This document sets out the approach which Connected Colleges Pty Ltd trading as Social Media College (Social Media College) will take in relation to the treatment of Personal Information. It includes information on how Social Media College collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how Social Media College makes the personal information it holds available for access to and correction by the individual.
This policy is a public document and has been prepared in light of APP 1, Open and transparent management of Personal Information.
Social Media College will only collect Personal Information where the information is necessary for Social Media College to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.Social Media College collects Personal Information primarily to supply employees of member organisations and individuals who obtain Social Media College products and services directly from Social Media College with information and details of its products and services. Social Media College also collects and uses Personal Information for secondary purposes including:
Social Media College collects Personal Information in a number of different ways including:
Social Media College will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:
Where it is not practicable for Social Media College to notify individuals of all of the Collection Information before the collection of Personal Information, Social Media College will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Social Media College will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
Social Media College will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.
Social Media College uses Personal Information primarily for the purposes listed in 1.2 above.
If Social Media College relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
Social Media College will not use Sensitive Information for Direct Marketing.
Social Media College may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
Social Media College will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
Social Media College will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
Social Media College may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
Social Media College may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
Social Media College will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
In the rare event that Social Media College will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
Social Media College is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors Social Media College will only do so in accordance with the Privacy Act or any other relevant Australian legislation.
Social Media College may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Social Media College will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
Social Media College does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved.
Social Media College will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
Social Media College will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
Social Media College requires employees and contractors to perform their duties in a manner that is consistent with Social Media College’s legal responsibilities in relation to privacy.
Social Media College will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Social Media College who have a genuine “need to know” as well as “right to know”.
Social Media College will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
Social Media College will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
Social Media College will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Social Media College, as per the details on the back of this document.
Social Media College will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
Contact with Social Media College via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
Any formal privacy related complaints should be directed in writing to Social Media College at Level 21, 60 Margaret St Sydney NSW 200.
Social Media College will endeavour to manage any privacy related complaint efficiently and in a timely manner.
Social Media College will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Social Media College may however request visitors to provide Personal Information voluntarily to Social Media College (for example, as part of a competition or questionnaire).
Social Media College will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
Social Media College generally does not send information overseas.
If Personal Information must be sent by Social Media College overseas for sound business reasons, Social Media College will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the Australian Privacy Principles, preferably as part of the services contract.