Privacy Policy

1. Your Privacy is Important

Trinity Grammar School Kew (Trinity) is bound by the Australian Privacy Principles contained In the Commonwealth Privacy Act. In relation to health records the School is also bound by the Health Records Act 2001 (Vic).

2. Policy

Trinity is committed to protecting and maintaining the privacy, accuracy and security of all personal information.

3. Scope

This policy applies to all members of the Trinity staff, volunteers, contractors, students and alumni. All staff, volunteers and contractors are required by law to protect the personal and health information the School collects and holds.

4. What kinds of personal information does the School collect and how does the School collect it?

The type of information the School collects and holds includes (but is not limited to) personal information, including health and other sensitive information about

• Students and parents and/guardians before, during and after the course of a student’s enrolment at the School
• Job applicants, staff members, volunteers and contractors, and
• Other people who come into contact with the School.

Trinity only collects such personal information that it needs to function as an educational institution and to fulfil its duty of care to its students (primary purposes) or for secondary purposes that are related to the primary purpose (e.g. to keep parents informed about matters related to their child’s schooling, through correspondence, newsletters, magazines and reports).

Trinity will generally collect personal information held about an individual by ways of forms filled out, face-to-face meetings, interviews, telephone calls and other communications.

In some circumstances the School may be provided with personal information about an individual from a third party, eg. a report provided by a medical professional or a reference from another school.

5. How the school will use personal information

Trinity will use personal information solely for the primary or related secondary purposes for which it was collected:

Students and parents

 Primary

o looking after student’s educational, social and medical well-being
o to satisfy the School’s legal obligations and allow the School to discharge its duty of care.

 Secondary

o to keep parents and guardians informed about matters related to their child’s schooling through correspondence, newsletters, magazines, reports, Trinity Connect and social media
o day-to-day administration of the School
o seeking donations and marketing for the School

In some cases where the School requests personal information about a student or parent/guardian, if the information requested is not provided, the School may not be able to enrol or continue the enrolment of the student or permit the student to take part in a particular activity.

In referring to ‘sensitive information’, the School means: information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, philosophical beliefs, sexual orientation or practices or criminal record, that is also personal information; health information and biometric information about an individual.
Unless the provider agrees otherwise, or is allowed by law, sensitive information will be used and disclosed only for the purpose for which it was provided, or a directly related secondary purpose.

Job applicants, staff members and contractors

The purposes for which the School uses personal information of job applicants, staff members and contractors include,
• assessing and (if successful) engaging the applicant, staff member or contractor,
• administering employment and other contracts
• insurance purposes
• seeking donations and marketing for the School
• satisfying the School’s legal obligations (for example, in relation to child protection)

Volunteers

The School obtains personal information about volunteers who assist the School in its functions or conducted associated activities to enable the School and its volunteers to work together.

Marketing and Fundraising

The School treats marketing and seeking donations for the future growth and development of the School as an important part of ensuring that the School continues to provide a quality learning environment in which both pupils and staff thrive. Personal information held by the School may be disclosed to organisations that assist in the School’s fundraising, for example the alumni organisations. We will not disclose your personal information to third parties for their own marketing purposes without your consent.

Parents, staff, contractors and other members of the wider school community may from time to time receive fundraising information. School publications, like newsletters and magazines that include personal information may be used for marketing purposes.

If you do not agree to this, please advise the School in writing to the Privacy Officer.

Photographs

As part of its regular activities, Trinity Grammar School Kew may take photographs and/or video/audio recording of staff, student and other participants in the life of the School. The purpose of these photographs/video/audio recordings is to:

• Record staff and student learning activities
• Provide staff with information so that they fulfil their duty of care
• Celebrate achievement
• Provide class photographs
• Recognise effort across a range of activities
• Introduce students to and educate students in the use of twenty-first century digital media
• Use visual and audio media as tools of teaching and assessment
• Publicise the activities and achievements of the School
• Advertise and market the School as an outstanding learning community.

Trinity may publish these visual images

• In classroom displays
• on class websites, which are password protected
• on the staff intranet –accessed by staff only
• on Trinity Connect –password protected and accessed only by parents/guardians and staff
• In the Mitre, Grammarian, Trinity eNewsletter, information booklets, prospectuses and other School magazines –. Any or all of these electronic or print publications may be uploaded onto the School website
• On the Trinity Website and social media platforms
• In newspapers or online to advertise and market Trinity Grammar School
• In addition, the School may give permission to Associated Grammar Schools of Victoria (AGSV), Independent School Victoria (ISV) AND Ruyton Girls’ School to publish photographs and video vignettes involving TGS students, on the their websites.

If you do not wish images of yourself or your son to be included in all or any of the above publications please advise the School. Write to TGS Privacy Officer, 40 Charles Street, Kew 3101 or email privacyofficer@trinity.vic.edu.au so that your images are not selected for publication. If the School does not receive an objection from you, it will be assumed that you have consented to allow the School to use digital images (which may include images of yourself and/or your son) for the purposes described above and in the publications identified above.
The School will seek your separate consent before publishing an image of yourself and/or your son that involves a specific activity, purpose or publication not identified above.
We may include students’ and parents/guardians’ contact details in the class list. If you do not want your contact details to be included in the class list, please inform the School so that your details can be removed.

6. Disclosure of personal information

The School may disclose personal information, including sensitive information, held about an individual to:

o Another school;
o Government departments;
o Medical practitioners;
o People providing services to the School, including specialist visiting teachers and sports coaches;
o Recipients of School publications, including newsletters and magazines
o Parents; and
o Others you have authorised the School to disclose information to and
o Anyone to whom we are required to disclose the information to by law.

7. Visitors to the Trinity Grammar School Website

Trinity Grammar School takes advantage of Google Analytics service offered by Google Inc. The information gathered by this service is used by Trinity Grammar School to provide general statistical data regarding the use of the Trinity website, to maintain quality of service and to improve the operation of the website.
To find out more about Google Analytics and the Google privacy policy visit http://www.google.com/analytics/learn/privacy.html

8. Sending information overseas

The School may disclose personal information about an individual to overseas recipients, for instance, when storing personal information with ‘cloud’ service providers that are situated outside Australia, or, to facilitate a school exchange. However, the School will not send personal information about an individual outside Australia without
• obtaining the consent of the individual (in some cases this consent will be implied) or
• otherwise complying with the Australian Privacy Principles or other applicable privacy legislation.

9. Management and security of personal information

The School’s staff are required to respect the confidentiality of student and parent/guardian personal information and the privacy of individuals.

The School has in place procedures to protect the personal information the School holds from misuse, loss, unauthorized access, modification or disclosure by use of various methods including locked storage of paper records and pass-worded access rights to computerised records.

10. Provision of access to records

Trinity endeavours to ensure that the personal information it holds is accurate, complete and up-to-date.
Under the Commonwealth Privacy Act an individual has the right to obtain access to any personal information which the School holds about them and to advise the School of any perceived inaccuracies. Trinity has in place standard policies in relation to access to, and correction of, records which contain personal information.
A person may seek access to their personal information file and to update their personal information held by the School by making a request in writing to the Privacy Officer at any time. To make a request write to

The Privacy Officer,
Trinity Grammar School,
40 Charles Street,
Kew
Victoria 3101.

The School may require applicants to verify their identity and specify what information is required. The School may charge a fee to cover the cost of verifying an application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, the School will advise the likely cost in advance. If we cannot provide you with access to that information, we will provide you with written notice explaining the reasons for refusal.

There may be occasions when access is denied. Such occasions would include where the release of information would have an unreasonable impact on the privacy of others, or where the release may result in a breach of the School’s duty of care to the student.

Where there is a disagreement about the accuracy, completeness or currency of the personal information and the individual asks Trinity to attach a statement claiming that the information is not accurate, complete or current, then the School must take reasonable steps to do so.
Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record. Consequently, the School Privacy Policy does not apply to the School’s treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the School and an employee.

11. Removal/Destruction of Information

Subject to legal requirements with respect to the retention of records and in line with the Trinity Retention and Disposal of Documents Policy, the School will take all reasonable steps to destroy, or permanently de-identify, personal information if it is no longer needed for any purpose for which the information was provided. Unsolicited personal information that is not needed by the School will be destroyed. Personal information will only be removed/destroyed by a secure means.

12. Consent and rights of access to the personal information of students

The School respects every parent/guardian’s right to make decisions concerning their child’s education.

Generally, the School will refer any requests for consent and notices in relation to the personal information of a student to the student’s parents/guardians. The School will treat consent given by parents/guardians as consent given on behalf of the students, and notice to parents/guardians will act as notice given to the student.

The School may, at its discretion, on the request of a student grant that student access to information held by the School about them, or allow a student to give or withhold consent to the use of their personal information, independently of their parents/guardians. This would normally be done only when the maturity of the student and/or the pupil’s personal circumstances so warranted.

13. Enquiries and complaints

Further information about the way Trinity manages the personal information it holds can be obtained by contacting the Privacy Officer.
Complaints involving an alleged breach of the Australian Privacy Principles by the School should be presented in writing to the Privacy Officer. The School will investigate any complaint and will notify the decision in relation to the complaint as soon as practicable after it has been made.

Trinity Grammar School understands an individual’s right to keep their personal information private is highly important.
We are committed to protecting and maintaining the privacy, accuracy and security of your personal information.
© Trinity Grammar School, Kew. Last updated: October 2015.