Complete Property Training Pty Ltd National Provider No 31828

Privacy Policy

Purpose
Authorisation
Collection
Notification
Use and disclosure of personal information
Data quality
Data security
Access and correction
Complaints
Privacy Contact Officer

1. Purpose

The purpose of this privacy policy is to:

clearly communicate the personal information handling practices Complete Property Training Pty Ltd
give staff and other individuals a better understanding of the sort of personal information that Complete Property Training Pty Ltd holds
enhance the transparency of Complete Property Training Pty Ltd ‘s operations

2. Authorisation

The Privacy Act 1988 (Privacy Act) is an Australian law that regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. The Privacy Amendment (Enhancing Privacy Protection) Act 2012 introduced many significant changes to the Privacy Act, including 13 Australian Privacy Principles (APPs) that apply to the handling of personal information. As an Australian Government agency, Complete Property Training Pty Ltd is obliged to comply with the APPs.

2.1 Personal information-definition

Personal information is defined under the Privacy Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable:

whether the information or opinion is true or not
whether the information or opinion is recorded in a material form or not

Some examples of personal information include names, addresses, phone numbers and email addresses. The definition of personal information only relates to ‘natural’ persons. It does not extend to other ‘legal’ persons, such as companies.

2.2 Sensitive information-definition

Under the Privacy Act, sensitive information is defined as:

Information or an opinion about an individual’s:
1. Racial or ethnic origin
2. Political opinions
3. Membership of a political association
4. Religious beliefs or affiliations
5. Philosophical beliefs
6. Membership of a professional or trade association
7. Membership of a trade union
8. Sexual orientation or practices
9. Criminal record

that is also personal information; or

Health information about an individual
Genetic information about an individual that is not otherwise health information
Biometric information that is to be used for the purpose of automated biometric verification or biometric identification
Biometric templates.

3. Collection

3.1 Solicited information

Generally, personal information is collected in order for Complete Property Training Pty Ltd to properly and efficiently carry out its functions. Complete Property Training Pty Ltd only collects personal information for purposes that are directly related to our functions or activities under the National Vocational Education and Training Regulator Act 2011 (NVR Act), or the Freedom of Information Act 1982 (FOI Act), and only when it is reasonably necessary for or directly related to Complete Property Training Pty Ltd ‘s functions.

Complete Property Training Pty Ltd will only collect sensitive information from individuals if the individual consents to the collection, unless:

the sensitive information is required or authorised by law
a permitted general situation exists
a permitted health situation exists
the sensitive information is required for an enforcement related activity

3.1.1 Information collected from an individual

Complete Property Training Pty Ltd uses personal information only for the purposes for which it was provided and for directly related purposes (unless otherwise required by or authorised under law). We also collect information in relation to employment services, human resource management, and other corporate service functions. Generally, the purposes for which Complete Property Training Pty Ltd collects personal information are when an individual:

submits an application relating to registration, including reconsideration of decisions relating to registration
submits an online complaint form about a training provider
submits an email complaint about Complete Property Training Pty Ltd or an employee
makes payment for an Complete Property Training Pty Ltd fee or charge, either via application or over the telephone, or when Complete Property Training Pty Ltd must refund an amount to an individual
submits a Freedom of Information (FOI) request via email
contacts Complete Property Training Pty Ltd seeking information or advice about Complete Property Training Pty Ltd ‘s functions, application queries or to lodge a complaint
is interviewed as part of an audit of a registered training organisation
provides intelligence information to Complete Property Training Pty Ltd for audit or investigation
submits an application for, or commences employment with Complete Property Training Pty Ltd , or
as an employee of Complete Property Training Pty Ltd , submits information to human resources for health records, or for a claim for compensation

An individual may, in some circumstances, such as lodging a complaint, prefer to remain anonymous, or to use a pseudonym, when interacting with Complete Property Training Pty Ltd. Whilst this is acceptable to Complete Property Training Pty Ltd, individuals should be aware that if they choose to do this, it may make investigating complaints or providing specific information impracticable, and it may lessen Complete Property Training Pty Ltd’s ability to provide its usual level of service.

Complete Property Training Pty Ltd generally collects personal information directly from the individual or their authorised representative.

3.1.2 Information collected from a third party

Sometimes personal information is collected 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. Complete Property Training Pty Ltd may also collect personal information from a third party for a specific purpose, such as an investigation, or when an Complete Property Training Pty Ltd is in the process of closing down and Complete Property Training Pty Ltd collects student information for the purpose of placing affected students with another training provider.

If Complete Property Training Pty Ltd collects personal information from a third party, Complete Property Training Pty Ltd ASQA will take reasonable steps to inform affected individuals that their personal information has been collected from a third party as soon as practicable after the collection has taken place. See 4.2 – notifying the individual if information is collected from a third party.

3.2 Unsolicited Information

If Complete Property Training Pty Ltd receives unsolicited information, it will determine if the information is required to carry out its functions.

If Complete Property Training Pty Ltd determines that the information is not required, and does not form part of a Commonwealth record, than it will destroy or de-identify the information as soon as practicable.

If Complete Property Training Pty Ltd determines that the information is required, then the information will be treated as solicited information as per 3.1 Solicited information.

4. Notification

4.1 Notifying the individual at collection

When collecting personal information directly from an individual, Complete Property Training Pty Ltd will take reasonable steps to notify, or otherwise ensure that the individual is aware:

that Complete Property Training Pty Ltd ‘s privacy policy provides information about how to access and seek correction of that personal information, and about how to lodge a complaint about a breach of the APPs
whether Complete Property Training Pty Ltd is likely to disclose an individual’s personal information to overseas recipients and, if it is practicable to specify, the countries in which those recipients are likely to be located.

4.2 Notifying the individual if information is collected from a third party

If Complete Property Training Pty Ltd collects personal information from someone other than the individual, or the individual may not be aware that the organisation has collected the personal information, reasonable steps will be taken to notify the individual, or otherwise ensure that the individual is aware:

that Complete Property Training Pty Ltd collects or has collected the information
of the circumstances of the collection, including
- from whom the information was collected, and
- the law under which Complete Property Training Pty Ltd collected the information
to whom Complete Property Training Pty Ltd may disclose the information, and
of the consequences of Complete Property Training Pty Ltd not collecting the information

5. Use and disclosure of personal information

Complete Property Training Pty Ltd will only use and disclose personal information for the primary purposes for which it was collected unless:

the individual has consented to the information being used for a secondary use or disclosure
the individual would reasonably expect Complete Property Training Pty Ltd to use or disclose the information for the secondary purpose and that purpose is related to the primary purpose, or
the use or disclosure of the information is required or authorised by or under an Australian law or a court/tribunal order
a permitted general situation exists in relation to the use or disclosure of the information, for example, if Complete Property Training Pty Ltd believes that the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or
Complete Property Training Pty Ltd reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

Complete Property Training Pty Ltd will only use sensitive information for a secondary purpose if it is directly related to the primary purpose. Some personal information provided to Complete Property Training Pty Ltd through application forms will be published on the national register, training.gov.au, in accordance with section 216 of the NVR Act. The information may also be shared with state and territory government and other Australian Government authorities and ministers, occupational licensing bodies, overseas authorities, and others in accordance with the information sharing provisions contained in the NVR Act or the provisions of the Privacy Act.

5.1 Disclosing personal information overseas

In situations where Complete Property Training Pty Ltd may disclose personal information overseas, Complete Property Training Pty Ltd will take reasonable steps to ensure that the overseas entity will comply with the APPs.

5.2 Use of personal information for direct marketing purposes

Complete Property Training Pty Ltd will only use personal information for direct marketing purposes where it could be reasonably expected that the individual would be aware that Complete Property Training Pty Ltd would use the information in that way.

6. Data quality

Complete Property Training Pty Ltd will take reasonable 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 individuals that their personal information has changed, and at other times as necessary. Complete Property Training Pty Ltd will also take reasonable steps to ensure the accuracy and completeness of the information prior to any disclosure of the information.

7. Data security

Complete Property Training Pty Ltd takes steps to protect the personal information we hold against interference, loss, unauthorised access, use, modification or disclosure, and against other misuse. When no longer required, personal information is destroyed in a secure manner, or deleted in accordance with Complete Property Training Pty Ltd.’s Records Management Policy, in compliance with the General Disposal Authority issued by the National Archives of Australia.

8. Access and correction

8.1 Access and correction under the Privacy Act

Unless Complete Property Training Pty Ltd is authorised to refuse access to information under the FOI Act or any applicable provisions of any law of the Commonwealth, Complete Property Training Pty Ltd will grant an individual’s request for access to the personal information that Complete Property Training Pty Ltd holds about them. Individuals may also request that Complete Property Training Pty Ltd correct any personal information about the individual that Complete Property Training Pty Ltd holds. Complete Property Training Pty Ltd will only update the information if it is satisfied the information it holds is incorrect. If Complete Property Training Pty Ltd is satisfied that an individual’s personal information is incorrect, Complete Property Training Pty Ltd will take reasonable steps to correct that information to ensure that it is accurate, up-to-date, complete, relevant and not misleading.

Complete Property Training Pty Ltd will provide a response to any request for access or correction to personal information within 30 days. If refusing the request, Complete Property Training Pty Ltd will provide a written statement of reasons for the refusal and remind the individual of the available complaint mechanisms, which are outlined below in 9 Complaints. For clarity purposes, Complete Property Training Pty Ltd will also take reasonable steps to associate a statement with the personal information that it refuses to correct.

Individuals will not be charged for requests for access or correction to their personal information. Members of the public should direct their requests to Complete Property Training Pty Ltd.’s Privacy Contact Officer. Complete Property Training Pty Ltd staff should direct their requests to the Manager, Human Resources

8.2 Access, amendment or annotation under the FOI Act

Individuals may also make a request to Complete Property Training Pty Ltd for access, amendment or annotation to their personal information under the FOI Act. Complete Property Training Pty Ltd will respond to these requests in accordance with the FOI Act. If unsatisfied with the response received from Complete Property Training Pty Ltd, an individual may seek an internal review of the FOI decision from Complete Property Training Pty Ltd. An individual may also request that the Australian Information Commissioner review Complete Property Training Pty Ltd.’s decision. In accordance with the Freedom of Information (Charges) Regulations 1982, Complete Property Training Pty Ltd does not charge for request for, or access to personal information.

9. Complaints

If a member of the public wishes to lodge a complaint about how Complete Property Training Pty Ltd handles personal information, or if they feel Complete Property Training Pty Ltd has breached the APPs, they can contact Complete Property Training Pty Ltd to discuss the matter. If an employee of Complete Property Training Pty Ltd wishes to lodge a complaint about how Complete Property Training Pty Ltd handles personal information, or if they feel Complete Property Training Pty Ltd has breached the APPs, they can contact the Chief Executive Officer or their representative.

10. Privacy Contact Officer

10.1 Members of the public

If you have any questions or complaints about privacy, confidentiality or access to your personal information, and are a student or prospective student, please contact Complete Property Training Pty Ltd

10.2 Complete Property Training Pty Ltd employees

If you have any questions or complaints about privacy, confidentiality or access to your personal information, and are Complete Property Training Pty Ltd employee, please contact the designated officer.