The Institute of Health and Nursing Australia (IHNA) is committed to providing quality training and assessment in accordance with the Standards for Registered Training Organisations (SRTOs 2015). As such, IHNA is required to comply with Federal law regarding Privacy and confidentiality of employees, clients and contractors. The purpose of this policy is to outline how IHNA complies with the Privacy Act 1988 and the Australian Privacy Principles (APPs) 2014, in accordance with the Standards for Registered Training Organisations (SRTOs 2015) and the Higher Education Support Act 2003 and the VET Student Loan Act and Rule 2016.
IHNA is bound by the Australian Privacy Principles (APPs) that have replaced the previous National Privacy Principles in the Privacy Act 1988 (Commonwealth) and the Higher Education Support Act 2003 (NPPs) for organisations from 12 March 2014 as well as other applicable laws and codes affecting the personal information that it collects from staff and students. IHNA is committed to respecting the right to privacy and protecting the personal information of its staff and clients.
The updated policy is easily available for all staff and students on the Knowledge hub(KH).
The Chief Operation Officer (COO) has the overall responsibility of this policy.
Personal Information: Information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Student/s: refers to all persons enrolled in a unit of study who are, or would be, entitled to apply for a VET Student Loan under the VET Student Loan Act 2016 or FEE-HELP assistance under Clause 43 of Schedule 1A of the Act. and
Client: refers to student and also means a learner, enterprise or organisation that uses or purchases the services provided by the Institute of Health and Nursing Australia as defined by Standards for Registered Training Organisations 2015
Staff: All the present and past employees of the Health Careers International (HCI) group of companies including but not limited to IHNA
Personal information will not be collected unless:
Personal information will not be collected by unlawful or unethical means.
Where personal information is collected for inclusion in a record or in a generally available publication, the Institute of Health and Nursing Australia will take all reasonable and practicable steps to ensure that, the student concerned is made aware of:
Where the Institute of Health and Nursing Australia solicits and collects personal information for inclusion in a record or in a generally available publication it will take reasonable steps to ensure that:
IHNA is committed to comply with obligation under the Privacy Act 1988, and the associated Australian Privacy Principles (APPs), in the way it specifically collects, uses, secures and discloses personal information. IHNA is committed to safeguarding any confidential information obtained by the RTO.
IHNA will ensure that:
IHNA respects and acknowledges the choice of anonymity and pseudonymity by individuals dealing with IHNA. IHNA provides opportunities for individuals to interact anonymously or by pseudonym with IHNA where appropriate. For example of anonymous dealings may include an unidentified individual telephoning an RTO to make a general enquire about its courses or services.
Pseudonymity requires that an individual may contact an RTO and use a name, term or descriptor that is different from the person’s actual name. Examples may include an email address that does not contain the person’s actual name, and/or a user name that a person uses when participating in an online forum.
Personal information should only be linked to a pseudonym if this is required or authorised by law.
Situations where it is impractical to implement Anonymity and/or Pseudonymity
While IHNA acknowledges Anonymity and Pseudonymity as a privacy principle, there are instances where identification is necessary to proceed with a matter.
The following are examples where it may be impracticable to deal with an individual who has not disclosed their actual identity:
Personal Information is defined in the Privacy Act 1988 as “information or an opinion about an identified individual, or an individual who is reasonably identifiable:
Sensitive Personal Information is defined in the Privacy Act 1988 as "information or an opinion about an individual's" that is also personal information, such as:
Information about students:
IHNA collects personally identifiable information that students provide when they register or enrol for any educational courses or programs, when they use certain IHNA online services or products, or when they enter promotions. The Institute’s preferred source of personal information is the individual concerned. However, IHNA may also receive information from other sources such as other members of the Health Careers International Group.
Under the Freedom of Information Act, Vic 1982, the Institute of Health and Nursing Australia will permit a Student to apply for and receive a copy of their VET personal information that the provider holds on the student’s record.
Information about Staff:
IHNA collects personal information from its staff which may be used for Selection, Appointment, Promotion, General Administration or Provision of Services to staff. The Institute’s preferred source of personal information is the individual concerned. However, IHNA may also receive information from other sources such as
IHNA takes all reasonable steps to ensure that information collected:
Personal and confidential information about individual staff members will not be released, without the staff members consent or request, to persons within or outside the Institute, except in circumstances required by law (e.g. income tax certificate).
Information about staff members employed by the Institute is considered confidential although some staff members may be identified publicly in publications such as hand books. The Institute is also required to comply with external authorities and submit general statistics about itself. These statistics do not specific identify individuals.
In certain circumstances relating to the employment of staff members, the Institute releases information to other organisations. For example, if a staff member of the Institute of Health and Nursing Australia resigns from their position to work for another organisation, it may be necessary to release information to the other organization, such as details of tha staff member’s study and long service leave credits and superannuation agreement. In such matters, the Institute will act as if it has the member’s consent unless informed to the contrary.
At the written request of a staff member, the Institute may release personal information to another organisation stating, for example, that the person is a staff member of the Institute, the position they occupy and the remuneration they receive.
The Institute does not release personal information about any student without the student’s written consent. Information on a student’s individual file is only accessible to Institute staff whose official responsibilities involve them in student and student related matters.
Releasing confidential information (including units attempted, units passed, grades, address, and phone number) to anyone other than the student or authorised Institute personnel, or as part of legal reporting requirements to relevant and authorised authorities is strictly prohibited.
If a student wishes to have information released concerning their enrolment at IHNA, they must:
The Institute may receive telephone messages for a student (and thereby acknowledge the students enrolment) but no personal details are disclosed to any caller.
Unless instructed otherwise, personal information may be shared with related companies within Health Careers International Pty Ltd (HCI) where it will remain confidential. IHNA does not collect or compile personally identifiable information for the dissemination or sale to outside parties for consumer marketing. It will only disclose information when:
These outside contractors act on behalf of IHNA and do not operate their own personal agendas while processing personal information. At times personal information may be provided to these outside contractors to undertake the contracted task. All information remains the property of IHNA at all times and the outside contractors are bound by specific confidentiality and non-disclosure agreements.
Where personal information is disclosed for the purposes of enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the purpose of the protection of the public revenue, the record-keeper shall include in the record containing that information a note of the disclosure. This will be noted on staff/student file.
A person, body or agency to whom personal information is disclosed will not use or disclose the information for a purpose other than the purpose for which the information was given to the person, body or agency.
IHNA takes the protection of customers, their information and their profile most seriously.
IHNA adheres to strict industry procedures and professional standards of conduct for the operation of enrolments and online education systems. It utilises high-level security practices and employs multiple layers of security mechanisms to ensure that all data is protected and secure.
The Institute of Health and Nursing Australia will ensure that:
While registering or paying for a course through IHNA’s website (www.ihna.edu.au), IHNA will need to collect the credit card details (if paying by credit card) along with other personal information. This allows IHNA to process and complete the enrolment.
IHNA utilises the Bank of Melbourne Payway facility for the receipt and processing of all electronic card payments. IHNA does not store any information about an individual’s credit card.
IHNA acknowledges that as per the new APP 12, it is required to provide access to all of an individual’s personal information it holds, even if that information is also the personal information of another individual, unless there are mitigating circumstances precluding access or legal grounds to refuse access.
IHNA shall consider whether the individual has a right of access to the information under other legislation. If not, IHNA may make a discretionary decision to either grant or deny access to the information.
Verifying an individual’s identity
IHNA must be satisfied that a request for personal information under APP 12 is made by the individual concerned, or by another person who is authorised to make a request on their behalf, for example, a legal guardian or authorised agent.
It would be impracticable for IHNA to deal with an anonymous request for personal information.
The steps appropriate to verify an individual’s identity will depend on the circumstances. In particular, whether the individual is already known to or readily identifiable by the RTO. The minimum amount of personal information needed to establish an individual’s identity will be sought. Where possible, the information may be sighted rather than copied or collected for inclusion in a record. For example, in a face-to-face dealing with an individual IHNA may reserve the right to record that an identity document was sighted without copying the document.
IHNA shall consider an application to access information not exceeding 30 calendar days after the request has been raised by an individual or other parties and after the necessary verifying process is completed.
IHNA also provides that, without limiting APP 12.5, ‘access may be given through the use of a mutually agreed intermediary.' where direct access would otherwise be refused.
For example, an intermediary may need to be a qualified health service provider if used to give access to health information
Correction of Data available with IHNA
In line with the APP 13.1, IHNA will take reasonable steps to correct personal information it holds, to ensure it is accurate, up-to-date, complete, relevant and not misleading, having regard for the purpose for which it is held.
The requirement to take reasonable steps applies in two circumstances:
IHNA will follow minimum procedural requirements in relation to correcting personal information, by:-