Domestic Privacy Policy and Procedure

1. Purpose and Scope

This policy shows Axial is committed to respecting and protecting personal information in compliance with the Privacy Act 1988 (Cth). This policy outlines Axial’s approach to managing personal information, ensuring privacy in the collection, use, and disclosure of data while upholding safety and transparency for all students, staff, and stakeholders.

This policy applies to all Axial employees, contractors, students, partners, and stakeholders involved in handling personal information. It covers all divisions of Axial, including Axial Training, VET in Schools and Axial International College, and adheres to ASQA standards, CRICOS requirements, and the ESOS Act.

2. Policy

Axial Training is committed to ensuring comprehensive protection and management of personal information across all Axial divisions.

2.1 Collection of Personal Information

  • Direct Collection: Axial collects personal information directly from individuals during enrolment, course progression, and employment applications. This may include contact details, education history, health information, and banking details.
  • Third-Party Collection: Information may also be gathered from social media platforms, Axial International College commercial partners, and government agencies to facilitate enrolment, support funding requests, or comply with legal obligations.
  • Types of Information: Collected information includes personal identifiers, contact information, education records, health and sensitive data, payment details, and training-related details as necessary.

2.2 Use and Disclosure of Personal Information

  • Primary Purpose: Information is used for enrolment processing, identity verification, course administration, and student support services.
  • Secondary Purposes: Axial may use personal information for promotional activities, operational support, research, and compliance with government requirements.
  • Data Sharing: Information may be disclosed to:
    • Government authorities, including NCVER, for VET data reporting.
    • Commercial and educational partners for joint programs.
    • Employers (for employer-sponsored training) and parents/guardians (for minors), with the consent of the student.

2.3 Health and Sensitive Information

  • Collection: Health and sensitive information, including racial or ethnic data, is collected only with consent or when required by law, primarily for supporting safe participation in training.
  • Use: Sensitive information is used to tailor student support services and maintain health and safety standards. De-identified data may be used for research and submissions to government bodies.

2.4 Website and Online Privacy

  • Cookies: Axial’s website uses cookies to enhance user experience. Users may disable cookies in their browser settings, though this may affect website functionality.
  • Third-Party Links: Axial’s website may include links to third-party sites, which operate independently. Users should refer to those sites’ privacy policies for information on data practices.
  • IP Address Collection: Axial may collect IP addresses for session management and security purposes.

2.5 Accuracy and Access to Information

  • Ensuring Accuracy: Axial takes reasonable steps to maintain the accuracy of information through regular updates and user verification. International students are required to keep contact information up to date including residential address.
  • Accessing Records: Students and staff may access their information by submitting a written request. Axial will provide access within 14 days, or longer if archived information retrieval is needed.

2.6 Data Provision Requirements 2012

  • NCVER Data: Under the Data Provision Requirements 2020, Axial discloses personal information to NCVER for VET research, policy analysis, and educational evaluation. NCVER may contact students for survey purposes, with an option to opt out.
  • Use of VET Data: Collected VET data may be used by NCVER for authenticated transcripts, regulatory purposes, workforce planning, and consumer information. This aligns with the National VET Data Policy and ASQA’s reporting requirements.

2.7 Working with Children and Minors

  • Safeguarding Children: Axial is committed to the safety of minors, in line with the National Principles for Child Safe Organisations. The organisation maintains a safe, inclusive environment with procedures to safeguard children from harm.
  • Working with Children Checks (WWC): Staff working with minors undergo appropriate checks (Blue Card) to ensure compliance with child protection laws.

2.8 Privacy Complaints and Contact Information

  • Complaint Process: Axial takes privacy complaints seriously and investigates all claims confidentially. Complaints should be directed to Axial’s Student Support Office at complaints@axial.edu.au
  • Contact Information: For questions regarding privacy or access to personal data, individuals may contact:

2.9 Policy Updates and Changes

  • Policy Review: This policy is reviewed regularly to reflect legislative or operational changes. Updates will be posted on the Axial website.

3. Procedures

This procedure provides a clear and systematic approach to managing personal information in compliance with the Privacy Act 1988, ASQA standards, CRICOS requirements, and the ESOS Act. It ensures Axial handles personal information responsibly, securely, and transparently.

Axial Training is committed to ensuring comprehensive protection and management of personal information across all Axial divisions.

3.1 Collection of Personal Information

Direct Collection: Collect personal information from students and staff during enrolment, course progression, and employment. Ensure that information collected is relevant and necessary.

Third-Party Collection: Obtain information from external parties only when necessary for training delivery, funding requirements, or legal compliance.

Responsible Parties: Sales, Administration Team, Student Support Officers

3.2 Use and Disclosure of Information

Primary Use: Use personal information for enrolment, identity verification, and training administration purposes only.

Disclosure for Regulatory and Operational Needs: Share information with government authorities, industry partners, and legal entities as required by law and for training-related purposes. Obtain consent where required.

Responsible Parties: Director - Compliance and Quality Assurance, Chief Executive Officer

3.3 Handling of Sensitive Information

Health and Safety: Collect sensitive information (e.g., health, racial data) only with consent, primarily to support student health, safety, and welfare.

Confidential Use: Use sensitive data exclusively for individualised support or regulatory compliance. Ensure such information remains confidential and secure.

Responsible Parties: Trainers, Student Support Officers, Administration Team

3.4 Online Privacy and Website Usage

Cookie Management: Inform users of cookie usage on Axial’s website and provide the option to disable cookies if preferred.

Third-Party Links: Advise users on Axial’s website that external links may have their own privacy practices. Ensure links are relevant and vetted for compliance.

Responsible Parties: IT Team, Marketing Team

3.5 Accuracy and Access to Information

Updating Information: Encourage students and staff to keep personal details current. Conduct periodic checks and allow individuals to update their information as necessary.

Access Requests: Process requests for access to personal information within 14 days, verifying identity and ensuring secure handling.

Responsible Parties: Administration Team, Student Support Officers

3.6 Compliance with Data Provision Requirements

NCVER Data Reporting: Regularly submit data to the NCVER in compliance with the Data Provision Requirements 2020. Ensure data is accurate and securely transferred.

VET Data Use: Use VET data only for regulatory, policy, and research purposes as directed by NCVER and ASQA standards.

Responsible Parties: Director – Compliance and Quality Assurance, Administration Team

3.7 Child Safety and Minors

Safeguarding Children: Ensure all staff working with minors have up-to-date Working with Children Checks (Blue Card) and are trained on child safety practices.

Child Safe Environment: Implement a safe, supportive environment for minors, ensuring they are protected from harm or discrimination.

Responsible Parties: Trainers, Director - Compliance and Quality Assurance

3.8 Privacy Complaints and Contact Process

Handling Complaints: Address privacy complaints confidentially and impartially within 14 days. Ensure complainants are informed of investigation outcomes.

Contact Points for Queries: Provide accessible contact details for all privacy-related questions and concerns.

Responsible Parties: Student Support Officers, Chief Executive Officer

Flowchart for Privacy

This sequence represents the procedural flow, showing each step from collection to complaint handling.

flowcart-for-privacy

Glossary

Access Request: A formal request by an individual to view or retrieve their personal information stored by Axial, processed according to the Privacy Act 1988.

ASQA (Australian Skills Quality Authority): The regulatory body overseeing vocational education and training standards, including privacy and data reporting requirements for RTOs.

Child Safe Environment: A framework ensuring that the rights and safety of minors are protected, in alignment with child protection laws and principles.

Cookies: Small text files used by websites to track and personalize user experiences, which users can manage through browser settings.

CRICOS (Commonwealth Register of Institutions and Courses for Overseas Students): A national registry for providers authorised to deliver courses to overseas students, requiring strict adherence to data protection standards.

Data Breach: An incident involving unauthorised access, loss, or disclosure of personal information that could compromise privacy.

Data Provision Requirements 2012: Regulatory standards requiring RTOs to collect and report data to NCVER, ensuring transparency in training outcomes.

ESOS Act (Education Services for Overseas Students Act 2000): Legislation protecting the rights and welfare of international students studying in Australia, ensuring fair treatment and privacy.

Health and Sensitive Information: Personal data about an individual’s health, racial or ethnic origin, or other protected attributes, which requires additional safeguards and consent before collection.

NCVER (National Centre for Vocational Education Research): A national organization that collects and analyses VET data, using it for research, policy, and evaluation.

Privacy Act 1988: Federal legislation that regulates the handling of personal information, setting guidelines for collection, use, disclosure, and security.

Reasonable Adjustments: Modifications made to training or assessments to accommodate individual needs, ensuring equitable access without compromising standards.

Acknowledgement to Country

The Axial Training community acknowledges the Traditional Custodians of the land upon which we gather each day. We pay our respects to the Elders past and present, for they hold the memories, traditions, culture and hopes of Aboriginal and Torres Strait Islander peoples across the nation.

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