iChildcare Management Pty Ltd ATF Early Learning Management Trust ABN 19 632 288 713 (collectively referred to in this document as ‘Early Learning Management’ / ‘we’ / ‘us’ / ‘our’/ ‘Company’) understands and respects the importance of your privacy and is committed to safeguarding your personal information. In providing our service to you, we must collect personal information from you, and this policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
Early Learning Management is bound by The Privacy Act 1988 (Cth) (‘Act’) as amended from time to time. This document sets out the Company’s policy with the protection of personal information, as under the Act and the Australian Privacy Principles (‘APPs’). The APPs regulate the handling of personal information.
The Act regulates how public agencies and individual private organisations can collect, hold, use and disclose personal information, and how you can access and correct that personal information. The Act applies only to information about individuals, not to information about corporate entities such as businesses, firms or trusts.
This Policy sets out how Early Learning Management complies with the Act and addresses how we collect, hold, use and disclose your personal information, including any financial information that you provide to Early Learning Management.
If we do not receive personal information about you, this Policy will not apply.
What is personal information?
Personal information is information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identified individual, and an indication of intention in respect of an individual. Personal information may be collected directly by Early Learning Management from you (or your representative), or via a third party. In most situations, Early Learning Management collects personal information about an individual from the Early Learning Management client or from the Early Learning Management client where the parent/guardian has a child enrolled in the childcare centre. In particular, we may also collect your personal information when you:
Register on our website to use the services we provide;
(a) post to the Early Learning Management Forum, blogs or on any of our social media platforms including but not limited to Facebook, Twitter and Instagram;
(b) contact the Early Learning Management support team; and
(c) visit our website.
Where Early Learning Management is provided with personal information by its clients;
Early Learning Management relies on its clients having obtained the consent of the individual for the collection, use, and disclosure of his or her personal information to and by Early Learning Management. Early Learning Management will not ask you for any personal information which we do not need. The Act requires that we should only collect information for a purpose that is reasonably necessary for or directly related to our activities and operations.
This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record. An employee record is a record of personal information relating to the employment of an employee. Examples of personal information pertaining to the employment of an employee include, but are not limited to, health information and information about the engagement, training, disciplining, resignation, termination, and terms and conditions of employment of the employee. Please see the Act for further examples of employee records.
Information we may collect from you
Early Learning Management collects only the information necessary to provide its services.
The information you give us; specifically, Early Learning Management collects and holds the following types of personal information (which will vary depending on the context of the collection):
(a) Name, address and contact details (for example email, phone and fax) – including for parents/guardians and their child(ren);
(b) Information about employment on its employees (for example user ID, salary details, payroll details, superannuation contributions, PAYG withholding tax). Early Learning Management utilises this information for its payroll product ‘iPayrollPro’ for all of its childcare centres;
(c) Information about identity (for example date of birth) – including for parents/guardians and their child(ren);and
(d) Information about financial affairs (for example banking details, payment details) – including for parents/guardians and their child(ren).
Information we collect about you
Concerning each of your visits to our website, we may automatically collect the following information Technical information, including the following:
(b) Browser type and version;
(c) Time zone setting;
(d) Browser plug-in types and versions; and
(e) Operating system and platform; and
(f) Information about your visit, including the following:
Full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time);
Products you viewed or searched for; and
Page response times download errors, the length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Early Learning Management will generally only collect personal information from its website where a person chooses to provide that information. If you visit our website to download or read information, then we may record technical information (for example your IP or server address, the time and date of your visit, and your general locality) which does not reveal your identity. This information is used for monitoring and development purposes. Early Learning Management will not make any attempt to identify you in these circumstances, other than in exceptional circumstances, for example, an investigation into the improper use of the website.
Some functionality of our website is run by third parties, for example, Google, Twitter, Facebook, LinkedIn and YouTube, who may capture and store your personal information, including outside of Australia. Those third parties may not be subject to the Act. Early Learning Management is not responsible for the privacy policies of third parties. We encourage you to examine each website’s privacy policies and make your own decisions. Our website may contain links to other websites. Early Learning Management is not responsible for the content or the privacy policies of external websites.
Unsolicited Personal Information
If we receive unsolicited personal information that could not have been obtained through solicited means on reasonable terms, we confirm that the data will be destroyed as soon as reasonably possible.
In some circumstances, we may collect personal information from you which is regarded as sensitive information pursuant to the Act (‘Sensitive Information’). Sensitive Information includes types of personal information such as:
(a) your racial or ethnic origin;
(b) religious beliefs or affiliations;
(c) criminal record; and
(d) health information (which may include information about your medical history, immunisations, allergies, special needs, disabilities or injuries) – including for parents/guardians and their child(ren). We will only collect Sensitive Information when necessary:
(e) in accordance with section 3.3 of the APPs as set out in the Act; and
(f) about you with your consent and where reasonably necessary for, or directly related to, one or more of our functions or activities.
Where you provide Sensitive Information to us, you consent to us using that Sensitive Information for the purpose for which it was collected. For example, if you provide health information to us, you consent to us using and disclosing that health information in connection with arranging our service.
Purposes for which personal information is collected and held
By providing us, or otherwise allowing us to collect your personal information, you consent to us using and disclosing your personal information for the purposes for which it was collected, and for related or ancillary purposes. We use information held about you for a number of different purposes relating to its activities and services, including:
(a) providing payroll services and child care management services;
(b) billing and account management;
(c) for internal business operations such as planning, product development, research, and reporting to Early Learning Management-related entities;
(d) advising clients on functions and product launches; and
(e) providing direct market offers for products and services provided by or on behalf of Early Learning Management (or other organisations), which Early Learning Management considers being of interest to its clients.
Early Learning Management uses and discloses personal information for the primary purpose for which it is collected. We will only use your personal information for secondary purposes where we are permitted to do so in accordance with the Act. With respect to information, we receive from other sources; We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive). We are only allowed to store your personal information for as long as necessary having regard to the purpose for which it was collected or a related or ancillary purpose. We may, therefore, delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.
Collection and storage of personal information methods
Early Learning Management collects personal information through a number of different methods, including:
(b) telephone and facsimile communications;
(c) email communications; and
(d) electronic and paper-based forms.
Disclosure of personal information
Early Learning Management does not sell or rent personal information to anyone. However, in using personal information, it may be necessary for Early Learning Management to disclose personal information to various organisations and/or parties, such as:
(a) the Australian Taxation Office;
(b) banking/financial institutions;
(c) superannuation authorities;
(d) health insurance organisations;
(e) contracted service providers;
(f) business partners; and
(g) related companies of Early Learning Management.
Early Learning Management may also disclose personal information in special cases when Early Learning Management believes, in good faith, that such action is reasonably necessary, for example to:
(a) conform to legal requirements or comply with legal process;
(b) protect and defend Early Learning Management’s rights or property;
(c) enforce Early Learning Management’s contractual arrangements; or
(d) protect the interests of Early Learning Management’s clients or others; and
(e) Early Learning Management will take seriously any unauthorised or accidental disclosure of personal information. We may also disclose your personal information to third parties. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
Other than with respect to the permitted disclosures set out above, and with respect to the overseas recipients detailed below, We will not disclose your personal information without your consent unless We reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), disclosure is authorised or required by law or disclosure is otherwise permitted by applicable privacy laws.
When you provide or otherwise allow us to collect your personal information, you consent to your personal information being disclosed to certain overseas recipients, as set out below under ‘Where we store your personal data’. Where we disclose your personal information to an overseas recipient, you agree that we will not be required to ensure the recipient’s compliance with Australian privacy laws or otherwise be liable or accountable for how the recipient handles your personal information. Although as outlined above, we will take reasonable steps in order to ensure that the overseas recipient complies with the Act and the APPs. If you have any objections to your personal information being disclosed to an overseas recipient, please let us know on the contact details form.
You have the right to ask us not to process your data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
We confirm that we will issue emails to our clients confirming the details of Our latest offers, news and updates, Please note that we will not inform you beforehand further than the information provided in this document that we intend to issue this material. If you wish to unsubscribe from receiving our promotional material, please email [email protected] to unsubscribe.
You can exercise your right to prevent the processing set out above by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us via the contact details outlined in the Policy.
Before we disclose personal information about you to a third party, we will take steps as are reasonable in the circumstances to ensure that you are aware that we have collected the information and the purpose of collecting the third party does not breach the APPs in relation to the information.
If you wish to make a complaint in relation to the collection and use of your personal information or any effects to your rights with respect to your personal information or place a request to amend information held about you.
How to correct, access and update your personal information
You are legally obliged always to provide us with accurate information, and you agree to update it whenever necessary. You also agree that, in the absence of an update, we can assume that the information submitted to us is correct.
You can also choose not to provide us with some of the information we request, however. As a result, we may not be able to provide our service to you.
To ensure that we carry out your instructions accurately, to help improve our service and in the interest of security, we may monitor and/or record:
(a) your telephone calls; and
(b) customer activities on our website. All recordings are and shall remain our sole property.
Anonymity and Pseudonymity
You have the option of not identifying yourself or using a pseudonym when dealing with the Company in relation to a particular matter. This does not apply where:
(a) the Company is required or authorised by or under Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
(b) it is impracticable for the Company to deal with individuals who have not identified themselves or who have used a pseudonym,
(c) however, in some cases, if you do not provide the Company with your personal information when requested, the Company may not be able to respond to your request or provide you with the goods or services that you are requesting.
If you believe we may have breached your privacy rights you may contact us using the contact details set out below. Early Learning Management is committed to achieving a speedy and fair resolution of any complaints and will ensure that your complaint is taken seriously. We will respond to your complaint or request promptly if you provide your contact details to us.
How to contact us
If you wish to:
(b) seek correction of or obtain access to your personal information;
(c) ask about how your personal information is collected, used, held or disclosed; or
(d) make a complaint about a breach of your privacy,
You may contact Early Learning Management’s Privacy Officer using the following contact details:
(a) [email protected]
(b) Privacy Officer – PO Box 6309 Gold Coast MC Qld 9726; and
(c) 07 5592 5800