OUR PHILOSOPHY
Little Wonders Creative Childcare Australia Pty Ltd ACN 632 108 920 trading as Little Wonders Creative Childcare Australia ABN 37 632 108 920 (we or us) is committed to protecting and respecting your privacy by handling all personal information securely and with care, in accordance with the Australian Privacy Principles (the APPs) as set out in the Privacy Act 1988 (Cth) (the Act). The APPs regulate the manner in which personal information is collected, used, disclosed, stored, accessed, corrected and disposed of.
We have adopted this Privacy Policy (Policy) to ensure that we comply with the APPs. The Policy provides an overview of the types of information held by us, as well as our information handling practices, procedures, and systems.
Please read the Policy carefully to ensure that you understand our practices regarding the management of any information you disclose to us.
WHAT IS ‘PERSONAL INFORMATION’ AND ‘SENSITIVE INFORMATION’?
‘Personal Information’ is any information or an opinion about you that identifies you or your child or that could reasonably identify you or your child. This could include (but is not limited to) information such as your name, contact details, date of birth or employment details or your child’s name and date of birth.
‘Sensitive Information’ is any information or opinion about you or your child which is health information or which relates to your or your child’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record. The APPs place more stringent obligations on us when we handle sensitive information.
WHAT INFORMATION DO WE COLLECT?
The Personal Information and Sensitive Information that you disclose to us or which we obtain from third parties enables us to provide educational, care and health related support and services to you and your child. We will only collect and retain information that is reasonably necessary for the performance of our activities and functions so that we are able to provide you with the services you require or which we recommend to you.
The kinds of Personal Information and Sensitive Information we collect and hold depends on the specific services provided to you, but will generally include basic personal contact information, as well as other information that is deemed relevant. This will usually include the following:
1. your contact details (name, postal address, email address, etc.);
2. your personal details (date of birth, gender, cultural identity, socio-economic status, etc.);
3. your child’s personal details (date of birth, gender, etc.);
4. your child’s health information and medical history;
5. information on personal issues, experiences and relationships;
6. information on your child’s personal issues, experiences and relationships; and
7. yours and your child’s family background (which can include Personal Information and Sensitive Information of third parties).
If you do not provide us with the required information, we may not be able to perform the services which you require us to provide.
HOW WE COLLECT AND HOLD PERSONAL AND SENSITIVE INFORMATION
During the course of providing our services to you and your child, we will collect Personal Information and Sensitive Information from you by asking you verbally for that information, or requiring you to complete forms or documents necessary to enable us to provide you and your child with our services.
We will take reasonable steps to store information in a secure manner, protected by a combination of physical and technical measures. Information that we store in hard copy is stored securely within a locked filing cabinet. Information that we store electronically is stored in an online secure cloud-based facility and/or on an external hard drive, which are password protected and kept in secure locations at all times.
We will take all reasonable steps to protect the security of yours and your child’s Personal Information and Sensitive Information held by us. This includes appropriate technology to protect your Personal Information and Sensitive Information stored electronically, such as passwords, as well as limiting the number of personnel who have access to your Personal Information and Sensitive Information, whether stored electronically or in hard copy.
To limit the possibility of human error, we will regularly provide training to our staff regarding the collection, storage and handling of yours and your child’s Personal Information and Sensitive Information.
When we no longer require your Personal Information and Sensitive Information, it will be destroyed or permanently de-identified. However, we will retain information for as long as the law requires.
WHAT HAPPENS IF THERE IS A DATA BREACH?
A data breach is when Personal Information and/or Sensitive Information held by us is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference. Examples of a data breach are when a device containing personal information of clients is lost or stolen, an entity’s database containing personal information is hacked or an entity mistakenly provides personal information to the wrong person. A ‘data breach’ may also constitute a breach of the Privacy Act, however this will depend on whether the circumstances giving rise to the data breach also constitute a breach of one or more of the APPs.
We have a data breach response plan. Our actions in the first 24 hours after discovering a data breach are crucial to the success of our response. A quick response can substantially decrease the impact on the affected individuals.
However, despite our reasonable efforts, we cannot guarantee that the security of yours or your child’s Personal Information and Sensitive Information will not be breached. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to a data breach, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.
THIRD PARTY PERSONAL AND SENSITIVE INFORMATION
We may ask you for Personal Information and Sensitive Information about other individuals, for example, your family members. If you provide us with this information, we rely on you to tell those individuals that you are giving their Personal Information and Sensitive Information to us, and to make them aware of this Policy.
HOW WE USE YOUR PERSONAL AND SENSITIVE INFORMATION
We may use yours or your child’s Personal Information and Sensitive Information for the following purposes:
- to confirm yours or your child’s identity;
- to provide you and your child with educational, care and health related support and services;
- to contact you directly about your services and other services which we offer from time-to-time;
- to share it with our related entities, subsidiaries or other specialist providers as required to perform functions on our behalf;
- for other purposes communicated to you when your information is collected;
- for disclosures required by law, regulation or court order; and/or
- to conduct internal client research and assessment.
This includes us using this information to communicate with you about our services, for internal administration, direct marketing and planning purposes. We will also use yours and your child’s personal information for purposes related to those described above which would be reasonably expected by you. You may request not to receive direct marketing communication from us.
We will not use yours or your child’s Personal Information and Sensitive Information for purposes other than those described above, unless we have your consent, or there are specified law enforcement or public health and safety reasons (as permitted under the Act).
TRANSFER OF PERSONAL AND SENSITIVE INFORMATION
We may outsource business functions to other organisations and as such, it is possible that your Personal Information and Sensitive Information will, as required from time to time, be disclosed or transferred to other organisations to allow them to assist us to provide you with services.
It is very unlikely that we will disclose yours or your child’s Personal Information and Sensitive Information to overseas recipients. If we transfer your Personal Information outside Australia, we may endeavour to comply with the requirements of the Act that relate to transborder data flows, but we cannot guarantee compliance and you specifically agree that you understand this. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to our non-compliance with APP 8.1, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.
You should also be aware that:
- any overseas recipient may not be subject to any privacy obligations or to any principles similar to the APPs;
- you may not be able to seek redress in the overseas jurisdiction; and
- any overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
While we will not directly disclose your Personal Information and Sensitive Information to overseas recipients without your consent, the entities to which we may disclose your Personal Information and Sensitive Information may do so. We are unable to say what countries, if any, those recipients are likely to be located in.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy discloses our current privacy practices. From time to time and in line with client expectations and legislative changes, this Privacy Policy will be reviewed, and, if appropriate, updated at any time without notice. We will endeavour to provide you with notice of the changes as soon as reasonably practicable to do so.
HOW TO CHANGE OR ACCESS THE INFORMATION WE HOLD ABOUT YOU
You can access the Personal Information and Sensitive Information we hold about you and your child.
We will take reasonable steps to ensure that any Personal Information or Sensitive Information that we collect, use, store or disclose, is relevant, accurate, complete and up-to-date. If you believe the information we hold is inaccurate, incorrect, or incomplete, you may request that your information be corrected and we can then take reasonable steps to correct this information.
Please contact our Privacy Officer (details below) to access or request updates to any Personal Information and/or Sensitive Information which we hold.
COOKIES OR WEB BEACONS
If you are accessing this Privacy Policy via our website (the Site), we may use cookies on the Site from time to time. Cookies are small text files created by a website and stored in your computer, which recognize and track your preferences. Cookies, on their own, will not provide us with your email address or other personally identifiable information. However, cookies allow third parties, such as Google, Facebook and Instagram, to cause our advertisements to appear on your social media and online media feeds as part of our online marketing campaigns. If and when you choose to provide the Site with personal information, this information may be linked to the data stored in the cookie. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing our website.
If you are accessing this Privacy Policy via the Site, we may use web beacons on the Site from time to time. Web beacons (also known as Clear GIFs) are often a transparent graphic image that is placed on a website or in an email that is used to monitor your behaviour. For example, web beacons can be used to count the number of users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
LINKS TO OTHER WEBSITES
If you are accessing this Privacy Policy via the Site, the Site may contain links to other third party websites. We have no control over those websites and we are in no way responsible for the protection and privacy of any personal information you provide whilst visiting those third party websites. Those websites will not be governed by this Privacy Policy and we recommend that you seek out their privacy policy when redirected to a third party website to ensure that you are aware of how they may use your personal information.
COMPLAINTS
If you have a complaint about the way we have dealt with yours or your child’s Personal Information or Sensitive Information, or about this Policy itself, we invite you to provide written details of your complaint to our Privacy Officer (contact details below).
Our Privacy Officer will contact you within 14 days of the date we receive the written details of your complaint to acknowledge that we have received it. Our Privacy Officer will then:
1. review the way we dealt with yours or your child’s Personal Information and/or Sensitive Information;
2. conduct an internal investigation (if necessary) into how your Personal Information and/or Sensitive Information came to be handled in the way that it was; and
3. provide a report to you within one month of the date we acknowledged receipt of your complaint.
If you believe we have breached the APPs, you may also lodge a complaint with the Office of the Australian Information Commissioner.
CONTACT US
Should you have any queries, complaints or comments about this Privacy Policy, please contact our Privacy Officer in writing by post or email at:
POST: Attention: The Privacy Officer
Little Wonders Creative Childcare Australia
c/- 522 Boundary Street
Toowoomba QLD 4350
EMAIL: [email protected]
PRIVACY NOTICE
We are required by law to give you this notice before, or at the time we collect your Personal Information and/or Sensitive Information. If it is not reasonably practicable for us to give you this notice at that time, we will give it to you as soon as we are able.
1. The entity collecting your personal information is Little Wonders Creative Childcare Australia Pty Ltd ACN 632 108 920 trading as Little Wonders Creative Childcare Australia ABN 37 632 108 920. You can contact us by phoning 0488 233 252 or emailing [email protected].
2. We have collected or will be collecting Personal Information and/or Sensitive Information about you and your child or children. Personal Information may include any information or an opinion about a person if they are reasonably identifiable by that information. Sensitive Information may include any information or opinion about a person which is health information or which relates to your racial or ethnic origin, political opinion, religious and/or philosophical beliefs, sexual preferences or practices or criminal record. The kind of Personal Information and Sensitive Information we collect depends on the circumstances and nature of your interaction with us, but will likely include yours and your child’s name, address, date of birth, racial information, health information, and information on personal issues and experiences. We will generally collect Personal Information and Sensitive Information about you and your child from you personally, however we may also need to obtain that information from third parties.
3. We collect Personal Information and Sensitive Information for the purposes of providing our clients with the educational, care and health related support and services they request of us, or which we recommend be provided to you or your child. Please see our Privacy Policy for additional details about how we may use any Personal Information and Sensitive Information you disclose to us.
4. If we do not collect the Personal Information and Sensitive Information we request from you we may not be able to provide you or your child with the services that you ask us to provide or which we recommend we provide.
5. We will not usually disclose Personal Information and Sensitive Information to other entities, who may or may not be bound to comply with the Australian Privacy Principles. Our Privacy Policy sets out how we may use or disclose your Personal Information and Sensitive Information in greater detail.
6. Our Privacy Policy also includes information about how you can access and correct your Personal Information and Sensitive Information, how you can complain about any breach by us of the Australian Privacy Principles and how we will deal with that complaint. The Privacy Policy is available on our website, Facebook page or upon request from Little Wonders Management.
7. It is very unlikely that we will disclose your Personal Information and Sensitive Information directly to overseas recipients. If we transfer your Personal Information and Sensitive Information outside Australia, we will comply with requirements of the Act that relate to transborder data flows. While we will not directly disclose your Personal Information and Sensitive Information to overseas recipients without your consent, the entities to which we may disclose your Personal Information and Sensitive Information may do so. It is not practicable for us to advise you which countries those recipients may be located in.