iPT AUSTRALIA PRIVACY STATEMENT
Smart eHealth Pty Limited | ABN 78 148 159 273
1. Your rights in relation to privacy
Smart eHealth Pty Limited ABN 78 148 159 273 (iPT Australia) understands the importance of protecting the privacy of an individual's personal information. This statement sets out how iPT Australia aims to protect the privacy of your personal information, your rights in relation to your personal information managed by iPT Australia and the way iPT Australia collects, holds, uses and discloses your personal information.
In handling your personal information, iPT Australia will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. To the extent iPT Australia handles your credit information, iPT Australia will also comply with the Credit Reporting Code. This policy statement may be updated from time to time.
2. What kinds of personal information does iPT Australia collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, iPT Australia may collect your personal information.
Generally, the kinds of personal information iPT Australia collects are:
- contact and identification information such as your name, address, telephone/mobile numbers, email address, date of birth, place of birth (where relevant to the provision of iPT Australia's products and/or service and only with your consent);
- photographic identification material including photographs and videos of you; your educational history and qualifications, including both prior to and during your participation, if any, in iPT Australia's services;
- if you are accepted as a student of iPT Australia, a student identification number (created by iPT Australia for the purposes of administering your education with iPT Australia);
- course results you obtain in the course of participating in iPT Australia's training services;
- your banking information for the purpose of facilitating payment to iPT Australia for services provided;
- credit information about your credit history and worthiness, where necessary to assess your ability to make necessary payments to iPT Australia for services provided, including from:
- a credit reporting body such as VEDA Advantage Information Services Solutions Limited (Veda) (the details of which are set out in paragraph 5); and/or
- information iPT Australia derives from such information based on its own analysis including internally generated scores, ratings and other assessments used to evaluate your credit worthiness; iPT Australia
- health information:
- where you consent to the collection of such information and if relevant to iPT Australia's provision of services to you and iPT Australia's occupational health and safety obligations or your ability to complete an educational/training course with iPT Australia;
- where you lodge an accident or injury report form; or
- where you are applying for a position with iPT Australia and it is relevant to the recruitment process through which you must progress following your application to iPT Australia;
In some circumstances iPT Australia may also hold other personal information provided by you.
3. How does iPT Australia collect personal information?
Generally, iPT Australia collects your personal information directly from you, through:
- the completion of a manual or online form, such as an application or enrolment form or other form on iPT Australia's website;
- an interaction or exchange in person, such as through an interview, or by way of telephone, facsimile, email, post or through the use of the iPT Australia website (whether during the enrolment/application process or otherwise in the course of participating in iPT Australia's training services); and/or
- the completion of a survey for the purpose of iPT Australia collating feedback and improving its products and/or services (although in most cases, you will not be identified in this process).
There may be occasions when iPT Australia collects your personal information from other sources such as from:
- your tutors, or other iPT Australia staff members with which you engage;
- your employer, if such information is related to you completing an educational/training course with iPT Australia;
- Veda or other credit reporting body;
- an information services provider;
- a publicly maintained record or other publicly available sources of information including social media and similar websites;
- iPT Australia's own records about you, from which iPT Australia may internally generate its own scores, assessments or deductions, particularly in relation to your credit worthiness;
- if for recruitment purposes, an external recruitment services provider or background screening services provider.
Generally, iPT Australia will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does iPT Australia need your personal information?
iPT Australia collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
- providing training and educational services for the purpose of you becoming qualified as a personal trainer;
- assessing and processing applications to enrol in a personal training course;
- administering the educational services you receive including any relevant support or ancillary services;
- communicating and discussing with you, your results, progress and additional requirements and needs;
- placing you with an employer or organisation for the purpose of completing a practical placement;
- issuing you with a certificate, or replacement certificate, confirming your completion of a qualification with iPT Australia;
- accounting, billing and other internal administrative purposes;
- identifying and informing you, whether you are an existing student or not, of products and services that may be of interest to you from iPT Australia or selected third parties;
- assessing your application for employment with iPT Australia or otherwise for the purposes of iPT Australia engaging you as a contractor or consultant; and
- any other legal requirements including but not limited to workplace health and safety obligations and regulatory obligations imposed on iPT Australia as a Registered Training Organisation.
iPT Australia may also use your personal information, including your image, quotes or other information for inclusion with our marketing materials, where you have consented to such use.
iPT Australia may also use your personal information for purposes related to the above purposes and for which you would reasonably expect iPT Australia to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.
Where personal information is used or disclosed, iPT Australia takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to iPT Australia. However, without certain information from you, iPT Australia may not be able to provide its products and/or services to you.
5. To whom does iPT Australia disclose your personal information?
iPT Australia discloses your personal information for the purpose for which iPT Australia collects it. That is, generally, iPT Australia will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:
third parties engaged to perform administrative or other services, including stationery printers and mailing houses;
- organisations with which you are placed, or hoping to be placed, for the purpose of completing a practical placement;
- people or entities considering acquiring an interest in iPT Australia's enterprise or assets or otherwise working with iPT Australia to facilitate the provision of its products and/or services;
- iPT Australia's professional advisors, contractors, consultants and related bodies corporate;
- debt collection agencies;
- regulatory bodies including ASQA and Service Skills Australia
iPT Australia may also disclose your personal information to the credit reporting body, Veda (contactable on the details set out below), for the purpose of undertaking a credit check to assess your suitability to pay iPT Australia via direct debit or credit card.
Disclosures to third parties are on a confidential basis or otherwise in accordance with law. iPT Australia may also disclose your personal information with your consent or if disclosure is required or authorised by law.
Veda can be contacted on the below details:
Veda's policies on its management of personal information and credit related personal information can be accessed through its website at: http://www.veda.com.au/.
6. Overseas disclosure
iPT Australia may disclose personal information, including credit related personal information, to iPT Australia's employees and/or related bodies corporate in New Zealand in order to provide its products and/or services and for administrative, data storage or other business management purposes. Such disclosure is always on a confidential basis.
New Zealand has a different, but comparable, privacy law framework. If you have any queries or objections to such disclosures, please contact iPT Australia's Privacy Compliance Officer on the details set out in paragraph 10.
iPT Australia uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our website. This enables us to assist you by providing tailored items of interest when you browse sites or search for interest areas within Google related to iPT Australia’s products and services.
Third party vendors including Google show ads that are likely to be more relevant to you based on websites you have visited.
Should you wish to opt out of interest-based ads you may use Google’s Ads Settings function to manage your preferences or any opt-out mechanism provided to you.
iPT Australia may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting iPT Australia via the contact details set out in paragraph 10 or through any opt-out mechanism contained in a marketing communication to you.
8. Security of your personal information
iPT Australia takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. iPT Australia holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff or by you by using your personalised login and password. Credit eligibility information, such as information iPT receives from Veda for the purpose of assessing credit worthiness, is also stored securely. Staff are bound by security policies and confidentiality agreements, which are regularly revised and re-issued.
iPT Australia will destroy or de-identify personal information in circumstances where it is no longer required, unless iPT Australia is otherwise required or authorised by law to retain the information.
If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you may request Veda not to use or disclose credit related personal information it holds about you by contacting Veda on the details set out in paragraph 5.
9. Can you access and correct the personal information that iPT Australia holds about you?
iPT Australia takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by iPT Australia. If at any time you would like to access or correct the personal information that iPT Australia holds about you, or you would like more information on iPT Australia's approach to privacy, please contact iPT Australia via the contact details set out in paragraph 10 below. Alternatively, you can access your profile and records by logging on to the iPT Australia database with your login and password, which will be established upon enrolment. iPT Australia will grant access to your personal information to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
Where necessary to resolve a request for correction of your credit related personal information, iPT Australia may also consult with other relevant entities, including but not limited to Veda. iPT Australia's use or disclosure of your credit related personal information to other entities for correction purposes is permitted by the Privacy Act.
To obtain access to your personal information:=
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- iPT Australia requests that you be reasonably specific about the information you require; and
- iPT Australia may charge you a reasonable administration fee, which reflects the cost to iPT Australia, for providing access in accordance with your request.
Alternatively, if you would like to access personal information held about you by Veda, please contact Veda on the contact details set out in paragraph 5.
iPT Australia will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If iPT Australia refuses your request to access or correct your personal information, iPT Australia will provide you with written reasons for the refusal and details of complaint mechanisms. iPT Australia will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of iPT Australia.
If you are dissatisfied with iPT Australia's refusal to grant access to, or correct, your credit related personal information, you may make a complaint to the Office of the Australian Information Commissioner.
10. How to contact us
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact iPT Australia's Privacy Compliance Officer at: firstname.lastname@example.org
11. Privacy complaints
Please direct all privacy complaints to iPT Australia's Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and iPT Australia.
Specifically, if your complaint relates to credit related personal information and/or iPT Australia's failure to comply with its obligations regarding credit related personal information under the Privacy Act and/or the Credit Reporting Code:
- iPT Australia will acknowledge your complaint within 7 days of receiving it and endeavour to resolve it within 30 days, unless iPT Australia informs you otherwise and seeks your agreement in writing;
- iPT Australia may consult with relevant third parties, such as Veda or other credit provider, in order to sufficiently and expeditiously resolve the complaint; and
- if your complaint relates to iPT Australia's refusal to provide access to, or correct, your credit related personal information, you may complain directly to the Office of the Australian Information Commissioner.
iPT Australia's Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which iPT will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.