Privacy Policy | Hillsong Child Care Centre Australia

Australian Christian Early Education Ltd Privacy Policy

Australian Christian Early Education Ltd Privacy Policy

AUSTRALIAN CHRISTIAN EARLY EDUCATION LTD COMMITMENT TO PRIVACY

Australian Christian Early Education Ltd t/a Hillsong Child Care Centre ABN: 56 617 423 775, in Australia is committed to managing personal, sensitive and health information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with:

(a) other applicable privacy laws; and

(b) Education and Care Services National Regulations 2019 (NSW); and

(c) Children (Education and Care Services National Law Application) Act 2010 No 104 (NSW); and

(d) Education and Care Services National Law Act 2010 (Cth).

This document sets out our policies for managing your personal, sensitive and health information and is referred to as our Privacy Policy.

INTERPRETATION

In this Privacy Policy, “we” and “us” refers to Hillsong Child Care Centre and “you” refers to any individual about whom we collect personal, sensitive and health information.

‘Personal information’ means any information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

‘Sensitive personal information’ means any information or opinion about an individual’s racial or ethnic origin, political opinion or association, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information and biometric information or templates.

‘Health Information’ means information or an opinion about the health including illness, disability or injury of an individual, an individuals expressed wishes about the future provision of health services to the individual, a health service provided or to be provided to an individual, other personal information collected to provide a health service to an individual, other personal information collected in connection with the donation by an individual, genetic information about an individual in a form that is or could be predictive of the health of the individual or genetic relative of the individual.

In this Privacy Policy “National Education and Care Law and Regulations” refers to the Education and Care Services National Law Act 2010 (Cth), Children Education and Care Services National Law Application Act 2010 (NSW) and Education and Care Services National Regulations 2018 (NSW).

ABOUT AUSTRALIAN CHRISTIAN EARLY EDUCATION LTD

Australian Christian Early Education Ltd is a Christian Child Care service which aims to provide high quality learning and development on a foundation of secure and respectful relationships.

Hillsong Child Care Centre offers a complete range of services, including day care for children under the age of 6 years.

WHAT INFORMATION DOES HILLSONG CHILD CARE CENTRE COLLECT ABOUT YOU?

The type of personal, sensitive and health information that we will collect will vary depending on the circumstances of collect and the kind of service that you request from us. The information collected for enrolled children in Hillsong Child Care Centre will typically include:

(a) Name;

(b) Address;

(d) Family contact details;

(e) Emergency contact details;

(f) Authorized nominee details;

(g) Parents occupations;

(h) Parents Name;

(i) Parents Genders;

(j) Parents Place of Birth;

(k) Parents Address;

(l) Parents Contact Details;

(m) Family Status

(n) Custodial Arrangements (if applicable);

(o) Cultural background;

(p) Home language;

(q) Religious beliefs;

(r) Financial and Payment Details (in order to conduct payment for services);

(s) Child Care Subsidy Status (CCS) and additional Child care benefit information or funding agreements;

(t) Medicare number;

(u) Immunization records;

(v) Incident Records;

(w) Medication Records;

(x) Medical information;

(y) Medical management plans;

(z) Doctors Contact Details;

(aa) Dentists Contact Details;

(bb) Private Health Insurer;

(cc) Financial and Payment Details (in order to conduct payment for services);

(dd) Photos of children;

(ee) Information about children’s strengths, interests, preferences and needs (including special needs);

(ff) Photos of children;

(gg) Information about children’s strengths, interests, preferences and needs (including special needs);

(hh) Developmental and behavioral records and plans.

Hillsong Child Care Centre must collect information which is considered sensitive information in order to fulfil legal obligations under National Education and Care Law and Regulations and to promote learning under the Early Years Learning Framework. For example, if your child is injured whilst at the childcare center or an event promoted or delivered by Hillsong Child Care Centre we require for health information to be collected in an emergency or otherwise with your consent.

Hillsong Child Care Centre collects personal, sensitive and health information about children. Where children do not have sufficient maturity and understanding to make decisions about their personal, sensitive and health information, we will require their parents or guardians to make decisions on their behalf.

You can always decline to give Hillsong Child Care Centre any personal, sensitive and health information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal, sensitive and health information we have requested, please let us know.

The information collected for prospective families and children to join Hillsong Child Care Centre will typically include:

(a) Name;

(b) Gender

(d) Date of Birth;

(e) Family contact details;

(f) Emergency contact details;

(g) Authorized nominee details;

(h) Parents occupations;

(i) Parents Name;

(j) Parents Genders;

(k) Parents Place of Birth;

(l) Parents Address;

(m) Parents Contact Details;

(n) Family Status

(o) Custodial Arrangements (if applicable);

(p) Cultural background;

(q) Home language;

(r) Religious beliefs;

(s) Child Care Subsidy Status (CCS) and additional Child care benefit information or funding agreements;

(t) Medicare number;

(u) Immunization records;

(v) Incident Records;

(w) Medication Records;

(x) Medical information;

(y) Medical management plans;

(z) Doctors Contact Details;

(aa) Dentists Contact Details;

(bb) Private Health Insurer;

(cc) Financial and Payment Details (in order to conduct payment for services);

(dd) Photos of children;

(ee) Information about children’s strengths, interests, preferences and needs (including special needs);

(ff) Developmental and behavioral records and plans.

Other individuals

Hillsong Child Care Centre may collect personal, sensitive and health information about other individuals who are not clients of Hillsong Child Care Centre. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to Hillsong Child Care Centre; and other individuals who interact with Hillsong Child Care Centre on a commercial basis. We will only process your personal, sensitive and health information where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your information.

Under the law in almost all cases the legal basis will be:

(a) Because it is in our legitimate interest as a registered Childcare service provider to use your personal, sensitive and health information to operate and improve our service;

(b) To fulfil any contractual relationship, we have with you in relation to provision of products or services;

(d) Because we need to use your personal, sensitive and health information to comply with a legal obligation, such as protection and welfare of individuals;

(e) To protect the vital interests of you or another person;

(f) To process sensitive/special category personal, sensitive and health data that is relevant to us as a childcare service provider;

(g) Where you have given us consent to contact you by email, phone or SMS to send you information and marketing communications.

The kinds of personal, sensitive and health information we collect will depend on the capacity in which you are dealing with Hillsong Child Care Centre. Generally, it would include:

(a) Name;

(b) Address;

(d) Occupation;

(e) Financial Details (in order to conduct payment for services); and

(f) Emergency Contact Details;

However, this list is not exhaustive of the type of data which may be collected.

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.

In limited circumstances, Hillsong Child Care Centre may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Hillsong Child Care Centre we may collect health information about you in an emergency or otherwise with your consent.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

HOW AND WHY DOES HILLSONG CHILD CARE CENTRE COLLECT AND USE YOUR PERSONAL, SENSITIVE AND HEALTH INFORMATION?

Hillsong Child Care Centre collects personal, sensitive and health information reasonably necessary to carry out our business, to assess and manage our clients’ needs, and provide high level education services to children. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing client relationships.

All personal information will be kept confidential and only be provided to third parties who assist us, provide goods or services requested by such persons, or with your prior consent.

The purposes for which Hillsong Child Care Centre usually collects and uses personal, sensitive and health information depends on the nature of your interaction with us, but may include:

Responding to requests for information and other general inquiries;
Assessing Children’s Applications;
Managing, planning, advertising and administering programs, events, competitions and performances;
Researching, developing and expanding our facilities and services;
Informing you of our activities, events, facilities and services;
Recruitment processes (including for volunteers, internships and work experience); and
Responding to enquires and complaints.

Hillsong Child Care Centre collects personal, sensitive and health information directly from you. We may collect and update your personal, sensitive and health information over the phone, by email, over the internet or social media, or in person. We may also collect personal, sensitive and health information about you from other sources, e.g.:

Hubworks;
Referral bodies or Agencies involved with the child or family in question e.g. child protection or child services;
Health providers;
Government bodies or agencies;
General Practitioners, dentists, speech pathologists, therapists and schools;
Professional bodies;
Higher institutional bodies;
Hillsong Church Kids program or other programs involved in the child or that fall within Child Protection Amendments in New South Wales regarding interagency collaboration; and
Third-party suppliers and contractors who assist us to operate our business

Hillsong Child Care Centre also collects and uses personal, sensitive and health information for marketing research purposes and to innovate our delivery of products and services.

HOW DOES HILLSONG CHILD CARE CENTRE INTERACT WITH YOU VIA THE INTERNET?

You may visit our website (https://hillsong.com/childcarecentre/) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal, sensitive and health information you provide to Hillsong Child Care Centre will be managed in accordance with this Privacy Policy.

Hillsong Child Care Centre and other affiliated Hillsong websites use cookies. A “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

Hillsong Child Care Centre’s websites may contain links to third-party websites. Hillsong Child Care Centre is not responsible for the content or privacy practices of websites that are linked to our website.

CAN YOU DEAL WITH HILLSONG CHILD CARE CENTRE ANONYMOUSLY?

Hillsong Child Care Centre will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable, for example, when making a general enquiry. Generally, it is not practicable for Hillsong Child Care Centre to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal, sensitive and health information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

HOW DOES HILLSONG CHILD CARE CENTRE HOLD INFORMATION?

Hillsong Child Care Centre stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia. Personal, sensitive and health information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal, sensitive and health information from misuse, interference and loss and from unauthorized access, modification or disclosure.

Hillsong Child Care Centre maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, e.g. we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal, sensitive and health information via the internet.

We take steps to destroy or de-identify information that we no longer require and retain information no longer then reasonably and legally necessary.

DOES HILLSONG CHILD CARE CENTRE USE OR DISCLOSE YOUR PERSONAL, SENSITIVE AND HEALTH INFORMATION FOR DIRECT MARKETING?

Hillsong Child Care Centre may use or disclose your personal, sensitive and health information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, Hillsong Child Care Centre may still contact you in relation to its ongoing relationship with you.

HOW DOES HILLSONG CHILD CARE CENTRE USE AND DISCLOSE PERSONAL, SENSITIVE AND HEALTH INFORMATION?

For clients

The purposes for which we may use and disclose your personal, sensitive and health information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.

For customers and participants

If you are a customer or participant in an event, we may disclose your personal, sensitive and health information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

Hillsong Child Care Centre may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance or development, printing, archiving, mail-outs, and market research. Hillsong may also disclose information to a third-party Government Agency if under the legal obligation to do so.

Personal, sensitive and health information may also be shared between related and affiliated companies of Hillsong International Ltd atf Hillsong International and Hillsong Church Australia Ltd atf Hillsong Australia, located in Australia.

Third parties to whom we have disclosed your personal, sensitive and health information may contact you directly to let you know they have collected your personal, sensitive and health information and to give you information about their privacy policies.

Use and disclosure for administration and management

Hillsong Child Care Centre will also use and disclose personal, sensitive and health information for a range of administrative, management and operational purposes. This includes, but is not limited to:

Administering billing and payments and debt recovery;
Planning, managing, monitoring and evaluating our services;
Quality improvement activities;
Statistical analysis and reporting;
Training staff, contractors and other workers;
Risk management and management of legal liabilities and claims (e.g. liaising with insurers and legal representatives);
Responding to enquiries and complaints regarding our services;
Obtaining advice from consultants and other professional advisers; and
Responding to subpoenas and other legal orders and obligations.
Department of health

Sharing of Personal, Sensitive and Health Information

With third parties who work with our practice for business purposes, such as accreditation agencies or information technology providers – these third parties are required to comply with APPs and this policy e.g. departmental agencies;
With other healthcare providers;
When it is required or authorised by law (e.g. court subpoenas);
When it is necessary to lessen or prevent a serious threat to a patient’s life, health or safety or public health or safety, or it is impractical to obtain the patient’s consent;
To assist in locating a missing person;
Risk management and management of legal liabilities and claims (eg, liaising with insurers and legal representatives);
When there is a statutory requirement to share certain personal, sensitive and health information (e.g. health, child protection, some diseases require mandatory notification);
During the course of providing medical services, through My Health Record (e.g. via Shared Health Summary, Event Summary);
Responding to subpoenas and other legal orders and obligations when it is required or authorized by law.

Only people who need to access your information will be able to do so. Other than in the course of providing medical services or as otherwise described in this policy, our practice will not share personal, sensitive and health information with any third party without your consent.

We will not share your personal, sensitive and health information with anyone outside Australia (unless under exceptional circumstances that are permitted by law) without your consent.

Other uses and disclosures

We may use and disclose your personal, sensitive and health information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

DOES HILLSONG CHILD CARE CENTRE DISCLOSE YOUR PERSONAL, SENSITIVE AND HEALTH INFORMATION OVERSEAS?

Hillsong Child Care Centre is an Australian organisation and works with clients, service providers, sponsors and commercial interests within Australia. It is unlikely that your personal, sensitive and health information will be disclosed to overseas recipients.

Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal, sensitive and health information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal, sensitive and health information.

In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which Hillsong Child Care Centre and its related entities and affiliates operate.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL, SENSITIVE AND HEALTH INFORMATION?

You are entitled to access your personal, sensitive and health information held by Hillsong Child Care Centre on request. To request access to your personal, sensitive and health information please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access your personal, sensitive and health information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal, sensitive and health information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal, sensitive and health information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal, sensitive and health information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal, sensitive and health information about the requested correction.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL, SENSITIVE AND HEALTH INFORMATION?

You may contact Hillsong Child Care Centre at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Hillsong Child Care Centre may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website (https://www.oaic.gov.au/about-us/contact-us/).

REQUIREMENT OF HILLSONG CHILD CARE CENTRE TO NOTIFY IF A BREACH OF PERSONAL, SENSITIVE AND HEALTH INFORMATION DATA OCCURS

If a breach of personal, sensitive and health information (data) occurs in the practice, we are required to notify the individuals involved and the OAIC personal, sensitive and health information is:

(a) lost (e.g. laptop containing medical records is stolen);

(b) accessed by an unauthorised person (e.g. hackers taking control of medical records);

(d) this is likely to result in serious harm to someone; and

(e) the practice can’t take steps to prevent the risk of serious harm.

Addressing the likelihood of serious harm may mean the breach is no longer ‘eligible’ for reporting to the OAIC. To assess whether serious harm is likely the following are considered:

(a) Whose personal, sensitive and health information, Certain people e.g. young persons and vulnerable individuals may be at more risk;

(b) How many individuals were involved;

(d) What parties have gained, or may gain access to, the personal, sensitive and health information.

If such a breach occurs, the practice will promptly prepare a statement of the OAIC via online form to lodge notification statements and provide additional supporting information including:

(a) Organisations identity and contact details;

(b) A description of the data breach;

(d) Recommendations to individuals about the steps they should take to minimise the impact of the breach.

After notifying OAIC the practice will notify individuals in one of two ways:

(a) Notify all individuals whose personal, sensitive and health information was part of the data breach;

(b) Notify only those individuals at risk of serious harm.

(c) If neither option (a) or (b) is practicable, we will publish a notification on our website and take reasonable steps to publicise the contents of the statement.

Notification of individuals can use any method (e.g. telephone call, SMS, physical mail, social media post or in-person conversation) and must provide the same information as provided in the statement to OAIC

Hillsong Child Care Centre respects and upholds your right to privacy protection under the Australian Privacy Principles in regulating how we collect, use, disclose and hold your personal, sensitive and health information. We have policies and procedures to ensure that only authorised staff have access to your personal, sensitive and health information and that it remains confidential and is only used for appropriate purposes and in accordance with this policy.

The Spam Act 2003

The Spam Act prohibits the sending of unsolicited emails, SMS and MMS messages for commercial purposes from or within Australia or to people in Australia and bans the supply and use of software designed to harvest email addresses. While charities do have some exemptions from this Act, Hillsong Child Care Centre will be guided by the Australian eMarketing Code of Practice. We will always provide you with an opt-out mechanism as part of all electronic communications.

HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?

Hillsong Child Care Centre may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

HOW CAN YOU CONTACT THE PRIVACY OFFICER OF HILLSONG CHILD CARE CENTRE?

The contact details for Hillsong Child Care Centre are:

Australian Christian Early Education Ltd,

ATTN: Privacy Officer

1/9 Solent Circuit, Norwest, NSW 2153

[email protected]

+61 2 1300 5353

This Privacy Policy was last updated in 10 January 2020.

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