Policy and Procedure

Reviewed by: F Blackadder (HR Consultant)
Approved by Matrix Management on: 28 May 2019
First creation date: December 2014
Version number: 6
Review date: 15 May 2019
Next review due: May 2020
Number of Pages: 3
Type: HR Policy

Policy

In the course of business, Matrix on Board Training (Matrix) collects and uses a range of personal information for the purposes of providing capacity building services to clients and organisations primarily in the not for profit sector. As a Registered Training Organisation (RTO#110079) Matrix may collect and use information from students or persons seeking to enrol, either electronically or in hard copy format, in our training courses, including information that personally identifies individual users. Matrix may also keep a record of various communications with individuals.

Matrix takes your privacy seriously. We encourage you to read this policy carefully. It will help you make informed decisions about sharing your personal information with us.

Matrix is bound by the Australian Privacy Principles (APPs) of the Privacy Act 1988 (Cth) as amended, to govern its collection, usage and disposal of personal information. The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed.

This policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information.

This policy is published on the Matrix on Board Training website, and is available in hard copy on request.

Definitions

Personal information is information, which identifies an individual and may include information such as an individual’s name, postal and email address, date of birth, telephone number, bank account details, and financial information.

Sensitive information is information which provides details about a person’s life such as an individual’s health history, religious and/or trade union affiliation, criminal record, photograph/s, video/s etc.

Collection of Personal Information

Staff and contractors

Matrix collects personal information from staff and contractors for the purpose of contacting and assessing potential staff and contractors; maintaining relevant registers of staff and contractors; and to obtain the information required to meet employment, legal and taxation obligations. Information is collected directly from the individual concerned.

Information collected includes general personal details, and may include details of any disability or health issue that may affect the staff member’s ability to meet the requirements of their position. Sensitive information is not normally collected by Matrix, other than as part of pre-employment screening purposes and for payroll purposes. Sensitive information is only collected with your consent.

Students

Matrix is required to collect personal information from students in order to process enrolments and obtain the information required to provide suitable training and assessment services. Where applicable information may also be required to comply with AVETMISS standards as specified by government regulators. Matrix will only collect personal information from students that is required for the purposes of education, or in meeting government reporting requirements.

Information collected includes general personal details, and may include details of any disability or health issue that may affect the student’s ability to undertake training and/or assessment activities. Information is collected directly from the individual concerned (where applicable information may be collected from the parent or guardian of a student under the age of 18).

Matrix will require students to sign a Release of Information Authority Form for the release of any student progress information to the employer.

Clients

Matrix collects personal information from clients including names, phone numbers and email addresses for the purpose of registering, maintaining contact with, follow up of, and marketing of Matrix services/products to subscribers and event participants. Information is collected directly from the individual concerned. De-identified data and answers to surveys are used for the collection of statistical information and benchmarking.

From time to time Matrix collects information on behalf of our clients for the purposes of providing management consulting services. This information may include may include stakeholder consultation, research, analysis and evaluation and is collected directly from the Matrix client organisation for the purpose of fulfilling the contracted project requirements. Data collected from clients is destroyed on completion of the project or stored securely on our data server.

Using and Disclosing Personal Information

Matrix will only use personal information for the business purpose(s) noted above or for another related purpose/s that an individual could reasonably expect.

Matrix uses personal information of its staff for the purposes of meeting employment requirements including payroll, superannuation and taxation.

Matrix uses personal information of its students for the purposes of meeting Vocational Education and Training (VET) requirements for the awarding of national qualifications, and to comply with reporting requirements where relevant, as specified by government regulators. Personal information as collected through the enrolment form or through other means will be passed on to government regulators as per legal data collection requirements. The Australian Skills Quality Authority (ASQA) may also access this personal information for the purposes of an audit.

Where Matrix uses the personal information it holds for direct marketing of its products or services, it will always provide you with the opportunity, at the first point of contact and at any time afterwards on request, to decline receipt of any further marketing information.

Matrix only discloses your personal information in limited circumstances.

Generally, Matrix uses services which are located in Australia. However, from time to time your personal information may be accessed by an overseas recipient where it is necessary for the performance of a contract between Matrix and a client organisation. Matrix has taken steps to ensure that, where this is the case, the disclosure of personal information data is for the express purpose for which the service has been contracted.

Matrix will not otherwise disclose personal information without your consent unless it is required to investigate suspected fraud or illegal activity; is authorised by law; is required for law enforcement and/or is required to operate Matrix’s business effectively.

Matrix will make all reasonable efforts to protect confidential information received from clients or partner organisations during the course of business operations. This information will not be disclosed without the prior consent of the client or partner organisation.

Data storage and destruction

Personal information is normally stored on Matrix on Board Training computer databases and/or hard copy.

Matrix on Board Training takes all reasonable steps to ensure the safe handling and security of the personal information it collects. If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable. We will give you a description of the data breach, the kinds of information concerned and recommendations about what steps you should take in response to the breach.

Increasingly personal information is collected and stored only in electronic form. Where personal information is collected in hard copy, such files are stored securely in filing cabinets in Matrix offices and are accessible only to authorised staff. Information stored electronically is kept on a secure cloud server and access is restricted to authorised employees.

Files and registers of personal information are regularly reviewed and destroyed where no longer current or needed for the particular business function. Reasonable steps will be taken to destroy or permanently de-identify personal information when it is no longer required for any purpose. Paper-based student files will be destroyed after 12 months from completion or withdrawal from accredited training.

Using our Website and Cookies

As with most websites, when you visit our website or use an application on our website, we may record anonymous information such as your IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.

We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use available to you of some of its features.

Our website may also contain links to or from other websites. We are not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information we collect on our website. We encourage you to read the privacy policies of other websites you link to from our website.

Rights and choices

Matrix will take all reasonable steps to ensure that personal information it uses is accurate and complete.

It is a policy of Matrix to allow access to personal information at any time to the person to whom those files relate, upon written request. Staff and students may access their files by submitting their written application to Student Records Coordinator.

If you advise Matrix that the information held on you is inaccurate, incomplete or out of date, Matrix will update the information accordingly.

You may at any time request that you no longer be subscribed to a Matrix marketing or communication database.

Complaints

If you have a concern about your privacy, you have the right to make a complaint and we will do everything we can to put matters right. To lodge a complaint, please get in touch with us using the contact details below. We will review your complaint and endeavour to resolve it quickly, usually within 30 days. If you are not satisfied with the outcome, you may pursue the matter with the Office of the Information Commissioner.

Contact details

For further information about this policy, please contact:

Matrix on Board Training
PO Box 3866
Alice Springs NT 0871
(08) 8953 2410
admin@mobct.com.au