Created: Sep 2015 Policy No. 2.0 Revision date: 20 Dec 2016
Personal information means an opinion about an identified individual or an individual who is reasonably identifiable.
Content of the policy
This policy has three sections that set out information about:
PRAXIS – this section sets out information about PRAXIS and its approach to privacy governance and accountability.
Our Personal Information Handling Practices – this section explains our general information handling practices across the company including how we collect, use, disclose and store your personal information. It addresses the requirements of the APPs and will tell you about the sort of records we keep and why.
Our Website – this section explains our personal information handling practices when you visit our website.
PRAXIS Australia Limited is a national, private, not for profit/charity organisation whose purpose is to enhance the understanding and practice of the ethical aspects of research involving human participants in Australia and internationally, and thereby enhance the welfare of research participants and the quality and effectiveness of research.
The Company PRAXIS is governed by a Board of Directors whose names are listed on our website.
Collection and use of personal information
PRAXIS collects personal information in a variety of ways. It is our usual practice to collect personal information directly from the individual or their authorised representative. Sometimes we collect personal information from a third party or a publicly available source, but only if the individual has consented to such collection or would reasonably expect us to collect their personal information in this way, or if it is necessary for a specific purpose such as the investigation of a privacy complaint.
Most of the information we collect comes via our website and our Moodle and Learner Management System Platforms, where people may enter information or submit forms such as enrolment or general enquiry forms.
The information we collect includes name, contact details and on occasion, details about employment or an association with an institution or organisation. We also collect and store invoices and bank details for payment processing. We also collect information about your interactions with our Moodle and Learner Management System such as time spent on individual pages, downloads and your responses to assessment activities.
In more detail, we collect the following information via various mechanisms;
- Lodging an enquiry: PRAXIS collects the name, email and phone number of the individual lodging the enquiry. This information is not disclosed to third parties (unless required by law) and is used for the purpose of following up enquiries and for future marketing activities.
- Participating in a course or other educational activity: PRAXIS collects the name, email and phone number, institutional details for billing purposes and banking details of students and institutions. This information is not disclosed to third parties (unless required by law) and is used for the purpose of enrolling students, processing fees and for future marketing activities. For students of PRAXIS, in order to assist with their educational experience we will also be recording student interactions with our online learning platform which may include detailed information such as time spent on individual pages of the learning tools, resources accessed and assessment activity responses.
- Creating and maintaining mailing lists: Where people consent, including by subscribing to offers on our website, or becoming a registered user of PRAXIS Australia Limited services, or by a listing on a publically accessible database, we collect email addresses for the purpose of future marketing activities.
Responding to complaints: In order to handle any complaints received about PRAXIS’ handling of personal information about them we may need to collect personal information to investigate and resolve the matter. The information we collect includes:
- name and contact details of the complainant and, if we pursue the matter, the respondent details of the problem or incident
- evidence supporting the complaint
- results of enquires or investigations
Employing staff: We collect personal information about applicants and employees to allow us to recruit appropriate staff and to manage the employment relationship. The information we collect includes:
- name and contact details
- curriculum vitae including work history and qualifications
- tax file numbers and bank account details and nominated superannuation provider
- referee reports and performance information and
- medical information where relevant
- PRAXIS Directors: We collect information about our company directors to pay fees, provide administrative support and to meet obligations under the Corporations Act 2001. The information collected includes name, date of birth and contact information, tax file numbers and bank details.
- Administer the company: We collect information to administer the company. These records will contain limited personal information relating to our contractors, suppliers and other administrative activities.
There may be instances where PRAXIS collects personal information which are not covered by these notices. In those instances, PRAXIS will separately inform the individual at that time of collection or shortly thereafter, in relation to the collection and use of your personal information.
Disclosure of personal information
We only disclose personal information for the purposes for which it was given to us, or for purposes which are related to one of our functions or activities, and we do not give it to other government agencies, organisations or anyone else unless one of the following applies:
- the individual has consented,
- the individual would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies,
- it is required or authorised by law,
- it will prevent or lessen a serious and imminent threat to somebody’s life or health,
- it is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.
And also in the following circumstances:
Creating and maintaining mailing lists: We will collect email addresses so that we can:
- send out email marketing materials, newsletters and other information about PRAXIS’s operation
- approach users to participate in research relevant to PRAXIS’s activities, including market research, for example, via focus groups or surveys
- tell users about additional services that PRAXIS provides related to its activities such as training. See website details above
Campaign Monitor allows us to gather information about how our newsletter is received. For example, we can generate reports about whether the newsletter has been opened, or was deleted without reading, and which pages were viewed. If you subscribe to our newsletter, you may opt out of further contact from us by clicking the unsubscribe option in all newsletters or promotional emails sent to you.
- HREC Essentials nationally accredited training course. This course requires us to disclose information to other organisations. This includes RMIT University who then provide the Australian Skills Quality Authority (ASQA) a variety of information about students including your name, date of birth, email and phone details and (if necessary) your passport number or other unique identifier, through various application forms. This is in accordance with section 216 of the NVR Act. http://www.asqa.gov.au/verve/_resources/ASQA_Privacy_Policy.pdf.
- Complaint files - We do not disclose any information about complainants without their knowledge and consent unless authorised or required by law. With the knowledge and consent of the complainant, we may need to disclose some information about complaints to researchers and others involved in the process, the NHMRC, AHEC, the Privacy Commissioner or other regulators or law enforcement bodies.
- PRAXIS Director’s files - We disclose information about our directors to the Australian Securities and Investment Commission as required by the Corporations Act 2001 (Cth).
- Staff files - We may need to disclose information about our staff to health service providers, other employers in the course of referee checks, the Australian Taxation Office, work place regulators including for occupational health and safety, and workers compensation and Superannuation and insurance bodies. Our external auditors may also review files.
- Administration files - We may disclose information from these files to our auditors, insurers, and accountant and to regulatory bodies.
- Moodle Site: We disclose to our Moodle site information about students and their interactions with this platform for all of our courses.
PRAXIS may also seek your consent to your personal information being used or disclosed for other specific purposes.
We take steps to ensure that the personal information we collect is accurate, up to date and complete. These steps include maintaining and updating personal information when we are advised by the people concerned that their personal information has changed, and at other times as necessary.
Our records are stored electronically on secure servers held behind firewalls by PRAXIS. Our Moodle site is hosted on a cloud based server in Australia. We also hold hard copy records, for example for our staff files, historical activities and some sensitive commercial-in-confidence material.
We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse. Our policies are developed following careful assessment of risks and are regularly reviewed.
When no longer required, personal information is destroyed in a secure manner by disposal in a confidential waste management system or is deleted.
This sections sets out the handling of personal information collected when users visit our website. The PRAXIS server makes a record of the visit and logs the following information:
- The users IP address;
- the date and time of the visit to the Website;
- the webpages accessed and the documents downloaded;
- the type of browser used; and
- the username entered if accessing a restricted webpage on our Website.
Our website also uses database software and Google Analytics to gather information to evaluate the effectiveness of our website and the level of interest in particular pages. Information and data collected through Google Analytics is stored by Google on servers in the United States of America, Belgium and Finland. We do not otherwise disclose personal information overseas.
Our website only uses session cookies to track users to retain session information (so that once you log in you stay logged in until you either log out or close your browser).
We recommend that you re-visit our website regularly to learn of new privacy practices or changes to our policy which we will highlight on our website home page.
Access and correction
If a person asks for access to the personal information we hold about them, or asks that we change that personal information, we will allow access or make the changes unless we consider that there is a sound reason which is authorised under the Privacy Act or other relevant law to withhold the information or to not make the requested change.
If we do not agree to provide access to personal information the individual may ask us to review the decision and if not satisfied may make a complaint to the Privacy Commissioner.
If we do not agree to make requested changes to personal information we will tell the individual why in writing. The individual may make a statement about the requested changes and we will attach this to the record.
Individuals can obtain further information about how to ask for access or changes to the information we hold about them by contacting us (see details below).
Your right to make a privacy complaint
If you think that we have mishandled your personal information we would encourage you to take to us in the first instance. If you are still not satisfied you make a complaint to the Privacy Commissioner.
How to contact us
If you would like further information on how your personal information is handled by PRAXIS or information on lodging a complaint or to request access or correction of your information, please contact the CEO at:
- email us at: firstname.lastname@example.org
- write to us at: PRAXIS Australia Limited 129 Glen Osmond Road EASTWOOD SOUTH AUSTRALIA 5063
- telephone us on: 08 8122 4576