PRIVACY POLICY

AIM

Drug and Alcohol Testing Institute regards Participant privacy as an important part of our relationship with our Participants, and is committed to the Australian Privacy Legislation.

The intent of this Policy is to demonstrate how Drug and Alcohol Testing Institute complies with the Commonwealth Privacy Act 1988, the Internet privacy standards, the Privacy Amendment (Enhancing Privacy Protection) Act 2012, and the Australian Privacy Principles (APP) in the way that all Personal Information collected about Participants is managed in an open and transparent way, is used only for recognised purposes, and is stored and managed compliantly.

We collect Personal Information from Participants for the purpose of providing Training / or services to the Participant or as otherwise described in this Policy.

The Policy describes procedures and purposes, and provides information for Participants to address any concerns with the way Drug and Alcohol Testing Institute manages their Personal Information.

By directly providing Drug and Alcohol Testing Institute with Personal Information on our website, through any Promotional Products, Enrolment Application Form, via phone or networking events, the Participant is giving consent to allow Drug and Alcohol Testing Institute and other third parties elected by us to collect, store, use and disclose Personal Information including Sensitive Information, and to deal with that information on the terms set out in this Policy.(APP 3.3)

This policy meets the Standards for Registered Training Organisations 2015 (Standard 5, 8.5), and best business practice.

All references to APP (e.g. APP 3.3) map to the Principles of the Australian Privacy Principles.

OBJECTIVE

This Privacy Policy covers Personal Information collected from individuals who partake in Drug and Alcohol Testing Institute services (Participants).(APP 1.3)

Our Policy about the privacy of Personal Information collected by Drug and Alcohol Testing Institute is;

to retain it as confidential to us, except as required by Government (e.g. ASQA and NCVER), and
to be open, honest and transparent with the Participant about the content of that information (APP 1.1).

This Policy is accessible for no charge via our Website or copy may be provided as a PDF upon request. (APP 1.5, 1.6)

DEFINITIONS

The terms used in this document or have the meanings assigned to them below:-

“Australian Privacy Principles” (APP) are a single set of principles that apply to both agencies and organisations, which are together defined as APP entities. There are 13 Australian Privacy Principles which apply to the handling of Personal Information.

“NVR” means the National Vocational Education and Training Regulator Act 2011.

“Participant”,”you” means an individual participant, and / or employer of the participant, who partakes in services provided or delivered by Drug and Alcohol Testing Institute and includes an individual participant and / or employer who commences an application to undertake such a course or services (a prospective Participant).

“Personal Information” has the same meaning as in the Privacy Act 1988 (Cth) which is “information or an opinion about an identified individual, or an individualwho is reasonably identifiable whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not”.

“Privacy Policy” or “Policy” means this statement; which describes how Drug and Alcohol Testing Institute complies with the Privacy Act 1988 and the Australian Privacy Principles.

“Promotional Platforms” may include but is not limited to our website or partner websites, surveys, social media e.g. Facebook, LinkedIn.

“RTO” or ”Registered Training Organisation”means a training organisation registered by the Australian Skills Quality Authority (ASQA) in accordance with the VET Quality Framework.

“Sensitive Information” has the same meaning as in the Privacy Act 1988 (Cth) which is “(a) information or an opinion about an individual‘s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association,membership of a trade union, sexual orientation or practices, or criminal record that is also personal information; or (b) health information about an individual; or c) genetic information about an individual that is not otherwise health information; (d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or (e) biometric templates.”

“Training” means any Accredited Training or Non-accredited Training and / or Education Services provided or delivered to the Participant by Drug and Alcohol Testing Institute.

“Unique Student Identifier” From January 1 2015, the Australian Government mandatorily requires all Participants who are enrolled into Accredited Training to apply for a Unique Student Identifier (USI) with the VET Registry System. The VET Registry System ensures Participant information is kept secure. The USI is a reference number which allows access to the records and results from all VET training completed by the individual from 1 January 2015 onwards under the Student Identifier Act 2013 (Cth). For further information about the USI, please access the link: http://usi.gov.au/create-your-USI/Pages/default.aspx

“Website” means www.drugtesttraining.com.au and our affiliated websites

“we”, “us” or any similar term means the Drug Testing Institute Pty Ltd as trustee for Drug Testing Institute Trust, trading as Drug and Alcohol Testing Institute, as that term is defined in the Corporations Act 2001 (Cth) together with its related entities.

This Privacy Policy includes examples of the types of information we may collect and the kinds of organisations to which we may disclose information. These examples are illustrative and should not be considered a complete inventory of our information collection or sharing practices. Accordingly, the words “include” and “including” mean inclusion without limitation.

As used in this Privacy Policy, the words “company” and “companies” mean any corporation(s), limited liability company or companies, partnership(s) or other similar entity or entities.

POLICY

Management of Personal Information

Drug and Alcohol Testing Institute conducts our business in a way which complies with the Australian Privacy Principles (APP 1.2a)

Our policy about the privacy of Personal Information collected by us about Participants is;

to retain it as confidential to us, except as required by Government (e.g. ASQA and NCVER), and
to be open, honest and transparent with the Participant about the content of that information (APP 1.1).

This Policy is accessible for no charge via our Website or copy may be provided as a PDF upon request. (APP 1.5, 1.6)

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our services, including accessing promotional platforms, registering / subscribing to receive product or service information, or complete surveys, we may collect Personal Information.

We gather Personal Information about the Participant from general enquiries, promotional platforms, through registration / subscriptions, completion of the enrolment process, Website, and a variety of sources including, telephone calls with the Participant, networking events, enrolment forms, or other agreements with us. We may also gather Personal Information about the Participant from employers with which we maintain business relationships.(APP 1.4b)

The Personal Information collected from Participants may include but may not be limited to: (APP 1.4a, 1.4c)

Information provided by the Participant, such as the Participants’ name, address(es), employer(s), telephone number(s), fax number(s), e-mail address(es), date and place of birth, credit card information, Unique Student Identifier;
Information about the Participant’s transactions with us, our affiliates or others, including without limitation, details of the Training undertaken or being undertaken by the Participant, the Participant’s results and records, , personnel records and any relevant certificates or statements of attainment; and

We may also collect Sensitive Information about the Participant where it is necessary for the purpose of the Training.(APP 3.3a (ii))

We may collect your personal information for the following reasons: (#1.4d)

To contact you
To ensure that you are kept adequately informed about the progress of your matter
For billing and other administration purposes
When dealing with other parties to a matter
When required by law
In response to requests from law enforcement and government agencies, which will have their own privacy and disclosure policies.
When dealing with Courts or Tribunals
We keep your personal information on our database.

Contractors

Drug and Alcohol Testing Institute contract out a number of services on occasions. Our contractors may see some Personal Information. Typically, our contractors would include Information Technology Support Technicians, Accountants, and Database and Web Designers. Our contractors are bound by the terms of our Privacy Policy in addition to their own organisational Privacy Policy.

Collection of Solicited Personal Information (APP 2, 3)

It is necessary for Participants to provide correct Personal Information to Drug and Alcohol Testing Institute so we can address enquiries, provide training, satisfy regulatory requirements, carry out administrative tasks and conduct client satisfaction research (APP 2.2b)

We collect Personal Information generally directly from the Participant, via: a completed enrolment form, training proposal agreement, phone, email, requests for information on our website including subscriptions, our Promotional Platforms, completed surveys, in writing, networking events, documents provided to us by the Participant and through answering questions during an interview.

There may be other occasions when we collect the Participant’s Personal Information from other sources such as from an information service provider or a publicly maintained record. However, we will only collect Personal Information from these sources if it is unreasonable or impracticable to collect the Personal Information from the Participant.

We collect Personal Information for a variety of reasons, including (without limitation) to: (APP 3.2)

provide information to the Participant;
provide Training to the Participant;
store Training and personnel records for use by the Participant, and ourselves;
to meet our RTO obligations outlined in the National Vocational Education and Training Regulator Act 2011 and associated legislative requirements such as Standards for Registered Training Organisations 2015 and the Data Provision Requirements 2012.

On request by a Participant, we will take all reasonable steps to inform the Participant the purpose or relevance of the Personal Information we have collected.

We may also collect Sensitive Information about the Participant where it is necessary for the purpose of the Training. (APP 3.3a (ii), 3.5)

Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health. The Personal Information we collect about the Participant is information that has been provided to us directly by the Participant, through mediums such as (but not limited to) web, enrolment forms, enquiry forms. In most circumstances it will be necessary for us to identify the Participant in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer the Participant the opportunity of doing business with us without providing us with personal information, for example, if the Participant makes general inquiries about our services and our fees.

If Personal Information requested by us is not provided, then the Participant may be denied access to the Training or our services. (APP 3.2, 3.3)

Unsolicited Personal Information (APP 4)

We may receive Personal Information, including Sensitive Information, from third parties.

Where that information is necessary or an immediate adjunct to providing the Training, or service, or complying with the law, we will retain that information and deal with it in the same way as all other Personal Information.

Where that information is not necessary or an immediate adjunct to providing the Training, or service, or complying with the law, we will destroy that information or ensure that the information is de-identified.

Notification of the Collection of Personal Information (APP 5)

Sometimes, we may collect information from a third party, for the purpose of the enrolment procedure and to offer our services e.g. employer;

In these instances, this personal information is entered into our student management system and the Participant is notified of their enrolment via email. All communication is recorded in the student management system and the Participant is able to amend any personal information by contacting the Customer Service Team via email or phone.

Use or Disclosure of Personal Information (APP 6)

Drug and Alcohol Testing Institute places great importance on the security of all information associated with our Participants and clients. We have security measures in place, and take all steps reasonable to ensure that Personal Information under our control is protected from loss, misuse, interference, unauthorised access, alteration and disclosure. Information is recorded in hard copy and in electronic forms in secure databases, on secure premises, accessible only by authorised staff.

Drug and Alcohol Testing Institute retains information the Participant provides to us, which may include Personal Information and credit card details, to enable us to verify transactions and Participant details, in order to retain adequate records for legal and accounting purposes. Personal information is de-identified or destroyed securely when no longer required by us, unless otherwise required or authorised by law to retain the information.

Each transaction on a Participants file is recorded and kept securely within our Learning Management System. .(APP 6.5)

Disclosure to Employer

If the Participant has been registered by their employer for training, the Participant’s results and information regarding participation and status cannot be accessed by their employer (or its nominated representative).

We are unable to provide copies of certificates to employers under the ‘National Vocational Education and Training Regulator Act 2011’ in which we are bound to comply with.

Standard 23.1 of the Standards for NVR Registered Training Organisations 2012 require that an ASQA-registered provider must issue to persons whom it has assessed as competent a vocational education and training (VET) qualification or statement of attainment.

Further, the Australian Qualifications Framework (AQF) Qualifications Issuance Policy (2.1.1) states that graduates are entitled to receive certification documentation.

“This requirement of the Standards, and the entitlement granted by the AQF, apply regardless of:

which party entered into an agreement with the provider, and
who paid for the training.

If an employer engages a provider to deliver training and/or assessment to its employees, it is the employee who undergoes the assessment process.”

Therefore, the Participant/employee would be the person the provider has ‘assessed as competent’. The provider must issue the qualification or Statement of Attainment directly to the Participant / employee (rather than to the employer).

We may disclose information in response to requests from law enforcement and government agencies, which will have their own privacy and disclosure policies.

Direct Marketing.(APP 6.1, 6.2, 7.2b, 7.2c, 7.3, 7.6)

The provision of Personal Information by the Participant on our website or on our Promotional Platforms promoting our courses and services, has consented to allow us and other third parties elected by us to aggregate and analyse all of the Personal Information about the Participant to enable us to develop targeted marketing programs and service offerings that we consider are tailored to the needs of particular groups of Participants. We may then use the Personal Information about the Participant to contact them regarding programs and services which may be of interest to them.

On completion of Training or our services, we provide a service to notify our participants of ‘other’ courses or ‘services’ that we offer or that they have requested either by phone or via surveys.

The Participant, at any time, can request to opt-out and not receive direct marketing communications by contacting the Customer Service Team either via email or phone, or by selecting the unsubscribe feature.

Disclosure of Personal Information Overseas (APP 1.4f, 1.4g, 8)

Drug and Alcohol Testing Institute does not disclose Personal Information about a Participant to any overseas recipient

Collection and Use of Government Related Identifiers (APP 9)

Drug and Alcohol Testing Institute does not adopt or disclose a Government related identifier relating to a Participant unless it is required by law or is reasonably necessary to fulfil obligations to an agency or a State or Territory authority or as prescribed by regulations. The Unique Student Identifier is such a requirement.

Quality of Personal Information (APP 10)

Drug and Alcohol Testing Institute takes reasonable steps to ensure that the Personal Information collected, used and disclosed is accurate, up to date and complete for the purposes for which we use that data. Drug and Alcohol Testing Institute makes every effort to ensure that Personal Information is up to date and accurate.

Should a Participant seek access to their Personal Information, or wish to change, modify or correct Personal Information, they will be asked to verify their identity via their name, date of birth, and address before this can occur. Under the Privacy Act, Participants have a right to access / and or correct Personal Information that is collected and held by us. Access to Personal Information is available through application to the Customer Service Team of Drug and Alcohol Testing Institute. We do refuse access if it interferes with the privacy rights of other Participants or if it breaches any confidentiality that attaches to that information. Access to Personal Information will be controlled at all times. (APP 10, 13.1).

Any changes of personal information requested by the Participant are recorded in the Learning Management System.

Security of Personal Information(APP 11)

Drug and Alcohol Testing Institute maintain reasonable physical, electronic, and procedural safeguards to protect Personal Information about Participants from loss, misuse and unauthorised access, disclosure, alteration and destruction. As part of those precautions, we seek to protect Personal Information about Participants through technologies designed to safeguard the data during its transmission. However, there is no method of transmitting or storing data that is completely secure. Although their physical characteristics are different, postal mail, telephone calls, faxes and transmissions over the Internet all present possibilities of loss, misrouting, interception and misuse of the data being transmitted. Drug and Alcohol Testing Institute cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Drug and Alcohol Testing Institute receives the participants transmission, it makes every effort to ensure its security on its systems.

Our systems including our Website, our Learning Management System and financial systems are password protected. We restrict access to Personal Information about Participants to those employees who we determine need to know that information, for us to provide Training to the Participant.

Employee misuse of Personal Information about Participants is treated as a serious offence for which disciplinary action may be taken.

Government identifiers, such as your Unique Student Identifier, are not used or disclosed other than required by law. We will never use a government identifier in order to identify you.

If a Participant has reason to believe that any account with us is no longer secure, they must immediately notify us.

In the event that Drug and Alcohol Testing Institute ceases to operate, all RTO records are required to be transferred to our regulator the Australian Skills Quality Authority (ASQA).

Cookies

We use ‘cookies’ to provide a better and more customised service and a more effective website. A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and the Participant can choose if and how a cookie will be accepted by configuring their preferences and options in their internet browser. We use cookies for different purposes such as:

To customise our website for you;
For statistical purposes;
For security purposes.

IP addresses

Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.

Access to Personal Information (APP 12)

It is a requirement that Participants provide an email address at the time of enquiry and enrolment, as course correspondence and communication is disseminated this way.

If a participant chooses not to provide their email address, Drug and Alcohol Testing Institute can arrange to have any pre-requisite material and information sent via mail to the Participants notified postal address. Personal information can be facilitated via a written request or by contacting our Customer Service Team providing identifiable information. We will respond to such a request as quickly as possible.

We do not charge a fee to Participants to enable them to access and edit their Personal Information. (APP 12.8)

We may refuse access to Personal Information by a Participant where; (APP 12.3, 12.9):

providing access would pose a serious and imminent threat to the life or health of the individual;
providing access would have an unreasonable impact on the privacy of other people;
the request is frivolous or vexatious;
the Personal Information relates to existing or anticipated legal proceedings between the Participant and us and the information would not be accessible by the process of discovery in those proceedings;
providing access would disclose our intentions in relation to negotiations with the Participant in such a way as to prejudice those negations;
providing access would be unlawful;
providing access would be likely to prejudice an investigation of possible unlawful activity or of improper or prescribed conduct or similar;
an enforcement body performing a lawful security function asks us not to provide the information;
providing access would reveal evaluative information generated by us in connection with a commercially sensitive decision.

If we refuse the Participant to access or correct Personal Information as requested by the Participant, we will provide the Participant with a written response setting out the reasons for our refusal and the process available to the Participant to complain about the refusal. (APP 12.9, 13.3)

Correction of Personal Information (APP 13)

It is important to us that the personal information we hold about the Participant is accurate and up to date. During the course of our relationship with the Participant we may ask the Participant to inform us if any of their personal information has changed. If the Participant believes that we hold any details about them that are incorrect, the Participant may write to us outlining how and why these details are incorrect. We will generally rely on the Participant to ensure that the information we hold about the Participant is accurate and correct. We will endeavour to update the details as soon as possible after the Participant has provided us with the correct details. Otherwise, we will provide an initial response to the Participant within seven days of receiving your request. Where reasonable, and after our investigation, we will provide the Participant with details about whether we have corrected the personal information within 30 days. We may need to consult with other entities as part of our investigation. If we refuse to correct personal information we will provide the Participant with our reasons for not correcting the information.

We do not charge a fee to Participants requesting to make changes to their Personal Information. (APP 13.4b)

Financial Sensitive Information and Purchases

When Participants enter Sensitive Information, such as a Credit Card number, on our website, we encrypt that information using secure socket layer technology (SSL. When Credit Card details are collected, we forward them onto the processing body as required). We never permanently store completed Credit Card details. Drug and Alcohol Testing Institute follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it.

If a Participant has purchased a product or service from Drug and Alcohol Testing Institute, we may request certain Personal Information which is identifiable to Participants. Participants may be required to provide Personal Information and Financial Information (such as Credit Card number, expiration date). We use this information for billing purposes and to complete the purchase. Should Drug and Alcohol Testing Institute have trouble in processing a purchase, we will use the information provided to contact the Participant.

Our Website and Links

This Privacy Policy applies to any website operated by Drug Testing Institute Pty Ltd as trustee for Drug Testing Institute Trust trading as Drug and Alcohol Testing Institute. Links on Drug and Alcohol Testing Institute site to external entities or third parties are not covered within this policy. The terms and conditions set out in this Privacy Policy only cover the domain name of Drug and Alcohol Testing Institute. Third parties are responsible for informing their own privacy policies.

Privacy Concerns and Complaints (APP 1.2b, 1.4e)

Participants may make a complaint about the handling or misuse of their Personal Information, including if the Participant feels we have breached the Privacy Act 1988, by contacting us in writing, via mail or email. The Participants complaint will be acknowledged and resolved in the timeframe provided under theComplaints and Appeals Policy.

For any concerns or queries about Participant’s Personal Information or our Privacy Policy the contact details are as follows:

Please contact us by clicking Here