PACT Privacy Policy
Ashley Services Group Limited Privacy Policy
Outline and Purpose of this Privacy Policy
Ashley Services Group Limited (ABN 92 094 747 510) and its Subsidiary Companies and associated or related businesses (“ASG”) are committed to respecting and protecting the integrity of your privacy and personal information obtained and collected in the course of the operation of ASG’s businesses.
ASG’s Subsidiary Companies include the following:
- Action Workforce Pty Ltd (ACN 099 238 954)
- ASG Integracom (Aust) Pty Ltd (ACN 153 558 457)
- Ash Pty Ltd (ACN 060 542 789) (trading as Ashley Institute of Training and ASG Integracom)
- Australian Institute of Vocational Development Pty Ltd (ACN 145 319 491)
- The Blackadder Recruitment Company Pty Ltd (ACN 086 799 715)
- Concept Engineering (Aust) Pty Ltd (ACN 073 583 669)
- Vocational Training Australia Pty Ltd (ACN 065 408 773) (trading as National Institute of Training)
- Tracmin Pty Ltd (ACN 081 782 005)
This Privacy Policy outlines our practices and procedures concerning the collection and handling of your personal information. In collecting your personal information, we will comply with the Australian Privacy Principles, the Privacy Act 1988 (Cth), the Privacy Amendment (Private Sector) Act 2000 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth).
Scope of this Privacy Policy
This Privacy Policy applies to the personal information of students and people making enquiries about our services.
To use our services, you must accept our Terms of Use and the terms of this Privacy Policy and in so doing you consent to our collecting your personal information, including any sensitive information which it includes, for these purposes and reasonably related purposes.
Under the Privacy Act 1988 (Cth):
- personal information is defined as information or an opinion, whether true or not and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.
- sensitive information is defined as information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, or criminal record that is also personal information.
Use of Information
ASG collects and retains personal information about you including your name, address, image and contact details and details concerning your career aspirations and your educational qualifications either electronically or in hard copy format, including information that personally identifies individual people.
In particular, we collect and use your personal information to provide you with information about study opportunities, course administration, academic information and maintenance of academic records, employment opportunities including to:
- Process your enrolment or other study applications with ASG’s education and training providers;
- Process any employment application or inquiries you have made through ASG;
- Assess your current and future vocational status and educational and training needs;
- Offer you specific, personalised and relevant vocational education and training information and services based on the information you have provided to us (including your career aspirations) which may enhance your qualifications and career opportunities;
- Inform you of available education and training opportunities, financial subsidies and/or support services;
- Directly market educational, career, employment and other opportunities to you, including through means of online remarketing, telemarketing and email marketing;
- Maintain our business relationship with you and offer our services on an on- going basis.
If you apply for a job advertised by us or one of our related entities, we may also contact you about related training and education opportunities. We may also use your information for compliance purposes and in-house research and analysis.
Collection of Information
Personal information is generally collected during the course of our contact with you and is largely provided by you. Generally the type of personal information which we collect will include your name, address, user’s image, telephone number(s), email addresses(s), date of birth, gender, country of birth, nationality, citizenship country, passport details, academic and English language attainments, disabilities, and health information (including illnesses, allergies and dietary Information). We may also collect information regarding payment of fees. It may be collected verbally in discussions with our employees, consultants or advisors. It may be supplied in writing by you in the form of job applications, enrolment applications, resume or academic records submitted by you in hard copy or electronically, either directly to us, or in some circumstances from a third party in which case ASG is careful to ensure that the third party provides your information with your consent.
We may record telephone conversations with you for staff training and compliance purposes. We will inform and obtain your approval prior to any recording commencements.
We may also share information between our related entities, depending on which of our related entities you initially dealt with and what services you obtain.
On occasion, information concerning you, your work history or qualifications may be provided by third parties such as former employers or educational institutions. Where this occurs we will take all reasonable steps to inform you of that. If students are under 18 years old, we may obtain information about you from a parent or guardian.
If you choose not to give ASG certain information then we may be unable to enrol you in a course, offer you employment or supply you with appropriate information.
Personal information may also be collected to assess your entitlement to Commonwealth assistance under the Higher Education Support Act 2003 (Cth) and to allocate a Commonwealth Higher Education Student Support Number (“CHESSN”). We will disclose this information to the Commonwealth Department of Education and Training for these purposes, who will store the information securely and may disclose any of the information supplied to the Australian Taxation Office. Personal information gathered for these purposes will not otherwise be disclosed without your consent unless required or authorised by law.
In general ASG education providers will not disclose personal information about you to another student, to people outside ASG education providers or to staff who have no need of access to the information, unless you tell us, in writing, that you have given permission.
However, there are some exceptions to the general application of this policy, some of which are obligations imposed on us by law. These exceptions include the following:
- we inform Centrelink (for Abstudy and Austudy) of your enrolment details (but not your results);
- we release statistical information to the Commonwealth Department responsible for the administration of the Data Provision Requirements: National Vocational Education and Training Regulator Act 2012 (NVR Act) which may in turn provide this information to other departments, the Australian Skills Quality Authority, State or Territory Government agencies, and other bodies authorised under the NVR Act but only for the purposes permitted in the NVR Act and in accordance with the procedures set out in the NVR Act and the Australian Privacy Principles;
- we tell the Australian Taxation Office (ATO) about your HELP liabilities each semester (you consent to this by signing your Payment Options form);
- if you are an International student, we provide a number of government organisations such as the Department of Immigration and Border Protection with information which we are required to release;
- we may be asked to provide information to the Department of Families, Housing, Community Services and Indigenous Affairs;
- if you are alleged to have committed an offence, we may be requested to assist the police or other authorised persons by providing personal information about you for the enforcement of the law;
- if you transfer to another institution we may release to that institution information about your academic progress, although we will only release this
information if you consented to the release of the information to the new institution;
- disclosure as necessary to prevent or lessen a serious and imminent threat to the life of health of the student or of another person;
- ASG education providers may use and disclose the information collected about you for the purpose of providing you with tailored marketing communications about products and services, or to conduct market research and analysis.
- ASG education providers may match an applicant’s marketing history with any other information gathered on the applicant for the purposes of assessing the effectiveness of particular marketing or to assist with future marketing.
Consent
Generally we require you to specifically consent to any collection, use or disclosure of your personal information. This is done by accepting our Terms of Use and Privacy Policy online or in person. Your consent may also be implied through your conduct with us.
Direct Marketing
From time to time we may use your personal information to provide you with
information about our services. By accepting ASG’s Terms of Use and by providing ASG with information or seeking its services, you consent to receive direct marketing of relevant services or opportunities as identified by ASG, its related entities or third party service providers dealing with ASG. If any phone number(s) you have provided to us is registered on the Do Not call register, you consent to ASG or its direct marketing providers calling that number(s). ASG may continue to contact you for an indefinite period until you advise us otherwise.
Opting out of Direct Marketing
You may opt out of receiving direct marketing at any time and request to be removed from our database by any of the means set out at the end of this Privacy Policy. You may also opt out of any marketing emails by following the ‘unsubscribe’ function found at the footer of such emails.
If you do not wish to receive marketing material, please note ASG will still contact you in relation to the ongoing relationship e.g. invoices.
Cookies
Cookies are uniquely numbered identification numbers like tags which are placed on individuals’ browsers. We use information from cookies to monitor usage of the website, identify returning users, enable targeted services and opportunities to be directly marketed to you based on your browsing history. Cookies are necessary for ASG to create a better user experience on ASG’s websites. You can delete cookies and change the settings on your web browser not to accept cookies, however, certain features and content may not be available to you.
Disclosure of Personal Information
ASG will disclose your personal information to our related entities and/or certain affiliated third party service providers in certain relevant circumstances and in the provision of our services to you.
This may include disclosure to:
- Prospective employers
- Federal, State and Territory education and vocational training bodies
- Federal, State and Territory Governments and designated authorities
- Third party service providers
ASG will not disclose your personal information to another person or organisation unless:
- you were reasonably likely to have been aware, or were made aware, that information of that kind is usually passed to that person or organisation;
- you have given written consent to the disclosure;
- we believes on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to your life or health or that of another person;
- the disclosure is required or authorised by or under law; or
- the disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of the public revenue.
In such circumstances, we will include in the records containing that information a note of the disclosure.
Personal and Sensitive User Data
Personal and sensitive user data includes, but isn’t limited to, personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call-related data, health data, Health Connect data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data. If our app handles personal and sensitive user data, we adhere to the following guidelines:
Data Access, Collection, Use, and Sharing
1. Limitations:
We limit the access, collection, use, and sharing of personal and sensitive user data acquired through the app to the app and service functionality and policy-conforming purposes reasonably expected by the user.
2. Advertising Compliance:
Apps that extend the usage of personal and sensitive user data for serving advertising comply with Google Play’s Ads policy.
3. Data Transfer:
Data may be transferred as necessary to service providers or for legal reasons, such as to comply with a valid governmental request, applicable law, or as part of a merger or acquisition with legally adequate notice to users.
4. Security:
We handle all personal and sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).
5. Permissions Request:
We use a runtime permissions request whenever available, prior to accessing data gated by Android permissions.
6. No Sale of Data:
We do not sell personal and sensitive user data. “Sale” means the exchange or transfer of personal and sensitive user data to a third party for monetary consideration. User-initiated transfer of personal and sensitive user data (for example, when the user is using a feature of the app to transfer a file to a third party, or when the user chooses to use a dedicated purpose research study app), is not regarded as a sale.
Location Data Collection
ASG collects precise or approximate location data to track the time and calculate the distance for the site being assigned.
- Data Collected:
– Your precise or approximate location data - How We Use Your Data:
– To track the time spent on-site
– To calculate the distance traveled to and from the assigned site - How We Share Your Data:
– Your location data is not shared with third parties except as required by law or to improve our services. - Your Consent:
– By using the app, you consent to the collection and use of your location data as described. If you do not consent, you may disable location services, but this may affect the app’s functionality.
Image and Document Access
ASG collects images, documents as a proof of completion tasks.
- Data Collected:
– Images and documents from Gallery and Camera - How We Use Your Data
– To verify the presence at the appropriate site
– As proof of task completion - How We Share Your Data:
– The images and documents being uploaded is not shared with any third parties expect as required by law or to improve our services. - Your Consent:
– By using the app, you consent to the collection and use of your images and documents as described. If you do not consent, you may choose not to upload images or documents, but this may affect the app’s functionality.
Up-to-date Personal Information
It is important that the personal information we hold about you is accurate, complete and up-to-date in order to efficiently provide our services. If you find that personal information ASG holds about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us.
Where a record is found to be incorrect or inaccurate as a result of that request, that record will be corrected. Where a request is made that a record be amended because it is said to be incorrect or inaccurate but is subsequently found to be accurate, details of the request will be noted for reference on your record.
Security of Information
ASG maintains personal information in both paper-based and electronic records and systems. ASG will ensure all such information is stored securely and take all reasonable measures to protect personal information collected from unauthorised access, misuse or disclosure.
Right to Access Records
You have the right to access or obtain a copy of the personal information that ASG holds about you. Requests to access or obtain a copy of personal information should be sent by any of the means set out at the end of this Privacy Policy.
You may be required to verify their identity when requesting access to information. ASG may charge a fee to cover the cost of verifying the request and locating, retrieving, reviewing and copying any material requested. ASG will advise the likely cost of any such charge in advance.
Publication
This Privacy Policy and the Terms of Use will be made available to students and prospective students by publication on ASG’s websites. In order to ensure students have given informed consent for their personal information to be disclosed to certain third parties as outlined in this Privacy Policy, ASG will advise students on enrolment about these procedures.
Enquiries, Request for Access and Complaints
All privacy enquiries, requests for access and complaints should be directed in writing to the Privacy Officer by:
- Sending an email to privacy@ashleyservicesgroup.com.au
- Calling us on +612 9216 4747
- Sending correspondence to:
- Privacy Officer
Ashley Services Group Level 10, 92 Pitt Street
Sydney NSW 2000
ASG will respond to a complaint within 28 days.