Privacy Policy

Policy Overview

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means each member of the of the Imagine Education Group of Companies from time to time, including Imagine Education Group Pty Ltd (ABN 46 649 035 174) and each of its associated entities and related bodies corporate (as those terms are defined in the Corporations Act 2001 (Cth)) (Imagine)

Imagine is committed to respecting your privacy. This privacy policy (Privacy Policy) sets out how we collect, use, store, disclose, retain and protect your personal information. It applies to your use of our website and to any other websites, applications (Apps) and/or platforms operated by us (collectively, the Services) where this Privacy Policy is referenced, regardless of how you access or use them, including through devices.

In handling your personal information, we are regulated by and are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (Privacy Law).

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us for as long as we consider necessary to fulfil the purpose for which such personal information was collected, or as required by relevant laws. In this context, “collect” or “collection” means gather, acquire or obtain by any means, information in circumstances where the individual is identified or identifiable.

This Privacy Policy applies to your use of the Services. This Privacy Policy also incorporates the Imagine CCTV Surveillance Policy accessible here [https://www.imagineelc.com.au/wp-content/uploads/2021/05/7.13-CCTV-Surveillance-Policy.pdf]

If you do not accept this Privacy Policy and any documents incorporated by reference into this Privacy Policy, you may not be able to use or accept the Services. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Each centre we operate respects the privacy of our staff, children and families. It is important for us to ensure that personal information of our staff, children and families is collected, handled, stored, used and protected properly. Without limiting this, our centres develop guidelines with educators in regard to handling personal information connected with their work as early childhood educators.

This policy demonstrates how we collect, use, store and disclose the personal information during your interaction with us.

What is “personal information”?

The Privacy Act currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:

(i) whether the information or opinion is true or not; and

(ii) whether the information or opinion is recorded in a material form or not.

If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.

What information do we collect?

The personal information which we collect and hold about you may include your: name, gender, address, phone numbers, facsimile number, email address, date of birth, bank account details, credit card number, tax file number, Centrelink Customer Reference Number, custody arrangements, camera images or videos captured by the CCTV surveillance cameras installed inside and/or outside of our premises and/or other information relevant to providing you with services

Additional specific information we collect and hold about children may include their: name, former name, gender, address, Centrelink Customer Reference Number, immunisation status, date and place of birth, birth certificate, Medicare number, custody arrangements or parenting orders, dietary requirements, languages spoken, doctor’s details, medical conditions , additional needs, photographs and videos of children, samples of children’s work and general information about your child and your family that assists us in providing individualised early learning and care to children.

How we collect your personal information

Personal information will generally be collected from you directly through the use of our standard forms, via email or written communication with you, or through a telephone conversation with you.

Photos and videos of children and children’s work samples are collected at our childcare centres. Name, address and phone numbers of children’s additional emergency contact people are collected from children’s parents or guardians.

Photos and videos can be captured by our surveillance CCTV cameras installed in and/or outside of our premises.

We may collect personal information from you when you input such information into our website or social media.

We also collect cookies from your computer which enable us to tell when you use the website and also to help customise your website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.

Purpose of collection and use of Personal Information

The purposes for which your personal information is collected will usually be obvious at the time it is collected. We collect personal information of parents and guardians, children, employees and stakeholders for the primary purposes of providing early childhood education and care services and advocating for the well-being, protection and development of children. We will only use your personal information for purposes associated with:

  • providing early childhood education and care services;
  • advocating for the well-being, protection and development of children;
  • documenting children’s learning;
  • managing children’s current or prospective enrolment;
  • providing you with information about our organisation, services and activities via letters, email, SMS and other centre or organisation communication channels;
  • requesting information from you about our organisation and services via surveys;
  • monitoring access, safety and security of children, visitors and staff inside and outside our premises through CCTV cameras, by authorised personnel only. Please refer to our CCTV Surveillance Policy here [https://www.imagineelc.com.au/wp-content/uploads/2021/05/7.13-CCTV-Surveillance-Policy.pdf] for details.

Direct Marketing

We may use your personal information that you have directly provided to us, to communicate with you in order to advertise our promotions and services and to inform you of our services. We may conduct these marketing activities by mail, email, telephone, SMS, social media, or any other electronic means in accordance with the Spam Act 2003 and the Privacy Act. We will always provide a way for you to opt out of receiving direct marketing messages from us (for example an unsubscribe link), and we will cease to send you direct marketing communications if you ask us to.

Sensitive Information

In some circumstances we may seek to collect personal information that is sensitive. This may include information such as your child’s racial or ethnic origin or any cultural or religious requirements. We are also required by the Education and Care National Regulations to collect and hold details of your child’s medical conditions, immunisation history and additional needs. We collect this information as it is reasonably necessary for ensuring the well-being, protection and development of children in our care.

We will only collect your sensitive information with your consent and will ensure that it is stored securely. If you do not wish for your sensitive information to be collected by us, you should discuss this with one of our employees.

Our employees will act strictly in accordance with this policy and will be happy to discuss the reasons for seeking to collect your sensitive information. They will also discuss with you any consequences of not providing your sensitive information which may include an effect on the services our centre can provide to you.

Disclosure

We will only disclose your personal information for the purpose it was collected or a reasonably expected or related secondary purpose.

We may disclose personal information about you or your child to:

  • third party service providers, who assist us in operating our business (including credit reporting bodies, collection agencies, legal advisors and technology service providers). We will take reasonable steps to ensure these service providers do not breach the Australian Privacy Principles. These providers may be based overseas or use overseas infrastructure to perform services for us, including in the United States of America;
  • Centrelink and other Government Agencies, including to allow us to deliver the Services to you;
  • child protection agencies and/or family support agencies when we reasonably believe that a child is at risk of significant harm; and
  • a purchaser of the assets and operations of our business or a part of it, provided those assets and operations are purchased as a going concern;

We will not otherwise disclose personal information to a third party for any other purpose without your consent unless it is authorised or required by law.

Access and Correction

You may request access to your personal information. Ordinarily we will require you to make a request for access in writing directed to our Privacy Officer. Our employees other than the Privacy Officer are not generally able to provide you with access.

If at any time you believe that our record of your personal information is incorrect, please let us know. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.

In some circumstances which are prescribed by the Privacy Act, such as where to do so might put a person at risk of harm or have an unreasonable impact on the privacy of others, we may decline access to personal information. If your request for access is denied, we will tell you why.

Internet

Website and social media sites can provide information to potential clients on what an organisation offers. A website maintained by the education and care service can support families to make informed decisions about education and care and find out if a particular education and care service will suit their needs. Families are also able to gain contact information or request further information via email. Social media may also be utilised to support enrolled families to communicate and share information.

If you access our website, we may collect additional personal information about you in the form of your IP address or domain name. Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and any linked websites are not subject to our privacy policies and procedures.

We will ensure that no confidential information can be gained from the centre’s website or social media site. Individuals and services are not obliged to give personal information through the website or social media site.

We will ensure that information gained via email can only be used by administration staff or management to contact a person, offer or send information about the service and to request feedback on the website, social media site or service provided.

We will ensure that information gained about users from the website and social media site will only be used for statistical research for the organisation to ascertain future development of the website and social media site. The following information will not be available to any other organisations:

  • IP address, the date and time of the visit;
  • Pages accessed, and documents downloaded on the site;
  • Search terms used;
  • Previous site visited;
  • Network providers name;
  • Any cookies that the browser has presented to the server;
  • The browser, operating system and various plugins that were used in visiting the site.

We will encourage families and educators to give feedback on the website and social media site and how it can be improved to meet the needs of the community.

We will not disclose or publish any information related to educators, children or families without written consent from that individual or their family.

We will develop guidelines for educators regarding their participation with families currently connected with the centre on social media sites such as Facebook, Instagram and Twitter.

Company representatives are advised that it is inappropriate, and it is unacceptable for them to make insulting, intimidating or otherwise offensive remarks about current, or past employees, or about any aspect of the company’s operations (including in relation to parents, families and children or any aspect of the company’s operations) on social networking sites, including but not limited to blogs, chat rooms, Twitter, Instagram, Facebook and similar, or in any other forum or medium, electronic or otherwise, in any form.

Company representatives found breaching this policy requirement will be subject to disciplinary action and depending on circumstances may be subject to termination of employment and/or legal defamation or other proceedings.

The company does not condone, in any way at all, company representatives using ‘public forums’ of the type listed above to make inappropriate or offensive comments.

Company representatives are encouraged not to use their personal accounts to comment on company social media pages. The admins of the social media pages are to represent the company and answer questions and make comments to encourage interaction.

Information Storage and Security

Personal information collected by us will be stored securely in paper form or electronically at an Ashton’s Place Immersive Learners centre and/or at Imagine Education Group Support Office.

We may store, process or back-up your personal information on computer servers that are located overseas, including through third party service providers who assist us in operating our business. Only authorised employees from us and third party service providers will have access to your information and this access will be structured in such a way as to ensure the use and disclosure as stated above. We will take reasonable steps to protect any personal information that we hold from unauthorised access, modification, misuse, loss and disclosure.

Court documents and subpoenas

When a subpoena is being prepared to request documentation from one of our centres, you must address the subpoena to the correct legal entity.

We strongly encourage you to ask us which legal entity operates the centre from which you to obtain documents. Please direct questions to this email address: enrolments@imagineelc.com.au

If you issue a subpoena to the incorrect legal entity or an entity that does not exist, you will not receive documents from a different entity [which may be the entity who holds the documents you want].

Where a subpoena is for a named staff member, we will seek authority from the staff member to accept the subpoena on their behalf. A solicitor will confirm if and when service has been accepted.

We will not accept service for personal legal matters unconnected to the work of our centres.

How to effect service

Any subpoenas or requests for giving evidence at court are to be sent to enrolments@imagineelc.com.au for the attention of the Manager Administration.

  • • We encourage service by e-mail.
  • • Please do not send us court documents by regular post.
  • • To avoid disruption at our centres, please do not try to serve them at a centre personally.

Staff at our centres are not authorised to accept service of any court document and the registered office of the legal entities that own the centres, is not at the centre itself.

Nothing in this statement is a representation that we will automatically comply with any court document, including a subpoena.

We reserve the right to object to any document, should that be an appropriate course of action to take in the circumstances of a particular matter.

Amendments to this Privacy Policy

We may change this Privacy Policy at any time without prior notice. When we do so, we will notify you of the changes by posting an updated version of the policy on our website.

Privacy Act

This policy is provided for your information and is not intended to limit or exclude your rights under the Privacy Act.

Complaints and Feedback

If you wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you. If you are not happy with our response, you may complain directly to the Australian Information Commissioner.

If you have any queries or concerns about our privacy policy or the way we handle your personal information, please contact our Privacy Officer by completing a web form at: https://www.imagineelc.com.au/contact/ or by calling 1300 001 154