Last Updated 15 October 2020
1. Collection of Personal Information
How we collect personal information
We collect personal information about individuals from schools that we provide our products and services to (“Clients“). We also collect personal information directly from individuals that use our products or services (each an “authorised user“).
Clients that use Career Central as their student career management system may choose, at their discretion, to provide us with additional information about their students to store in Career Central for the purpose of us making our products and services available to the students as authorised users. Clients may also create accounts in Career Central for students and/or their parents or legal guardians by importing their existing records and providing those individuals with access credentials. Student, parent and legal guardian users who are provided with access credentials may enter information about themselves or their children directly into Career Central.
Other examples of the types of circumstances in which personal information may be collected by Career Central, include when a Client or an authorised user:
- requests to download a document, product trial, video or e-lesson from Career Central;
- makes an enquiry through our website, online enquiry service or any other online platform operated by Career Central from time to time;
- lodges a support request regarding Career Central product or service;
- subscribes for a newsletter;
- registers to attend a seminar or event (such as a webinar or training); or
- otherwise contacts or interacts with Career Central.
Types of personal information we collect
The types of personal information that Career Central may collect from Clients or authorised users, include:
- internal review, analysis, reporting and work with students;
- academic performance data (task and assessment marks, standardised testing marks, learning observations);
- contact information (student-family relationships and living arrangements);
- notes attached to student profiles, which may capture any additional information included by the Client; and
- any other information provided to us.
As a general rule, we do not collect sensitive Information (as defined In the Privacy Act). However, If we do, It will usually be for purposes of facilitating the operation of our business or to provide our products or services to you and we will seek your consent to collect your sensitive information.
2. How We Use and Disclose Personal Information
Use and disclosure
We will use and disclose your personal information only in compliance with the Privacy Act and only for the purposes for which it was collected. We collect, hold, use or disclose your personal information for the following purposes:
- To provide our products and services to our Clients and authorised users;
- To operate our business;
- To operate and maintain our website and online platforms;
- To communicate with our Clients and authorised users;
- To bill and maintain our accounts with our Clients;
- To improve our service and product offerings to our Clients and authorised users;
- To our third party service providers (located in Australia and overseas) to permit them to provide features and services on our behalf or as requested by our Client (see ‘Overseas Disclosure of Personal Information’ section);
- To resolve a problem or support issue on behalf of the relevant Client or authorised user;
- To protect the rights, property or personal safety of any Client or an authorised user, or any member of the public, or to protect our interests;
- As may be required by law or as ordered by a court;
- In the event of a reorganisation, merger, sale, assignment, bankruptcy or other disposition of our business assets or shares in our company; or
- Any other purpose authorised by our Clients and authorised users.
We may use or disclose information that is not personal information, including aggregated, de-identified data, for a variety of purposes subject to applicable law, including:
- to improve our educational products for adaptive learning purposes;
- to customize the student or user experience;
- to demonstrate the effectiveness of Career Central, including in our marketing materials; or
- to develop and improve our products or services.
Electronic marketing communications
From time to time, we may send our Clients direct marketing communications and relevant information about our products and services that we consider may be of interest to our Clients. These communications may be sent in various forms, including SMS and email. If a Client no longer wish to receive any communications from us, then please follow the unsubscribe link contained in the relevant electronic communication, or contact our Privacy Contact Officer using the details set out below. If a Client wants to be removed from any Career Central database, please contact our Privacy Contact Officer using the details set out below.
We do not use personal information collected through Career Central to send student authorised users marketing and promotional materials.
Career Central will not disclose personal information to third parties for marketing purposes without the relevant individual’s consent.
Under no circumstances will Career Central sell (or otherwise receive payment for licensing or disclosure of) personal information.
3. Storage of Personal Information
Career Central is cloud-hosted, and has a localised installation running in Australia, on Amazon Web Services. Career Central connects to various school information systems (via Wonde, Australia) to automatically import student data. For more about Wonde: How Wonde Works Alternatively, student accounts can be created via CSV file upload; or, individual self-set up. We work our Clients and authorised users to set up accounts.
4. Overseas Disclosure of Personal Information
5. Usage Information and Cookies
When a Client or any of its authorised users use Career Central, our servers automatically collect the Internet Protocol (“IP”) address associated with the Client’s or authorised user’s computer. We may also collect additional information such as the login timestamp, the user’s browser type and version, and the operating system of the user’s computer. This information is logged to help us to diagnose technical problems, to administer Career Central and to improve user-experience of our product, services, website and platforms.
Anonymous aggregated information is collated for analysis and is only available to a limited number of Career Central staff. It is evaluated and published in reports that show usage patterns. One of the tools used by Career Central for this purpose is Google Analytics. For more information on how Google Analytics collects and processes data, please see https://policies.google.com/technologies/partner-sites.
Web beacons may also be used in some of our emails to let us know which emails (and which links within those emails) have been opened by recipients. This allows us to gauge the effectiveness of our customer communications.
For security reasons, Career Central also uses software programs to monitor network traffic and identify unauthorised attempts to upload or change information, or otherwise cause damage. By using Career Central, you agree to the use of these tracking technologies.
6. How You May Access or Modify Your Information
A student authorised user may request access to or correction of their personal information held by Career Central. Student authorised users may access or correct their personal information held by Career Central by accessing their accounts or contacting Career Central at email@example.com.
We will respond to requests for access or correction with the timeframe required by the Privacy Act.
We are committed to protecting the security, integrity and confidentiality of the personal information that we hold through the use of physical and technical safeguards. We use SSL and server authentication technology to protect data when Career Central is accessed using a supported web browser.
Career Central uses cloud-based services, with entities that host data within Australia and New Zealand to store and process personal information. We host the data that we collect in secure server environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time Clients or other users sign on to Career Central. Most of our Clients use Microsoft or Google Single Sign On (SSO) for secure access. The internet, however, is not perfectly secure and Career Central is not responsible for security breaches not reasonably within its control.
We require that each authorised user of Career Central maintain the confidentiality of their user name and password. If a Client or their authorised user becomes aware of any unauthorised use of an account, loss of an authorised user’s account credentials, or otherwise suspects a security breach, they must notify us immediately.
8. Data Retention
9. What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact Career Central at firstname.lastname@example.org and provide details of the incident so that it can be investigated.
The Career Central will treat your requests or complaints confidentially and will endeavour to ensure that your complaint is resolved in a timely and appropriate manner.
If you are not satisfied with the outcome, you may then refer the matter to the Office of the Australian Information Commissioner at:
- Website: www.oaic.gov.au
- Phone: 1300 363 992
10. Updates to This Policy