GenConnect: Guidelines of Use and Privacy Policy

Genazzano FCJ College is committed to complying with the National Privacy Laws by ensuring the
privacy of all stakeholder information (students, staff and parents). This policy explains how the
College will manage personal information in compliance with the privacy laws. Such National Laws
include the:
- Privacy Amendment (Enhancing Privacy Legislation) Act 2012 (Cth)
- Health Records Act 2001 (Vic)

1. Collection of personal information
The College collects and holds personal information that is reasonably necessary for, or directly
related to, the operation of the College and for the purpose of providing educational services to
the students.
The College will collect personal information from:
􀁸 Prospective students, current students and their parents/guardians
􀁸 Staff members, job applicants, volunteers and independent contractors
􀁸 Other persons with whom the College may have dealings.

The kinds of personal information the College collects and holds includes:
􀁸 Names, date of birth, identity documents, photographs, health information and sensitive
information
􀁸 Contact details and addresses
􀁸 employment history, qualifications, police record, references

The College collects personal information in the following ways:
􀁸 from parents/guardians through the enrolment process, face-to-face meetings, over the
telephone and during the school year by way of forms completed by parents/guardians or
students
􀁸 from students during the course of their enrolment at the College
􀁸 from third persons such as medical practitioners and health advisers
􀁸 from prospective employees through the recruitment process, at interviews, from past
employers and referees
􀁸 from volunteers and contractors through our engagement processes.

Health information includes:
􀁸 Information or an opinion, that is also personal information, about:
o The health or a disability (at any time) of an individual
o An individual’s expressed wishes about the future provision of health services to him
or her, or
o A health service provided, or to be provided, to an individual, or
􀁸 Other personal information collected to provide, or in providing, a health service.

Sensitive information is a subset of personal information and includes:
􀁸 Information or opinion, that is also personal information, about an individual’s:
o Racial or ethnic origin
o Political opinions
o Membership of a political association
o Religious beliefs or affiliations

Privacy Policy
o Philosophical beliefs
o Membership of a professional or trade association
o Membership of a trade union
o Sexual preferences or practices, or
o Criminal record.
􀁸 Health information about an individual.

We may also collect personal information, including sensitive information, if the information is
required or authorised by or under an Australian law. If we do collect personal information in
these circumstances we will notify the individual(s) of that fact (and of the name of the
Australian law that requires or authorises the collection of the information). The College may
disclose personal student and parent information to overseas recipients where approval to do
so has been granted (eg. international student tours).

2. Purpose of collecting, holding, using and disclosing personal information
The College will not collect personal information about an individual unless it is reasonably
necessary for its functions and activities. The College will not collect sensitive information
unless consent is provided and the information is necessary for, or directly related to, the
functions and activities of the College.
In the case of students and parents, the purpose for collecting, holding, using and disclosing
personal information include:
􀁸 enable the student’s application for enrolment to be properly assessed
􀁸 keep parents informed about matters related to their child’s schooling
􀁸 assist with the administration of the College’s operations
􀁸 look after the education and social and wellbeing of the student
􀁸 seek donations and fundraising assistance for the College
􀁸 satisfy the College’s legal obligations as an educational institution and to discharge its duty
of care to its students
􀁸 to inform Genazzano FCJ College Alumnae Inc and College clubs and parent associations of
contact details for members and parents.*
( * Such details can be withheld upon individual request)

In the case of job applicants, volunteers and contractors, the purpose for collecting, holding,
using and disclosing personal information include:
􀁸 to assess and, if successful, engage the person at the College
􀁸 to assist with the administration of the College’s operations
􀁸 to satisfy the College’s legal obligations as an educational institution and to discharge its
duty of care to its students.

If a parent/guardian or student does not provide the College with the information it seeks then
it may not be able to enrol or continue the enrolment of the student or be able to provide
necessary services to the student during their education at the College.
If a job applicant, volunteer or contractor does not provide the College with the personal
information it seeks then the College may not be able to engage or continue to engage the
person at the College.

In the conduct of its operations, the College may need to disclose the personal information it
holds to:
􀁸 Relevant government departments, agencies or authorities
􀁸 Diocesan and Parish authorities
􀁸 Parents
􀁸 Recipients of the College’s publications like newsletters and magazines
􀁸 Other schools with whom the College interacts
􀁸 Medical practitioners and other providers of health or wellbeing services
􀁸 Insurance companies
􀁸 Persons that provide services to the College including visiting teachers and specialist
visitors, sports coaches, camp and excursion providers
􀁸 Genazzano Alumni Inc and College parent associations.

The College may also publish information such as academic and sporting achievements, student
activities and other news in College publications, website and newsletters.
The College is likely to disclose personal information to overseas recipients only if it is directly
relevant to an educational program being conducted by the College and only with the written
consent of the individual concerned. In some cases this consent may be implied. It is not
practicable to specify in this policy the countries in which such recipients are likely to be
located.

3. Personal information about students
The College will generally collect information about students from their parents/guardians.
However, there may be occasions when the College may also collect personal information
about students directly from them.
The College will usually disclose information about its students to their parents/guardians.
However, there may be occasions when it is appropriate that access and disclosure of such
information to parents should be lawfully denied. Also, the College may at its discretion
provide a student access to information held about them or allow a student to give or withhold
consent to the use or disclosure of their personal information.

4. Access to personal information
Requests for access to information the College holds about an individual may be made and the
College will respond to such requests within a reasonable time.
Advice can also be provided to the College to correct Personal information if it is inaccurate.
Unsuccessful job applicants’ details will be destroyed unless the College requests and consent is
provided to the information being held for future positions that may arise.
The College will take reasonable steps to ensure that all personal information held by it is up-todate,
complete, relevant, not misleading and accurate.
In some circumstances, it may be lawful for the College to refuse access to the personal
information it holds.
Requests for access or correction of your personal information are to be made to the Privacy
Officer (College Business Manager):
The Privacy Officer
Genazzano FCJ College
301 Cotham Street
Kew Vic 3101
Telephone: (03) 8862 1000
Fax: (03) 8862 1133
Email: busmgr@genazzano.vic.edu.au
Please note that this policy does not apply to the records of job applicants who become an
employee of the College.

5. Security and quality of your personal information
The College will take reasonable steps to protect the personal information it holds from misuse,
interference and loss and from unauthorised access, modification or disclosure by use of
various methods including locked storage of paper records and password access rights to
computer records. Further, the College staff are required to respect the confidentiality of
personal information held by the College.
The College will also take reasonable steps to ensure that the personal information it collects,
uses or discloses is accurate, up to date, complete and relevant.

6. Notification of collection of personal information
You are notified by this Privacy Policy of the collection of your personal information by:
Genazzano FCJ College Limited
301 Cotham Street
Kew Vic 3101

A Collection Notice will be included with all Enrolment and Employment letters of offer. A copy
of the policy will be included on the College website, intranet (GenSpace) and available for
inspection at the main College Reception.

7. Complaints
Complaints can be made if it is considered that the College has interfered with privacy of an
individual(s) because of an alleged breach of the privacy principles under the privacy laws.
The procedure for a complaint is:
(a) A written complaint must be forwarded to the Privacy Officer and must specify details of
the alleged breach.
(b) The Privacy Officer will consider your complaint and make a determination within 45 days.
You will be advised of the determination in writing.
(c) If the Privacy Officer determines that there has been a breach of the privacy principles, he
or she will advise the relevant persons at the College in writing of any action required in
order to remedy the breach. If the breach is not remedied within 30 days the Privacy
Officer must inform the Principal of the College.
(d) The Privacy Officer will keep a record of all complaints and determinations together with a
record of the action taken to remedy any breach.

______________________________________________________________________

REPORTING AND REVIEW

This policy will be the responsibility of the Privacy Officer to administer and maintain in accordance
with the requirements above and relevant legislation. The policy will be reviewed by the Privacy
Officer every three years (or as legislation changes) with recommended changes to be presented to
the College Executive and College Council.

1. The College collects personal information, including sensitive information about pupils and parents or
guardians before and during the course of a pupil’s enrolment at the College. This may be in writing or in
the course of conversations. The primary purpose of collecting this information is to enable the College
to provide schooling to the pupil and to enable them to take part in all the activities of the College.

2. Some of the information the College collects is to satisfy the College’s legal obligations, particularly to
enable the College to discharge its duty of care.

3. Laws governing or relating to the operation of a College require certain information to be collected and
disclosed. These include relevant Education Acts and Public Health and Child Protection laws.

4. Health information about pupils is sensitive information within the terms of the Australian Privacy
Principles under the Privacy Act. We may ask you to provide medical reports about pupils from time to
time.

5. The College from time to time discloses personal and sensitive information to others for administrative
and educational purposes, including to facilitate the transfer of a pupil to another school. This includes to
other schools, government departments, (Catholic Education Office, the Catholic Education Commission,
the College’s local diocese and the parish, Schools within other Dioceses / other Dioceses) medical
practitioners, and people providing services to the College, including specialist visiting teachers, (sports)
coaches, volunteers and counsellors.

6. Personal information collected from pupils is regularly disclosed to their parents or guardians.

7. The College may store personal information in the ‘cloud’ which may mean that it resides on servers
which are situated outside Australia.

8. The College’s Privacy Policy sets out how parents or pupils may seek access to personal information
collected about them. However, there will be occasions when access is denied. Such occasions would
include where access would have an unreasonable impact on the privacy of others, where access may
result in a breach of the College’s duty of care to the pupil, or where pupils have provided information in
confidence

9. The College Privacy Policy also sets out how an individual may complain about a breach of privacy and
how the College will deal with such a complaint.

10. The College from time to time engages in fundraising activities. Information received from families may
be used as a part of the fundraising appeal process. We will not disclose personal information to third
parties for their own marketing purposes without parental consent.

11. On occasions information such as academic and sporting achievements, pupil activities and similar news
is published in College newsletters and magazines (and on our website). Photographs of pupil activities
such as sporting events, school camps and school excursions may be taken for publication in College
newsletters and magazines and on our intranet. The College will obtain separate permissions from the
pupils’ parent or guardian prior to publication if the College wishes to include photographs or other
identifying material in promotional material for the College or otherwise make it available to the public
such as on the internet.

12. The College will include pupils’ and pupils’ parents’ contact details in a class list and College Directory
(requests for details to be withheld can be made).

13. If an individual provides the College with the personal information of others, such as doctors or
emergency contacts, we encourage the individual to inform others that such information is being
disclosed to the College and why, that they can access that information if they wish and that the College
does not usually disclose this information to third parties.