The secure storage of all records;
• The confidentiality of all information maintained on records.
3. Policy Principles
3.1 Legislation
a) Greenhouse Education, although not required to, chooses to abide by the Privacy Act 1988
and associated 13 x Australian Privacy Principles (APPs).
b) The APPs came into force on 12 March 2014 and set out standards, rights and obligations for
the handling, holding, accessing and correction of personal information (including sensitive
information).
3.2 Underpinning Principles
a) Personal Information is defined in the Privacy Act 1988 to mean “information or an
opinion about an identified individual, or an individual who is reasonably identifiable:
i. whether the information or opinion is true or not; and
ii. whether the information or opinion is recorded in a material form or not.
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b) Sensitive Personal Information is defined in the Privacy Act 1988 to mean “information or
an opinion about an individual’s” that is also personal information, such as:
i. racial or ethnic origin; or
ii. political opinions; or
iii. membership of a political association; or
iv. religious beliefs or affiliations; or
v. philosophical beliefs; or
vi. membership of a professional or trade association; or
vii. membership of a trade union; or
viii. sexual orientation or practices; or
ix. criminal record.
3.3 PART 1 – Consideration of Personal Information Privacy
a) Open and Transparent Management of Personal Information.
Greenhouse Education will :
i. Ensure that personal information is managed in an open and transparent way.
ii. Take reasonable steps to implement practices and procedures that will facilitate
dealing with enquiries or complaints from individuals regarding compliance with the
Australian Privacy Principles (APPs).
iii. Ensure that it maintains an up-to-date policy about the management of personal
information.
iv. Ensure that Greenhouse Education Privacy Policy contains the following information:
• The kind of information that is collected and held;
• How the information is collected and held;
• The purposes for which information is collected, held, used and disclosed;
• How an individual may access their personal information that is held by
Greenhouse Education and seek correction of such information as necessary;
• How the individual may make a complaint about a breach of the APPs and
how Greenhouse Education will deal with such a complaint;
• Whether Greenhouse Education is likely to disclose personal information to
overseas recipients, and if so the countries in which such are likely to be
located.
v. Provide the Privacy Policy free of charge and in such form as appropriate, and as is
reasonable.
b) Anonymity and pseudonymity
Greenhouse Education will :
i. Respect that individuals may not wish to identify themselves when making enquiries
on Greenhouse Education products and services;
ii. However, require full personal details as required by law and for identification
purposes from clients.
3.4 PART 2 – Collection of Personal Information
a) Greenhouse Education will not collect personal information form you unless that information
is necessary for one or more of its functions or activities, or is required by law.
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b) Greenhouse Education advises that it is required by law to collect, hold, use and supply
personal information, in accordance with the National VET Provider Collection Data Provision
Requirements.
c) Greenhouse Education will take reasonable steps at or before the time of collection to ensure
that you are aware of:
i. Who we are and how to contact us;
ii. How to gain access to your own information;
iii. The purpose for which the information is being collected;
iv. Any organisation to which we would normally disclose information of that kind;
v. Any law that requires the particular information to be collected;
vi. The main consequences for the individual if all or part of the information is not provided.
d) Greenhouse Education collects information from you in the following ways:
i. When you register your interest on line, apply for enrolment, request certain services or
products, or otherwise contact or do business with us.
ii. Information may be collected from enrolment forms, certified documents, telephone
calls, faxes, emails, letters sent by you.
iii. Information may be collected from third parties, such as other training providers,
regarding confirmation of training and ongoing professional development that you
have attended, as permitted by you.
e) Should Greenhouse Education collect information about you from a third party we will take
reasonable steps to ensure that the individual is or has been made aware of the matters listed
above except to the extent that making the individual aware of the matters would pose a
serious threat to the life or health of any individual.
3.5 PART 3 – Dealing with Personal Information
a) Greenhouse Education will not use or disclose personal or sensitive information for any
purpose other than what it was collected for, unless the relevant person has provided written
consent to use or disclose that information in circumstances that are different to those for
which it was collected.
The circumstances where an exception may occur are:
i. Where the use or disclosure of this information is required or authorised by or under an
Australian law or a court/tribunal order;
ii. The individual would reasonable expect Greenhouse Education to use or disclose the
information for the secondary purpose;
iii. A permitted health situation exists in relation to the use or disclosure of the information
by Greenhouse Education;
iv. A permitted general situation exists in relation to the use or disclosure of the information
by Greenhouse Education;
v. Greenhouse Education reasonably believes that the use or disclosure of the information is
reasonably necessary for one or more enforcement related activities conducted by, or
on behalf of, an enforcement body.
b) Greenhouse Education collects your personal information so as to:
i. Process applications;
ii. Manage your enrolment;
iii. Record and maintain your details;
iv. Administering training programs;
v. Record and maintain details of your ongoing training and assessment;
vi. Provide you with details regarding client services, benefits, and training opportunities;
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vii. Notify you about upcoming events and opportunities;
viii. Gain feedback from you;
ix. Communicate with you;
x. Report to relevant authorities as required by law.
c) Direct Marketing
Greenhouse Education:
i. May use personal information (specifically your name and relevant address details) and
information about your preferences for direct marketing (ie the communication channels
which you prefer for receiving direct marketing from us and the types of products and
services in which you are interested in) so as to let you know about our services and benefits,
where we have your consent.
ii. Provides an opt-out and/or unsubscribe method that is easily accessible for individuals to
request not to receive direct marketing communications.
d) Cross Border Disclosure
Greenhouse Education:
iii. Does not disclose personal information to overseas recipients unless prior written approval is
received by the individual who the personal information relates.
e) Adoption, use or disclosure of Government Related identifiers
Greenhouse Education:
i. Is required by law (Student Identifier Act) to collect, maintain and report to relevant
Government agencies the individual’s Unique Student Identifier (USI) number in accordance
with the National VET Provider Collection Data Provision Requirements.
ii. Will not disclose the Unique Student Identifier (USI) number for any other purpose, including
on any Certification documents you receive.
iii. Must not adopt the Unique Student Identifier (USI) number as its own identifier of the
individual.
3.6 PART 4 – Integrity of Personal Information
a) Quality of personal information
Greenhouse Education will take steps, as are reasonable, to ensure that the personal
information it:
i. Collects is accurate, up to date and complete;
ii. Uses or discloses, is, having regard to the purpose of the use or disclosure, accurate, up
to date, complete and relevant.
b) Security of personal information
Greenhouse Education will take steps, as are reasonable in the circumstances to:
i. Protect the information from misuse, interference and loss as well as unauthorised
access, modification or disclosure.
ii. Destroy the information or to ensure that the information is de-identified.
3.7 PART 5 – Access to, and correction of, Personal Information
a) Greenhouse Education provides all clients with electronic access to their own personal
records, where the individual can update and maintain their own personal information.
b) In some circumstances, Greenhouse Education may not permit access to individuals for their
personal information. If this is ever the case, Greenhouse Education will provide full details
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for the legal reasons for this decision. These may include that Greenhouse Education believes
:
i. That giving access to the information would pose a serious threat to the life, health or
safety of the individual, or to public health or public safety; or
ii. Giving access would have an unreasonable impact on the privacy of other individuals; or
iii. The request for access is frivolous or vexatious; or
iv. The information relates to existing or anticipated legal proceedings between Greenhouse
Education and the individual, and would not be accessible by the process of discovery
in those proceedings; or
v. Giving access would reveal the intentions of Greenhouse Education in relation to
negotiations with the individual in such a way as to prejudice those negotiations; or
vi. Giving access would be unlawful; or
vii. Denying access is required or authorised by or under an Australian law or a court/tribunal
order; or
viii. Both of the following apply:
▪ Greenhouse Education has reason to suspect that unlawful activity, or misconduct
of a serious nature, that relates to Greenhouse Education functions or activities
has been, is being or may be engaged in;
▪ Giving access would be likely to prejudice the taking of appropriate action in
relation to the maters; or
ix. Giving access would be likely to prejudice one or more enforcement related activities
conducted by, or on behalf of, an enforcement body; or
x. Giving access would reveal evaluative information generated within Greenhouse
Education in connection with a commercially sensitive decision-making process.
c) When dealing with requests for access to personal information, Greenhouse Education will:
i. Respond to request for access within 30 days of the request, if from an individual, and
within a reasonable time, if the request is from an organisation; and
ii. Provide access to the information in the manner requested, if it is reasonable and
practicable to do so.
d) Greenhouse Education does not charge a fee for access to personal information. The
exception is re-prints of certification documentation previously supplied.
e) With regard to the correction of personal information held:
i. should Greenhouse Education be satisfied that information is inaccurate, out of date,
incomplete, irrelevant or misleading, Greenhouse Education will take such steps as
reasonable to correct the information to ensure that, having regard to the purpose for
which it is held, the information is accurate, up-to-date, complete, relevant and not
misleading.
ii. Should Greenhouse Education refuse to correct information, Greenhouse Education will
give written notice to the individual that sets out:
▪ The reason for refusal
▪ The mechanisms available to complain about the refusal; and
▪ Any other matter prescribed by the regulations.
4. Greenhouse Education Responsibilities
Director Greenhouse Education ensures that all employees are made aware of this policy and its
underpinning legislative requirements, and comply with this policy at all times.
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Director Greenhouse Education ensures that all clients have access to and awareness of this policy.
5. Records Management
All personal information and records are maintained in accordance with Records Management Policy.
(See Records Management Policy)
6. Monitoring and Improvement
All practices for Privacy are monitored by the Director Greenhouse Educat