Privacy Policy

Your privacy is important

Somerville House (the School) is bound by the Australian Privacy Principles (APPs) contained in the Commonwealth Privacy Amendment (Enhancing Privacy Protection) Act 2012 and has developed a comprehensive policy to ensure it meets those obligations.

This statement outlines how personal information provided to or collected by the School is used and managed.

The School may, from time to time, review and update this Privacy Policy to take into account new laws, changing technology and/or changes to the School’s operations, business or education practices.

Collection of Information

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

• Students and parents and/or guardians ("Parents") before, during and after the course of a student's enrolment at the School 
• Job applicants, staff members, volunteers and contractors 
• Past students of Somerville House; and
• Other people who come into contact with the School.

Personal information you provide

The School will generally collect personal information held about an individual through forms completed by parents or students, from face-to-face meetings and interviews, or from telephone calls. On occasions, people other than parents and students provide personal information.

Personal information provided by other people

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

Collection of personal information from a third party will be undertaken where the School deems it necessary to do so in order to fulfil its purpose. Any personal information that is unsolicited will be dealt with in accordance with the APPs.

Sensitive information

"Sensitive information" can include 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 preferences, criminal record, and health or biometric information about an individual.

The School will collect, use and disclose sensitive information where it is reasonably necessary to fulfil the School’s primary purpose, a directly related purpose or a purpose allowed by privacy laws. It will only be collected with consent, unless one of the exceptions under the APPs applies and used or disclosed for the purpose for which it was collected or the use/disclosure is required/permitted by law.

Exception in relation to employee records

Under the Privacy Act, the Australian Privacy Principles do not apply to an employee record held by the employing entity. This means that the School’s Privacy Policy does not apply to how the School deals with an employee record that concerns current or former employees of the School.

Use of personal information

Somerville House will use personal information it collects from you for the primary purpose of collection, which is to enable the School to provide education for the student, and for such secondary purposes which are related to his/her schooling which are reasonably expected, or to which you have consented.

This includes satisfying both parents’ and students’ needs throughout the whole period s/he is enrolled at the School.

The purposes for which Somerville House uses personal information regarding students and parents may include (but is not limited to)

• Keeping parents informed about matters relating to their child's education, through correspondence, newsletters and magazines
• Managing day-to-day administration 
• Supporting a students' educational, social and medical wellbeing 
• Seeking donations and marketing for the School 
• Satisfying the School's legal obligations; and
• Allowing the School to discharge its duty of care.

In some cases where Somerville House requests personal information, including sensitive information, about a student or parent, if the information requested is not provided, the School may not be able to enrol or continue the enrolment of the student or permit him/her to participate in a particular activity.

Job applicants, staff members and contractors

In relation to personal information relating to job applicants, staff members and contractors, the School's primary purpose of collection is to assess and (if successful), to engage the applicant, staff member or contractor, as the case may be.

The purposes for which the School uses personal information relating to job applicants, staff members and contractors include:

• Administering the individual's employment or contract 
• For insurance purposes 
• Seeking funds and marketing for the School; and
• Satisfying the School's legal, compliance and due diligence obligations.

Volunteers

Somerville House also obtains personal information about volunteers who assist the School in its functions or who conduct associated activities. For example personal information may be required concerning volunteer staff in the Communication and Admissions Unit, the Somerville House Foundation, Somerville House Parents' & Friends' Association and related Support Groups and the Old Girls' Association. This information enables the School and volunteers to work together.

Marketing and Fundraising

The School engages in marketing and fundraising to promote future growth and development and to sustain and improve the educational environment for both students and staff. School publications such as newsletters and magazines, which include personal information, may be used for marketing purposes.

The School may also disclose personal information which it holds to organisations which assist in the School's fundraising, such as capital appeals organised by the Somerville House Foundation, Parents' & Friends' Association and the Old Girls' Association (and if necessary, external fundraising organisations).

Parents, staff contractors and other members of the wider School community may from time to time receive fundraising or marketing information.

The School will abide by any direction from an individual not to disclose personal information to third parties for such purposes and allows individuals to “opt out” of receiving fundraising or marketing materials at enrolment, annually via an updating of information survey or via an inclusion in the advertising material itself.

Disclosure of personal information

Somerville House may disclose personal information, including sensitive information, held about an individual to:

• Another school 
• Government departments 
• Medical practitioners 
• People providing services to Somerville House, including specialist visiting teachers and sports coaches
• Recipients of School publications, such as newsletters and magazines
• Parents
• Anyone to whom you provide authorisation for the disclosure of information; and 
• Anyone to whom the School is required, by law, to disclose the information.

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 which are situated outside Australia or to facilitate a School exchange or International Tour.

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.

Quality of information

The School endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. It requires parents to update their child’s health information prior to any camp, overnight excursion or international tour and parents of students with specialised health needs to update their information annually.

A person may seek to update his or her personal information held by the School by contacting the Business Manager at any time.

Management and security of personal information

Staff are required and have been trained to respect and protect the confidentiality of personal information relating to parents and students and the privacy of individuals.

The School will take all reasonable steps:
i. to protect the personal information held from misuse, loss, unauthorised access, modification or disclosure
ii. destroy or de-identify information that is no longer needed in accordance with the APPs.

Methods used to safeguard personal information include the locked storage of paper records and password access rights to computerised records.

Access to Personal Information

Under the Commonwealth Privacy Act, an individual has the right to obtain access to any personal information which the School holds about him or her and to advise the School of any perceived inaccuracy. There are some exceptions to this right which are set out in the applicable legislation, including for example, where access may impact the privacy of others or pose a threat to the individual.

Students will generally have access to their personal information through their parents, but older students may seek access themselves.

If you wish to access or have any concerns about the accuracy of the information held by Somerville House, about you or your child, please contact the Principal in writing.

The School will respond to this request within a reasonable 14 days from the receipt of the application. It may require you to verify your identity and specify what information you require. Where it is reasonable the School will provide access in the manner requested.

A fee may be charged to cover the cost of verifying your application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, the School will advise of the likely cost in advance. However the School will not charge for the application for access.

If your request for access is refused, the School will provide you with written notice explaining the reason for refusal and include in the response, details on how to make a complaint, should you wish to do so.

Consent and rights of access to the personal information regarding students

The School respects the right of every parent to make decisions concerning his or her child's education.

Generally, Somerville House will refer any requests for consent and any notices relating to the personal information about a student to the student's parents. The School will 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.

As stated above, parents may seek access to personal information held by the School about them or their child by contacting the Principal. However, there will be occasions when access is denied. Such occasions would include where release of the 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.

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

Enquiries and complaints

If you would like further information about the way the School manages the personal information it holds please contact the Business Manager.

If you believe that the School has breached the APPs and wish to complain you should direct your complaint in writing to the Principal. The School will investigate your complaint in a timely manner and respond in writing. If you are not satisfied with the School’s response, a complaint can be lodged with the Office of the Australian Information Commissioner at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.