- What types of personal information BJE might collect;
- How BJE collects personal information, including sensitive information;
- How BJE aims to use personal information it has collected;
- When BJE will disclose personal information to others;
- How BJE manages and secures personal information;
- How you can access and seek to correct personal information which BJE holds about you; and
- How you may make a complaint if you think that BJE has breached the Australian Privacy Principles or NSW Health Privacy Principles, and how BJE will deal with such a complaint.
Types of Personal Information Collected by BJE
BJE aims to collect only ‘personal information’ (as defined under the Privacy Act) that is reasonably necessary for its operation and/or related activities including statutory reporting obligations to third parties and/or fundraising activities to financially support its diverse activities.
The personal information collected and held by BJE about an individual will depend on the circumstances of collection and on the individual’s dealings with BJE. It typically includes:
- Information about students and parents before, during, and after the course of enrolment in BJE classes and activities, including names, addresses, email addresses, telephone and facsimile numbers, and other contact details;
- Information about job applicants, volunteers, and contractors, including name, email address, telephone number, address, financial details (including banking details), date of birth, citizenship, employment references, civil, credit and criminal records, working with children checks, driver’s licence information, education, employment history, marital status, membership of a professional or trade association, membership of a trade union and health information;
- Roles that individuals have or have had with BJE, and relationships between individuals;
- Notes taken by staff;
- Birth, death, Bar/Bat Mitzvah, and marriage information (usually sourced from the Australian Jewish News or other publicly available sources);
- Details of people who come into contact with BJE, such as suppliers, contractors and service providers, including name, job title, business contact details of company representatives with whom BJE deals, financial information and banking details, history and background checks and credit records;
- Financial information provided in support of financial assistance applications; and
- Bank account and credit card information.
Some of the information BJE collects is ‘sensitive information’. Sensitive information, as defined by the Privacy Act, includes information about racial or ethnic origin, religious beliefs, trade union or other professional or trade association membership, philosophical beliefs, criminal records, and health information.
How BJE Collects Personal Information
BJE usually collects personal information directly from the person concerned, or from their parents if they are a student or child. Examples of ways in which BJE collects information include forms, face-to-face meetings, interviews, telephone calls, electronic messaging, social media postings, email, CCTV security camera monitoring, and being contacted via our website. We do not collect personal information from visitors to our website other than what they provide voluntarily.
On occasion, BJE may receive information about a person from a third party, with or without the person’s direct involvement. Examples of information received from third parties include reports from medical professionals, references from employers and information from government agencies.
How BJE Uses Personal Information It Has Collected
BJE will collect and use personal information for the purpose for which it was collected, or for related purposes or other purposes.
Information Relating to Parents and Students
Personal information is collected from parents and students to assist BJE in providing its services. These services include, but are not limited to, the provision of classes, informal education sessions, camps, opportunities for social interaction between students, celebrations or commemorations of events, study programs (including overseas study programs), teacher training, and outreach programs to the non-Jewish community. The purposes for which BJE collects and uses the information include, but are not limited to:
- Keeping parents informed about their child through correspondence, newsletters, and magazines;
- Day-to-day administration;
- Attending to students’ well-being;
- Marketing, promotional and fund-raising activities for BJE;
- contracting out some of its functions to external service providers and suppliers (such as mailing houses and printing companies, IT, advertising and marketing);
- Satisfying BJE’s legal and regulatory obligations and allowing it to discharge its duty of care and child protection obligations;
- such purposes for which BJE may obtain consent from time to time; and
- Evaluating applications for enrolment and/or financial assistance.
There may be cases in which a failure to provide requested information will result in BJE being unable to meet its legal obligations or discharge its duty of care. In this event, BJE may be unable to enroll or continue the enrolment of the relevant student(s). Should this occur, you will be advised in writing.
Information Relating to Job Applicants, Contractors, service providers and Volunteers
BJE collects personal information relating to job applicants, contractors, service providers and volunteers to enable BJE to assess and (if successful) engage and manage those people. For example, BJE collects and uses personal information of job applicants, volunteers, service providers and contractors for the purposes of:
- assessing a person’s suitably for a job or task;
- managing a person’s engagement or contract, or (in the case of a volunteer) managing the volunteer’s deployment to a suitable task or tasks;
- ensuring that it holds relevant contact information; and/or
- satisfying BJE’s legal and regulatory obligations, for example allowing BJE to discharge its duty of care obligations and in relation to child protection legislation.
In some cases, if BJE requests personal information and that information is not provided to BJE, then BJE may not be able to assess and consider applications from prospective job applicants, contractors, service providers or volunteers. If this is the case, we will advise the person affected.
Marketing and Fundraising
Marketing BJE and seeking funds to support it are both important aspects of ensuring the ongoing viability of BJE and the services it provides. Accordingly BJE engages in fundraising activities from time to time. Information collected from you as a parent, student, prospective parent, job applicant, contractor or volunteer may be used by BJE in order to assist fundraising appeals.
BJE may from time to time provide parents, staff, contractors, and other members of the wider BJE community with information for the purpose of fundraising. BJE publications, such as newsletters and magazines, which include personal information, may be used for marketing purposes. If you do not want to receive further direct marketing or be contacted for marketing purposes by phone, fax email, letter or in person, please let us know by contacting us at firstname.lastname@example.org.
Circumstances in which We May Disclose Personal Information to Others
BJE discloses personal information collected for the purpose for which it was collected. It may also disclose personal information for related or other purposes. BJE will usually disclose personal information in connection with its educational and administrative functions.
It may disclose personal information to (without limitation) the following parties and for the following purposes:
- the NSW Department of Education and Training for the purpose of accessing funding for community language students;
- the JCA (Jewish Communal Appeal). BJE confidentially provides the JCA with information about its community. For example, sometimes BJE shares information about enrolments, including the identity of students or applicants for enrolment, with the JCA in order to assist us and the JCA to plan for the following school year. BJE also sometimes provides the JCA with information about its supporters to assist with fundraising or marketing activities;
- parents and the community for marketing and information purposes. For example, on occasion, information and photographs and/or video footage concerning academic and other achievements, student activities and other BJE news are published in school newsletters, magazines, on social media, and on our website. Such information and photographs may also be published in the Australian Jewish News, J-Wire, the Sydney Jewish Report, the Wentworth Courier, or similar publications.;
- anyone authorised by you to receive your personal information (your consent may be express or implied and can be withdrawn at any time). If you provide BJE with the personal information of others, such as doctors or emergency contacts, we encourage you to inform them that you are disclosing such information;
- outsourced service providers who perform functions on BJE’s behalf, such as organisations providing security services, conducting market research, or providing email and mail handling services;
- medical practitioners;
- companies located overseas, including in Israel, that provide services to BJE, its staff and/or students in relation to international BJE programs;
- anyone to whom we are required by law to disclose personal information.
We require third parties to use your personal information only for the specific purpose for which it was given to us and to protect the privacy of your personal information. We will only disclose your personal information to third parties on the basis that such parties agree with BJE to keep your information confidential.
BJE deems that you consent to us disclosing your personal information and, where applicable, your child’s personal information, to the third parties listed above, and similar organisations who may in turn provide your information to other third parties (for example, for marketing purposes).
If you do not permit the disclosure of personal information about you or your child to any of the organisations listed above or similar organisations, you must advise BJE in writing that your permission is withheld.
If you do not permit the disclosure of some personal information as BJE requests, BJE may not be able to meet its legal obligations or discharge its duty of care, and may not be able to enrol or continue the enrolment of a student or engage you to work at BJE. If this is the case, we will let you know.
Sending Information Overseas
Apart from storing information in the ‘cloud’, which may involve the use of servers located outside Australia, BJE will not send your personal information outside Australia without first:
(a) obtaining your consent (in some cases this is implied); or
(b) otherwise complying with the Principles or other applicable legislation.
When you visit the public pages of BJE’s website, a record is made of your visit and the following information is logged:
- your IP (‘Internet Protocol’) address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
- search terms used;
- the operating system and Internet browser software you are currently using; and
- the data that you download (such as web pages or other document files or software), and the time that you download it.
This information cannot be used to identify you and is only used for statistical purposes to help us identify what parts of our website our users visit the most, which in turn assists us to determine how to improve our services.
If you contact us through our website or email us, BJE will use your personal information only to respond to your request or answer your queries. We will not add your email address to our mailing list.
Management and Security of Personal Information
BJE’s Business Manager is responsible for the management of personal information that we collect.
BJE staff are required to respect the confidentiality of all personal information and the privacy of individuals, and we have directed our staff that personal information must be dealt with in accordance with this statement.
BJE has security systems in place to protect your personal information from misuse, loss, unauthorised access, modification, or disclosure. Paper records are stored while electronic records are stored on a secure network with multi-factor autehication and password-protected access rights.
BJE may also store personal information in the ‘cloud’, which may result in the information residing on servers situated outside Australia.
If BJE receives personal information about you which it did not request and which it does not reasonably require, BJE may destroy or de-identify this information where appropriate.
If you reasonably believe that there has been an unauthorised use or disclosure of your personal information, please let us know by contacting our Office at email@example.com or by telephoning 02 9365 7900.
Updating Personal Information
BJE aims to keep all personal information that it holds accurate, complete and up-to-date.
We encourage you to tell us if you change your contact details. If you believe that any information that we hold about you is incorrect, incomplete or out-of-date, please contact BJE on (02) 9365 7900 and ask for the Business Manager. Alternately, you may wish to email our Office at firstname.lastname@example.org
BJE is required by law to keep some types of information for certain periods of time. In particular, the Health Privacy Principles impose certain obligations about the length of time that health records must be stored. If we no longer require your personal information, we will generally destroy or de-identify that information. However, the BJE reserves the right to retain personal information for a period longer than for which it is required to retain the information, if BJE considers that it is necessary, and as long as it is in accordance with the Principles and the Health Privacy Principles.
How to Access the Personal Information which BJE Holds About You
Under the Privacy Act and the Health Records Act, an individual generally has the right to obtain access to any personal information which BJE holds about him/her and to advise BJE of any perceived inaccuracy in that information. There are some exceptions to this right.
In some circumstances, the Privacy Act entitles BJE to deny access, for example if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which BJE is involved. If we do refuse access, we will generally let you know the reasons for our refusal.
If you make a request for access to your personal information, we may require you to verify your identity and specify what information you require. BJE may charge a fee to cover the cost of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, BJE will generally advise you of the likely cost in advance.
Any request to access personal information held by BJE should be made in writing. Within a reasonable period after receiving a request from the individual, BJE will take reasonable steps to provide the individual with access, if it is reasonable and practicable to do so. Please write to BJE, address your correspondence to The Office Manager, and mark your letter “Confidential”. Alternately, please email BJE’s Office at email@example.com and enter the subject line as ‘Confidential – Request to Access Personal Information’.
Consent and Rights of Access to the Personal Information of Students
BJE respects parents’ right to make decisions concerning their children’s education. Parents may seek access to personal information collected about them and their child by contacting BJE. Students may also seek access to personal information about them.
Generally, BJE will refer any requests for consent and notices in relation to the personal information of a student to the student’s parents. BJE will also generally treat consent given by parents as consent given on behalf of the student, and notice to parents will act as notice given to the student.
However, there will be occasions when BJE denies a parent access to a student’s records. Such occasions would include, but not be limited to, where:
- release of the information would have an unreasonable impact on the privacy of others;
- release may result in a breach of BJE’s duty of care to a student; or
- the student withholds consent to the disclosure of his/her personal information. This would normally be done only when the maturity of the student and/or the student’s personal circumstances so warranted.
BJE may, at its discretion, give students direct access to their own personal information and records, although again this would normally be done only when the maturity of the student and/or the student’s personal circumstances so warranted.
For further information about the way BJE manages the personal information it holds, or if you would like to make a complaint about BJE’s handling of your personal information or compliance with the Principles, please contact BJE’s Business Manager by email (firstname.lastname@example.org ) or by telephoning BJE on (02) 365 7900 and asking for the Office Manger. BJE will respond to complaints within a reasonable period of time. If an individual disagrees with BJE’s decision, the individual may refer the complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing email@example.com.