Speech Pathology for Schools Privacy Policy

 

Speech Pathology for Schools Pty Ltd (“SPS”, “us”, “our” and “we”) values your privacy and is committed to protecting information that we collect.

 

This Privacy Policy applies to all your interactions with us, including your use of our website.

 

All our staff including contractors and service providers of SPS, must comply with this policy and their obligations at law.

 

SPS management of ‘personal information’ and ‘health information’ is governed by the Privacy Act 1988 (Cth), the Privacy and Data Protection Act 2014 (Vic) and Health Records Act 2001 (Vic).

 

This policy explains how SPS collects and manages Personal, Sensitive and Health information.  SPS will comply with all its privacy obligations at law.

 

Importantly, SPS will comply with all privacy policies provided to us by each school we operate in.

 

Definitions

 

Personal information is recorded information or an opinion, whether true or not, about a person whose identity is apparent, or can reasonably be ascertained, from the information. The information or an opinion can be recorded in any form. A person's name, address, phone number and date of birth (age) are all examples of personal information.

 

Sensitive information is a type of personal information with stronger legal protections due to the risk of discrimination. It includes information or an opinion about an identifiable person’s racial or ethnic origin, political opinions or affiliations, religious beliefs or philosophical beliefs, sexual orientation or practices, criminal record, health or genetic information and any other biometric information.

 

Personal and Sensitive information is regulated in Victoria under the Privacy and Data Protection Act 2014 (Vic).

 

Health information is information or an opinion about an identifiable person’s physical, mental or psychological health, including an illness, disability or injury, or expressed wishes about the future or current provision of health services to an individual. Health information is a type of personal information which, because of its sensitivity, also has different and stronger legal protections.

 

Health information is regulated in Victoria under the Health Records Act 2001 (Vic).

 

What information do we collect

 

SPS collects the following types of information.

 

• Personal information including:

• name and date of birth;

• residential, postal and business addresses, telephone/mobile/fax numbers and email addresses;

• any information that you provided to us, including during your account creation process or added to your user profile;

• preferences and password for using this site and your computer and connection information; and

• any information that you otherwise share with us, including through our partner schools, students and their families, for example, speech pathology goal monitor progress data for students.

 

• Information about job applicants and staff, provided by job applicants, staff members, and others – for example, qualifications, working with children checks, speech pathology registration and payroll details.

• Sensitive and Health information for the purposes of our business.

 

How do we collect this information

 

SPS collects information in several ways, including:

 

• in person and over the phone: from you, teachers and/or schools, students and their families, staff, job applicants and others

• from electronic and paper documentation: such as job applications, emails, invoices, letters, and forms (such as speech pathology parental consent forms)

• through SPS websites and SPS social media

• through online tools: such as apps and other software used by SPS through polls, surveys and questionnaires.

 

IP addresses

 

Our website may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. SPS collects and manages IP addresses as part of the service of providing internet session management and for security purposes. SPS may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.

 

Cookies

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Our website uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store Personal information about you. SPS extends the same privacy protection to your Personal information, whether gathered via cookies or from other sources.

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You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

 

Why we use cookies

 

Our website uses cookies in order to:

• remember your preferences;

• manage the signup process when you create an account with us;

• recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;

• show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and

• remember details of data that you choose to submit to us (eg, through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).

 

Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.

 

Third party cookies

 

In some cases, third parties may place cookies through this site. For example:

• Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this site and the pages that they visit;

• Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and

• third party social media applications (eg, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this site.

 

 

Consent processes

 

Consent is when someone voluntarily agrees for their information to be collected, used and/or shared within or outside SPS.

 

Consent, when required, is sought in different ways and can be verbal, online or in writing, depending on the circumstances. There are many consent processes that may be applied during the delivery of speech pathology services (for example, parental consent for students to participate in speech pathology group sessions, or, remote service delivery consent for recording of on-line video sessions).

 

SPS follows the school’s processes for obtaining consent. This is usually specific consent associated with delivery of speech pathology services to the school. SPS relies on the school to obtain and record consent.

 

SPS may collect Health information without consent 1) if the purpose of the collection is research relevant to public health and safety or the management, funding or monitoring of a health service; 2) the purpose cannot be served if the information is de-identified; and 3) it is impracticable for us to seek individual’s consent to the collection.

 

 

Why do we collect this information?

 

Primary purposes of collecting information about schools and students

SPS collects information about students and their families when necessary to:

• verify your identity;

• respond to any queries or feedback that you may have;

• conduct research and development in respect of our services;

• deliver speech pathology services to students and school communities;

• support students’ social and emotional wellbeing, and health;

• fulfil regulatory requirements, including to:

• make reasonable adjustments for students with disabilities (for example, data in line with NCCD – Nationally Consistent Collection of Data – for students with communication disabilities);

• ensure, as far as is reasonably practicable, the health and safety of people in school workplaces (occupational health and safety law)

• enable SPS to:

• communicate with school leaders, teachers and parents about students’ schooling speech pathology matters to support the efforts and achievements of students;

• maintain the good order and management of speech pathology services delivered to schools

• enable SPS to:

• ensure the effective management, resourcing and administration of speech pathology services;

• fulfil statutory functions and duties plan, fund, monitor, regulate and evaluate the SPS policies, services and functions comply with reporting requirements

• maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;

• obtain or provide services.

 

 

Primary purposes of collecting information about others

SPS collects information about employees, volunteers, contractors, suppliers and job applicants:

 

• verify your identity;

• make changes to your account;

• respond to any queries or feedback that you may have;

• conduct appropriate checks for credit-worthiness and for fraud;

• prevent and detect any misuse of, or fraudulent activities involving this site;

• to assess suitability for the role or tasks;

• to administer employment or volunteer placement;

• for insurance purposes, including public liability and WorkCover;

• to fulfil various legal obligations, including employment and contractual obligations, occupational health and safety law and to investigate incidents;

• to respond to legal claims against SPS;

• and for any other purpose reasonably considered necessary or desirable by SPS in relation to the operation of our business.

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From time to time, we may communicate with you by providing our customers with news, information and offers relating to our own services or those of selected partners. Your Personal information may also be collected so that SPS can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease acquiring products and services from us. If you would prefer not to receive promotional or other material from us, please let us know, and we will respect your request. You can unsubscribe from such communications at any time if you choose.

 

When do we use or disclose information?

 

For the purposes set out above, SPS may disclose your Personal information to organisations outside SPS consistent with privacy law and other associated legislation.

 

Your Personal information may be disclosed to these organisations only in relation to this site, and SPS takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal information. These organisations may carry out or provide:

• customer enquiries;

• mailing systems;

• billing and debt-recovery functions;

• information technology services;

• marketing, telemarketing and sales services;

• market research; and

• website usage analysis.

 

In addition, we may disclose your Personal information to:

• your authorised representatives or legal advisers (when requested by you to do so);

• credit-reporting and fraud-checking agencies;

• credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);

• our professional advisers, including our accountants, auditors and lawyers;

• government and regulatory authorities and other organisations, as required or authorised by law;

• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and

• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

 

 

SPS may use or disclose information with notice and/or consent – for example, parent consent provided for the use and disclosure of student details for participating in speech pathology services. The information will not be disclosed beyond the purposes for which the consent is provided unless such disclosure is required or authorised by law.

 

SPS may use or disclose de-identified information for research or school statistics purposes, or to inform SPS policy and strategy.

 

Third party websites

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You may click-through to third party websites from our website or communications we send you. In which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only and we assume no responsibility for the content of any third party websites.

 

Re-marketing

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We may use the Google AdWords, Facebook and other re-marketing services to advertise on third party websites to previous visitors to our website based upon their activity on our website. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network, inside Facebook or otherwise. Google, Facebook and the relevant provider may use cookies and/or pixel tags to achieve this. Any data so collected by Google, Facebook and/or others will be used in accordance with their own respective privacy policies. None of your personal Google, Facebook or other sites information is reported to us.

You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising. You should check the other sites that you use for similar opt out settings.

 

 

Third-party disclosure to education providers

 

A third party other than the student’s parents, legal guardians, and/or carer such as school leaders and teachers will be provided speech pathology service reports that may include Health information of students subject to the consent of individual student’s parent(s) and/or legal guardian(s). This will be limited to where it is necessary to carry out school functions.

 

Generally, Health information is only available after de-identification, provided that granting access would be in the student’s best interests or the disclosure is required or authorised by law.

 

Responding to complaints

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SPS may use and disclose your information if it is considered appropriate to respond to complaints from you, schools and/or others whether the complaints are made internally or externally through other organisations.

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Accessing your information

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In most cases, you may have access to Personal information that we hold about you provided that access to information or records doesn’t increase the risk to the safety of a child or children. We will handle requests for access to your Personal information in accordance with the Australian Privacy Principles. All requests for access to your Personal information must be directed to the Privacy Officer by email using the email address provided below or by writing to us at our postal address. We will deal with all requests for access to Personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

In some cases, we may refuse to give you access to Personal information that we hold about you. This may include circumstances where giving you access would:

• be unlawful (eg, where a record that contains Personal information about you is subject to a claim for legal professional privilege by anyone;

• have an unreasonable impact on another person’s privacy; or

• prejudice an investigation of unlawful activity.

 

We may also refuse access where the Personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.

 

If we refuse to give you access, we will provide you with reasons for our refusal.

 

Access to student information

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SPS only provide speech pathology service reports to school leaders and teachers who have a right to that information.

In some circumstances, an authorised representative may not be entitled to information about the student. These circumstances include when granting access would not be in the student’s best interests or would breach our duty of care to the student, would be contrary to a mature minor student’s wishes or would unreasonably impact on the privacy of another person.

 

Storing and securing information

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We are committed to maintaining the confidentiality of the information that you provide us, and we will take all reasonable precautions to protect your Personal information from unauthorised use or alteration. In our business, Personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. We store all paper and electronic records securely, consistent with the SPS records management policy and information security standards. All SPS records are formally disposed of, or archived, as required by the relevant record retention and disposal regulations and policies.

 

Updating your information

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It is important that the information we hold about you is accurate, complete and up to date. We will amend any Personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your Personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

 

Please contact SPS when information you have has changed.

 

 

Changes to this Privacy Policy

 

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this site.

 

 

Privacy

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If you have a query or complaint about privacy, please contact:

 

Post:    Privacy Manager

   Speech Pathology for Schools

   33 Hutcheson St Moonee Ponds 3039

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Phone: 0409 332 842

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Email:  privacy@speech.edu.au

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