Privacy Policy

1. Purpose

Maitland Christian School Limited is an independent Christian educational community, that aims to grow faith, character and abilities through teaching and learning excellence, in partnership with families and the local church. It was established by Metford Community Baptist Church in 1983 and continues to be a ministry of Metford Community Baptist Church. Our School Core Values are Faith, Unity, Excellence, Generosity and Growth. Maitland Christian School Limited operates two schools – Maitland Christian School and Arise Christian College.

This Privacy Policy sets out how the School manages personal information provided to or collected by it, and your rights in relation to your personal information, including how to complain and how we deal with complaints.

The School is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988 (Privacy Act). In relation to health records, the School is also bound by the New South Wales Health Privacy Principles which are contained in the Health Records and Information Privacy Act 2002 (NSW) (Health Records Act).

The School may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to the School's operations and practices and to make sure it remains appropriate to the changing school environment.

2. Scope

This Policy applies to all School staff regarding the collection, use and safe storage of staff, student and family personal and confidential information or data.

3. Responsibilities

1. The Board is the Approver of this policy.
2. The Head of Operations is responsible for ensuring the implementation and communication of this policy.
3. The Executive Principal is responsible to ensure this policy is adopted.

4. What kinds of personal information the School collects and how it collects it

4.1 The type of information we collect

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

1. students and parents and/or guardians ('Parents') before, during and after the course of a student's enrolment at the School, including:
   • name, contact details (including next of kin), date of birth, gender, language background, previous school and religion;
   • parents' education, occupation and language background;
   • medical information (e.g. details of disability and/or allergies, absence notes, medical reports and names of doctors);
   • conduct and complaint records, or other behaviour notes, and school reports;
   • information about referrals to government welfare agencies;
   • counselling reports;
   • health fund details and Medicare number;
   • any court orders;
   • volunteering information;
   • school surveillance images (including by using the School's VSS (Video Surveillance Systems) system for the potential use of Facial Recognition, Number Plate Recognition and Movement Tracking)
   • photos and videos at School events;
2. job applicants, staff members, volunteers and contractors, including:
   • name, contact details (including next of kin), date of birth, and religion;
   • information on job application;
   • professional development history;
   • salary and payment information, including superannuation details;
   • medical information (e.g. details of disability and/or allergies, and medical certificates);
   • complaint records and investigation reports;
   • leave details;
   • photos and videos at School events and from sign-in system;
   • workplace surveillance information; and
   • work emails and private emails (when using work email address) and Internet browsing history;
3. anyone who enters the School property who is captured by the School's VSS (Video Surveillance Systems), including:
   • Facial Recognition
   • Number Plate Recognition
   • Movement Tracking
   • 24-hour access in darkness and daytime via the internet portal and/or App
   • We DO NOT use voice recording technology.
4. other people who come into contact with the School, including name and contact details and any other information necessary for the particular contact with the School, including photos taken by sign-in system.

4.2 How we collect information

1. Personal Information you provide: The School will generally collect personal information held about an individual by way of forms filled out by parents or students (including electronic forms), face-to-face meetings and interviews, emails, and telephone calls. On occasions people other than parents and students provide personal information.
2. 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.
3. Exception in relation to employee records: Under the Privacy Act and the Health Records Act, the Australian Privacy Principles and Health Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to the School's treatment of an employee record, where the treatment is directly related to a current or former employment relationship between the School and employee.
4. Personal information from other sources: We may also collect personal information through surveillance activities (such as Video Surveillance Systems security cameras) and email filtering.

5. How the School uses personal information

5.1 Use and Management

1. The School will use personal information it collects from you for the primary purpose of collection, and for such other secondary purposes that are related to the primary purpose of collection and reasonably expected, or to which you have consented.
2. The School will manage the storage and destruction of data it has collected, for the time required by regulatory bodies and in keeping with the School's Information Management and Record Keeping Policy.

5.2 Students and Parents

1. In relation to personal information of students and parents, the School's primary purpose of collection is to enable the School to:
   • provide schooling to students enrolled at the school,
   • exercise its duty of care, and
   • perform necessary associated administrative activities, which will enable students to take part in all the activities of the School. This includes satisfying the needs of parents, the needs of the student and the needs of the Principal and School throughout the whole period the student is enrolled at the School.
2. The purposes for which the Principal and School uses personal information of students and parents include:
   • to keep Parents informed about matters related to their child's schooling, through correspondence, apps, newsletters and magazines;
   • day-to-day administration;
   • looking after students educational, social, spiritual and medical wellbeing;
   • seeking donations and marketing for the School; and
   • to satisfy the Principal and School's legal obligations and allow the School to discharge its duty of care.
3. In some cases where the School requests personal information about a student or parent, if the information requested is not obtained, the School, at its ultimate discretion, may not be able to enrol or continue the enrolment of the student or permit the student to take part in a particular activity.

5.3 Job applicants and contractors

1. In relation to personal information of job applicants and contractors, the School's primary purpose of collection is to assess and (if successful) to engage the applicant or contractor.
2. The purposes for which the School uses personal information of job applicants and contractors include:
   • assessing and (if successful) engaging the applicant or contractor;
   • administering the individual's employment or contract;
   • for insurance purposes;
   • seeking donations and marketing for the School; and
   • satisfying the Executive Principal and School's legal obligations, for example, in relation to child protection legislation.

5.4 Volunteers

1. The School also obtains personal information about volunteers to:
   • assist the School in its functions or conduct associated activities,
   • to enable the School and the volunteers to work together,
   • for insurance purposes, and
   • satisfy the School's legal obligations, for example, in relation to child protection legislation.

5.5 Marketing and fundraising

1. The School treats marketing and seeking donations for the future growth and development of the School as an important part of ensuring that the School continues to provide a quality learning environment in which both students and staff thrive. Personal information held by the School may be disclosed to organisations that assist in the School's fundraising, for example, the School's alumni organisation or, on occasions, external fundraising organisations.
2. Parents, staff, contractors and other members of the wider School community may from time to time receive fundraising information. School publications, like newsletters and magazines, which include personal information, may be used for marketing purposes.
3. If you do not want to receive fundraising communications from us, please contact our Privacy Officer.

5.6 Exception in relation to related Schools

1. The Privacy Act allows each school, being legally related to each of the other schools conducted by Maitland Christian School Ltd to share personal (but not sensitive) information with other schools conducted by Maitland Christian School Ltd.
2. Other Maitland Christian School Ltd schools may then only use this personal information for the purpose for which it was originally collected by Maitland Christian School Ltd. This allows schools to transfer information between them, for example, when a pupil transfers from one Maitland Christian School Ltd school to another school conducted by Maitland Christian School Ltd.

6. Who the School might disclose personal information to and store it with

6.1 Who we disclose information to

1. The School may disclose personal information, including sensitive information, held about an individual for educational, administrative, welfare and/or support purposes. This may include to:
   • other schools and teachers at those schools, including a new school to which a student transfers to facilitate the transfer of the student;
   • government departments (including for law enforcement, policy and funding purposes);
   • medical practitioners;
   • people providing educational, support and health services to the School, including specialist visiting teachers, music coaches, volunteers, and counsellors;
   • providers of specialist advisory services and assistance to the School, including in the area of Human Resources, child protection, and students with additional needs;
   • providers of learning and assessment tools;
   • assessment and educational authorities, including the Australian Curriculum, Assessment and Reporting Authority (ACARA) and NAPLAN Test Administration Authorities (who will disclose it to the entity that manages the online platform for NAPLAN);
   • agencies and organisations to whom we are required to disclose personal information for education, funding and research purposes;
   • people providing administrative and financial services to the School;
   • recipients of School publications, such as newsletters and magazines;
   • pupils' parents or carers;
   • anyone you authorise the School to disclose information to; and
   • anyone to whom we are required or authorised to disclose the information to by law, including child protection laws.

6.2 Storage and security of personal information

6.2.1 How we store personal information

1. The School stores personal information in hard copy and electronically, on a variety of devices including servers, laptop and desktop computers, mobile phones, cameras, and other recording devices.
2. The School may use online or 'cloud' service providers to store personal information and to provide services to the School that involve the use of personal information, such as services relating to email, instant messaging and education and assessment applications.
3. The security of your personal information is of importance to us and we take all reasonable steps to protect the personal information we hold about you from misuse, interference and loss and from unauthorised access, modification or disclosure. The School has systems and processes in place for the review and approval of all software and ICT systems used in the School. This includes a review of the compliance of all systems with the Australian Privacy Principles, an assessment of the compliance of the system with the General Data Protection Regulation (GDPR - the personal data protection requirement adopted by Europe), and determination of the purpose, accessibility and sovereignty of all data used and stored by the system. The IT Manager has the final approval for all software use in the School and ensure that all systems meet these requirements.
4. Some limited personal information may also be provided to these service providers to enable them to authenticate users that access their services. This personal information may be stored in the 'cloud' which means that it may reside on a cloud service provider's server which may be situated outside Australia.
5. An example of such a cloud service provider is Microsoft Office 365. Microsoft provides 'Office 365 for Education' including Email, and stores and processes limited personal information for this purpose. School personnel and its service providers may have the ability to access, monitor, use or disclose emails, communications (e.g. instant messaging), documents and associated administrative data for the purposes of administering the Office 365 suite and ensuring its proper use.

6.2.2 Sending and storing information overseas

1. The School may disclose personal information about an individual to overseas recipients, for instance, to facilitate a school exchange.
2. The School may use online or 'cloud' service providers to store personal information and to provide services to the School that involve the use of personal information, such as services relating to email, instant messaging and education and assessment applications. Some limited personal information may also be provided to these service providers to enable them to authenticate users that access their services and provide technical support. This personal information may be stored in the 'cloud' which means that it may reside on a cloud service provider's servers which may be situated outside Australia.

7. How the School treats sensitive information

1. In referring to 'sensitive information', the School means 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 orientation or practices
   • criminal record, that is also personal information
   • health information and biometric information
2. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or the use or disclosure of the sensitive information is allowed by law.

8. Management and security of personal information

8.1 Protect Personal Information

1. The School's staff are required to respect the confidentiality of students and parents' personal information, and the privacy of individuals.
2. The School has in place reasonable steps to protect the personal information the School holds from misuse, interference and loss, unauthorised access, modification or disclosure by use of various methods including locked storage of paper records and password access rights to computerised records. These steps include:
   • Restricting access to information on the School databases on a need-to-know basis with different levels of security being allocated to staff based on their roles and responsibilities and security profile.
   • When an employee leaves the School, any digital devices provided to the employee for the purpose of carrying out their work are returned and all accounts the employee had access to are deactivated.
   • Ensuring all staff are aware that they are not to reveal or share personal passwords.
   • Ensuring where personal and health information is stored in hard copy files that these files are stored in lockable filing cabinets in lockable rooms. Access to these records is restricted to staff on a need-to-know basis.
   • Implementing physical security measures around the School buildings and grounds to prevent break-ins.
   • Implementing ICT technical controls, policies and procedures, designed to protect personal information storage on our computer networks.
   • Implementing human recourses policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling personal information.
   • Undertaking due diligence with respect to third party service providers who may have access to personal information, including cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
   • Ensuring that data retention and destruction protocols are in place and followed as per our Record Management Policy and other related guidelines that support the requirements of Australian Privacy Principle 11.2.

9. Access and correction of personal information

1. Under the Commonwealth Privacy Act and the Health Records Act, an individual has the right to seek and obtain access to any personal information which the School holds about them and to advise the School of any perceived inaccuracy. Students will generally be able to access and update their personal information through their Parents, but older students may seek access and correction themselves.
2. There are some exceptions to these rights set out in the applicable legislation.
3. To make a request to access or to update any personal information the School holds about you or your child, please contact the School Office by telephone or in writing.
4. The School may require you to verify your identity and specify what information you require. The School may charge a fee 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 the likely cost in advance. If we cannot provide you with access to that information, we will provide you with written notice explaining the reasons for refusal.

10. Consent and rights of access to the personal information of students

1. The School respects every Parent's right to make decisions concerning their child's education.
2. Generally, the School will refer any requests for consent and notices in relation to the personal information of 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.
3. Parents may seek access to personal information held by the School about them or their child by contacting the School Principal or School Business Manager by telephone or in writing. However, there may 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.
4. The School may, at its discretion, on the request of a student grant that student access to information held by the School about them or allow a student to give or withhold consent to the use of their personal information, independently of their Parents. This would normally be done only when the maturity of the student and/or the student's personal circumstances warrant it.

11. Enquiries and complaints

1. If you would like further information about the way the School manages the personal information it holds or wish to make a complaint that you believe that the School has breached the Australian Privacy Principles, please contact the Executive Principal by writing or telephone at principal@maitlandcs.nsw.edu.au or 02 4933 7633.
2. The School will investigate any complaint and will notify you of the making of a decision in relation to your complaint as soon as it is practicable to do so.

12. Source of Obligation

• Health Records and Information Privacy Act 2002 (NSW) (Health Records Act)
• Privacy Act 1988 (CTH)