Updated on 01 July 2020
Edna (“Edna,” “us,” “we,” or “our”) is an Australian-based organisation which complies with all relevant Australian Commonwealth, State and Territory legislation and regulatory requirements relevant to our operations, including the Australian Privacy Principles as outlined in the Privacy Act 1988. We also conform to the General Data Protection Regulation 2016 (EU), California Consumer Privacy Act (California, USA), and the Children’s Online Privacy Protection Act (USA), as eventhough we are an Australian-based organisation, our students come from all over the world.
If you reside or are located in the European Economic Area, Edna is the data controller of all Personally Identifiable Information – that is information that can be used to identify you, herewith known as personal information. Personal information can include information such as your name, e-mail address, IP address and device identifier, among other things.
2. Scope and definitions
The scope of this policy includes:
- collection and use of personal information
- security and integrity of personal information
- children under 13
- rights to access and updating records
- external links
- concerns, questions or problems
- our use of your personal information is necessary to perform our obligations under any agreement with you;
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests such as to run, grow and develop our business; operation our website and provide our services; select appropriately skilled and qualified suppliers; build relationships with partners and education providers; carry out research and statistical analysis; carry out marketing and business development; and for internal administrative and auditing purposes; or
- use of your personal information is necessary for the legitimate interests of others; or
- consent, to send you certain communications or where you submit certain information to us.
Under the Privacy Act 1988 and Privacy Amendment (Enhancing Privacy Protection) Act 2012 (s6(1)), personal and sensitive information is defined as follows:
- Personal information: “information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.”
- Sensitive information: “(a) information or an opinion about an individual’s: (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 preferences or practices, or (ix) criminal record, that is also personal information; or (b) health information about an individual; or (c) genetic information about an individual that is not otherwise health information; or (d) biometric information that is to be used for the purposes of automated biometric verification or biometric identification; or (e) biometric templates”.
3. Collection and use of personal information
Edna collects personal information, either directly or indirectly, that is reasonably necessary for, or directly related to its delivery of the services it offers. Some of the information collected may be regarded as ‘sensitive’ as defined by the Privacy Act 1988.
Personal information collected by us may include (but is not limited to):
- e-mail address;
- contact details;
- education history;
- course enrolment details; and
- information about your work history or career aspirations and interests.
Edna will only collect personal information from you by fair and lawful means which is necessary for our operations. We will only collect sensitive information with the consent of the individual and if that information is reasonably necessary for our operations.
If an individual chooses not to give us certain pieces of information, we may not be able to enrol the said individual into one of our courses or supply them with the appropriate information.
We may also receive personal information when you:
- send us an e-mail, a chat message or other forms of communications;
- access or log-into a third party site (such as Facebook) from our website;
- provide information in response to a survey;
- use a partner education provider site or service (such as enrolling in a Diploma program through an Australian Registered Training Organisation); and/or
- use our credit card processing provider – please note that our credit card processing provider, not us, collect and process your credit card information. Edna does not collect, process or store this information.
We also collect the following information when you use our website:
- Google Analytics – to help us analyse how you use our website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information is used to create reports about the use of our websites. Google is the party that stores this information and we will not use Google Analytics to track or collect any personal information of visitors to our websites. we will not associate any data gathered from the websites with any personal information from any source as part of our use of Google Analytics. If you do not want your website visit data reported on by Google Analytics, you can install the Google Analytics opt-out browser add-on here.
If Edna should receive any unsolicited personal information, it will be treated and managed according to the Australian Privacy Principles.
4. Security and integrity of your personal information
Edna is committed to ensuring the confidentiality, security and integrity of the personal information we collect, use and disclose. We will take all reasonable steps to ensure that any personal information collected is relevant to the purpose for which it was collected for, is accurate, up-to-date, and complete. We will store all records containing your personal information securely and take all reasonably practicable security measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Your personal information is held in electronic format on our database. Our systems and internal networks are protected from unauthorised access by using appropriate technologies. Most system data transferred over the internet is protected by a Secure Socket Level protocol (SSL). The inherent risks associated with data transmission over the internet are, however, commonly acknowledged.
Third-party providers used by Edna for the delivery of services are required to be compliant with the Australian Privacy Principles (or their local Privacy Laws) and offer appropriate safeguards to protect personal information.
You consent to us using your personal information for sending you information, including promotional material, about us or our services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, telemarketing, e-mail, and SMS messages.
If you do not wish to receive marketing information from us, you can opt-out from receiving such material by clicking on the ‘Unsubscribe’ link in a direct marketing e-mail that you have received from us, or contacting us using our Contact Us page and advising that you would like to opt-out of a particular marketing channel or from all direct marketing communications from us.
6. Children under 13
Edna strongly believes in protecting the privacy of children. Whilst we are an Australian-based organisation, our students come from all over the world. This means that we comply with the laws of the land in which our student is based in. Therefore, in accordance with the United States Children’s Online Privacy Protection Act (“COPPA”), we will outline our practices regarding collecting children’s personal information.
We collect information about students directly from their parents, who provide us with the child’s name, age, type of schooling, location and other relevant information to help us provide appropriate educational services to the child. No information is collected directly from children except during the delivery of the course, such as when they share information about themselves with the Instructor and the rest of their class voluntarily. Children also are not to post personal information publicly on our website.
The personal information we collect from parents about their child(ren) are used to enable us to appropriately deliver the education and training services to their child(ren). This information is treated as part of the Parent’s Personal Data and may be shared as described in Section 3 – Collection and Use of Personal Information.
Whilst we expect Instructions and all other users to abide by our standards of conduct, please note that we cannot control or monitor what personal information a child shares with their Instructors or classmates, nor what those third-parties ultimately do with that information. Edna disclaims all responsibility in that regard.
Edna will obtain parental consent before collecting any personal information from your child. If you do not consent, then we will not collect, use or disclose any personal information about your child, and your child will not be permitted to use our services in any way.
At any time, you can refuse to permit us to collect further personal information from your child(ren) and can request that we delete from our records the personal information we hold of your child(ren). Please keep in mind that a request to delete records may lead to a termination of any services previously or currently being provided to you and your child(ren).
7. Rights to access and updating records
Individuals have the right to access the personal information that Edna holds about them. Requests to access or obtain a copy of your personal information must be made in writing and there is no charge for you to access the information that we keep about you. However, we may charge a fee to make a physical copy.
If an individual considers your personal information to be incorrect, incomplete, out-of-date, or misleading, you can request that the information be amended. Where a record is found to be inaccurate, a correction will be made as soon as practical. Where an individual requests that a record be amended because it is inaccurate, but the record is found to be accurate, the details of the request for amendment will be noted, and the record will not be revised.
8. External links
9. Concerns, questions or problems
If you reside or are located in the EEA, you may also make a complaint to the supervisory body for data protection matters, the UK Information Commissioner’s Office, or seek a remedy through local courts if you believe your rights have been breached.