Certificate IV in Building and Construction

Privacy Policy Statement

BACK TO BASICS BUSINESS TRAINING PTY LTD

AUSTRALIAN PRIVACY PRINCIPLES POLICY

Back to Basics Business Training Pty Ltd is committed to maintaining the privacy and confidentiality of its RTO personnel and participant records. BACK TO BASICS BUSINESS TRAINING PTY LTD complies with the Privacy Act 1988 including the 13 Australian Privacy Principles (APPs) as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

As a component of our risk management practices, Back to Basics Business Training Pty Ltd has conducted a Privacy Impact Assessment for all operations. Mitigation actions from this risk assessment have been implemented for the management of privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction and de-identification.

Providing an overall framework for our privacy practices, Back to Basics Business Training Pty Ltd has developed and implemented this APP Privacy Policy.

Back to Basics Business Training Pty Ltd manages personal information in an open and transparent way. This is evident in the implementation of practices, procedures and system we outline in this policy, that ensure our compliance with the APPs and any binding registered APP code, and provide suitable procedures for Back to Basics Business Training Pty Ltd personnel to be able to deal with related inquiries and complaints that may be received from time to time.

The following sections of this policy outline how we manage personal information.

Australian Privacy Principle 1 - Open and transparent management of personal information

Purposes for information collection, retention, use and disclosure

Back to Basics Business Training Pty Ltd retains a record of personal information about all individuals with whom we undertake any form of business activity. Back to Basics Business Training Pty Ltd must collect, hold, use and disclose information from our clients and stakeholders for a range of purposes, including but not limited to:

As a government registered training organisation, regulated by the Australian Skills Quality Authority, Back to Basics Business Training Pty Ltd is required to collect, hold, use and disclose a wide range of personal and sensitive information on participants in nationally recognised training programs. This information requirement is outlined in theNational Vocational Education and Training Regulator Act 2011 and associated legislative instruments.

In particular, the legislative instruments:

It is noted that Back to Basics Business Training Pty Ltd is also bound by various State Government Acts requiring similar information collection, use and disclosure (particularly Education Act(s), Vocational Education & Training Act(s) and Traineeship & Apprenticeships Act(s) relevant to state jurisdictions of Back to Basics Business Training Pty Ltd operations).

It is further noted that, aligned with these legislative requirements, Back to Basics Business Training Pty Ltd delivers services through a range of Commonwealth and State Government funding contract agreement arrangements, which also include various information collection and disclosure requirements.

Individuals are advised that due to these legal requirements, Back to Basics Business Training Pty Ltd discloses information held on individuals for valid purposes to a range of entities including:

Kinds of personal information collected and held

The following types of personal information are generally collected, depending on the need for service delivery:

The following types of sensitive information may also be collected and held:

Where Back to Basics Business Training Pty Ltd collects personal information of more vulnerable segment of the community (such as children), additional practices and procedures are also followed. Please refer to Back to Basics Business Training Pty Ltd’sWorking with Children Policy and Procedures for further information.

How personal information is collected

Back to Basics Business Training Pty Ltd’s usual approach to collecting personal information is to collect any required information directly from the individuals concerned. This may include the use of forms (such as registration forms, enrolment forms or service delivery records) and the use of web based systems (such as online enquiry forms, web portals or internal operating systems).

Back to Basics Business Training Pty Ltd does receive solicited and unsolicited information from third party sources in undertaking service delivery activities. This may include information from such entities as:

How personal information is held

Back to Basics Business Training Pty Ltd’s usual approach to holding personal information includes robust storage and security measures at all times. Information on collection is:

Only authorised personnel are provided with login information to each system, with system access limited to only those relevant to their specific role. Back to Basics Business Training Pty Ltd ICT systems are hosted internally with robust internal security to physical server locations and server systems access. Virus protection, backup procedures and ongoing access monitoring procedures are in place.

Destruction of paper based records occurs as soon as practicable in every matter, through the use of secure shredding and destruction services at all Back to Basics Business Training Pty Ltd sites.

Individual information held across systems is linked through a Back to Basics Business Training Pty Ltd allocated identification number for each individual.

Retention and Destruction of Information

Back to Basics Business Training Pty Ltd maintains a Retention and Disposal Schedule documenting the periods for which personal information records are kept.

Specifically for our RTO records, in the event of our organisation ceasing to operate the required personal information on record for individuals undertaking nationally recognised training with us would be transferred to the Australian Skills Quality Authority, as required by law.

Accessing and seeking correction of personal information

Back to Basics Business Training Pty Ltd confirms all individuals have a right to request access to their personal information held and to request its correction at any time. In order to request access to personal records, individuals are to make contact with:

BACK TO BASICS BUSINESS TRAINING PTY LTD Privacy Officer

1300 855713

Contact Us

A number of third parties, other than the individual, may request access to an individual’s personal information. Such third parties may include employers, parents or guardians, schools, Australian Apprenticeships Centres, Governments (Commonwealth, State or Local) and various other stakeholders.

In all cases where access is requested, Back to Basics Business Training Pty Ltd will ensure that:

Complaints about a breach of the APPs or a binding registered APP code

If an individual feels that Back to Basics Business Training Pty Ltd may have breached one of the APPs or a binding registered APP Privacy Complaints Procedure below for further information.

Likely overseas disclosures

Back to Basics Business Training Pty Ltd it is an Australian Based Company only with no overseas Business partnerships.

Making our APP Privacy Policy available

Back to Basics Business Training Pty Ltd provides our APP Privacy Policy available free of charge, with all information being publicly available from the Privacy link on our websites at https://constructioncourses.com.au/privacy-policy/; http://patientcaretraining.com.au/privacy-policy/; http://civilconstructioncourses.com.au/privacy-policy/; https://builderscourse.com.au/privacy-policy.html and http://tradecontractorlicence.com.au/privacy-policy.html

This website information is designed to be accessible as per web publishing accessibility guidelines, to ensure access is available to individuals with special needs (such as individuals with a vision impairment).

In addition, this APP Privacy Policy is:

If, in the unlikely event the APP Privacy Policy is not able to be provided in a particular format requested by an individual, we will explain the circumstances around this issue with the requester and seek to ensure that another appropriate method is provided.

Review and Update of this APP Privacy Policy

Back to Basics Business Training Pty Ltd reviews this APP Privacy Policy:

Where this policy is updated, changes to the policy are widely communicated to stakeholders through internal personnel communications, meetings, training and documentation, and externally through publishing of the policy on Back to Basics Business Training Pty Ltd’s website and other relevant documentation (such as our RTO Handbook) for clients.

Australian Privacy Principle 2 - Anonymity and pseudonymity

Back to Basics Business Training Pty Ltd provides individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us in relation to a particular matter, whenever practical. This includes providing options for anonymous dealings in cases of general course enquiries or other situations in which an individuals’ information is not required to complete a request.

Individuals may deal with us by using a name, term or descriptor that is different to the individual’s actual name wherever possible. This includes using generic email addresses that does not contain an individual’s actual name, or generic user names when individuals may access a public component of our website or enquiry forms.

Back to Basics Business Training Pty Ltd only stores and links pseudonyms to individual personal information in cases where this is required for service delivery (such as system login information) or once the individual’s consent has been received.

Individuals are advised of their opportunity to deal anonymously or by pseudonym with us where these options are possible.

Requiring identification

Back to Basics Business Training Pty Ltd must require and confirm identification however in service delivery to individuals for nationally recognised course programs. We are authorised by Australian law to deal only with individuals who have appropriately identified themselves. That is, it is a Condition of Registration for all RTOs under theNational Vocational Education and Training Regulator Act 2011 that we identify individuals and their specific individual needs on commencement of service delivery, and collect and disclose Australian Vocational Education and Training Management of Information Statistical Standard (AVETMISS) data on all individuals enrolled in nationally recognised training programs. Other legal requirements, as noted earlier in this policy, also require considerable identification arrangements.

There are also other occasions also within our service delivery where an individual may not have the option of dealing anonymously or by pseudonym, as identification is practically required for us to effectively support an individual’s request or need.

Australian Privacy Principle 3 - Collection of solicited personal information

Back to Basics Business Training Pty Ltd only collects personal information that is reasonably necessary for our business activities.

We only collect sensitive information in cases where the individual consents to the sensitive information being collected, except in cases where we are required to collect this information by law, such as outlined earlier in this policy.

All information we collect is collected only by lawful and fair means.

We only collect solicited information directly from the individual concerned, unless it is unreasonable or impracticable for the personal information to only be collected in this manner.

Australian Privacy Principle 4 - Dealing with unsolicited personal information

Back to Basics Business Training Pty Ltd may from time to time receive unsolicited personal information. Where this occurs we promptly review the information to decide whether or not we could have collected the information for the purpose of our business activities. Where this is the case, we may hold, use and disclose the information appropriately as per the practices outlined in this policy.

Where we could not have collected this information (by law or for a valid business purpose) we immediately destroy or de-identify the information (unless it would be unlawful to do so).

Australian Privacy Principle 5 - Notification of the collection of personal information

Whenever Back to Basics Business Training Pty Ltd collects personal information about an individual, we take reasonable steps to notify the individual of the details of the information collection or otherwise ensure the individual is aware of those matters. This notification occurs at or before the time of collection, or as soon as practicable afterwards.

Our notifications to individuals on data collection include:

Where possible, we ensure that the individual confirms their understanding of these details, such as through signed declarations, website form acceptance of details or in person through questioning.

Collection from third parties

Where Back to Basics Business Training Pty Ltd collects personal information from another organisation, we:

  1. Confirm whether the other organisation has provided the relevant notice above to the individual; or
  2. Whether the individual was otherwise aware of these details at the time of collection; and
  3. If this has not occurred, we will undertake this notice to ensure the individual is fully informed of the information collection.

Australian Privacy Principle 6 - Use or disclosure of personal information

Back to Basics Business Training Pty Ltd only uses or discloses personal information it holds about an individual for the particular primary purposes for which the information was collected, or secondary purposes in cases where:

Requirement to make a written note of use or disclosure for this secondary purpose

If Back to Basics Business Training Pty Ltd uses or discloses personal information in accordance with an ‘enforcement related activity’ we will make a written note of the use or disclosure, including the following details:

Australian Privacy Principle 7 - Direct marketing

Back to Basics Business Training Pty Ltd does not use or disclose the personal information that it holds about an individual for the purpose of direct marketing, unless:

On each of our direct marketing communications, Back to Basics Business Training Pty Ltd provides a prominent statement that the individual may request to opt out of future communications, and how to do so.

An individual may also request us at any stage not to use or disclose their personal information for the purpose of direct marketing, or to facilitate direct marketing by other organisations. We comply with any request by an individual promptly and undertake any required actions for free.

We also, on request, notify an individual of our source of their personal information used or disclosed for the purpose of direct marketing unless it is unreasonable or impracticable to do so.

Australian Privacy Principle 8 - Cross-border disclosure of personal information

Before Back to Basics Business Training Pty Ltd discloses personal information about an individual to any overseas recipient, we undertake take reasonable steps to ensure that the recipient does not breach any privacy matters in relation to that information.

Australian Privacy Principle 9 - Adoption, use or disclosure of government related identifiers

Back to Basics Business Training Pty Ltd does not adopt, use or disclose a government related identifier related to an individual except:

Australian Privacy Principle 10 - Quality of personal information

Back to Basics Business Training Pty Ltd takes reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete. We also take reasonable steps to ensure that the personal information we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant. This is particularly important where:

We take steps to ensure personal information is factually correct. In cases of an opinion, we ensure information takes into account competing facts and views and makes an informed assessment, providing it is clear this is an opinion. Information is confirmed up-to-date at the point in time to which the personal information relates.

Quality measures in place supporting these requirements include:

Australian Privacy Principle 11 - Security of personal information

Back to Basics Business Training Pty Ltd takes active measures to consider whether we are able to retain personal information we hold, and also to ensure the security of personal information we hold. This includes reasonable steps to protect the information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

We destroy or de-identify personal information held once the information is no longer needed for any purpose for which the information may be legally used or disclosed.

Access to Back to Basics Business Training Pty Ltd offices and work areas is limited to our personnel only - visitors to our premises must be authorised by relevant personnel and are accompanied at all times. With regard to any information in a paper based form, we maintain storage of records in an appropriately secure place to which only authorised individuals have access.

Regular staff training and information bulletins are conducted with Back to Basics Business Training Pty Ltd personnel on privacy issues, and how the APP’s apply to our practices, procedures and systems. Training is also included in our personnel induction practices.

We conduct ongoing internal audits (at least annually and as needed) of the adequacy and currency of security and access practices, procedures and systems implemented.

Australian Privacy Principle 12 - Access to personal information

Australian Privacy Principle 13 - Correction of personal information

Back to Basics Business Training Pty Ltd takes reasonable steps to correct personal information we hold, to ensure it is accurate, up-to-date, complete, relevant and not misleading, having regard to the purpose for which it is held.

Individual Requests

On an individual’s request, we:

In cases where we refuse to update personal information, we:

Correcting at Back to Basics Business Training Pty Ltd’s initiative

We take reasonable steps to correct personal information we hold in cases where we are satisfied that the personal information held is inaccurate, out-of-date, incomplete, irrelevant or misleading (that is, the information is faulty). This awareness may occur through collection of updated information, in notification from third parties or through other means.

Susan Stephens

Chief Executive Officer

Back to Basics Business Training Pty Ltd

March 2014