Policy Statement

The purpose of this Policy is to ensure that in the course of Immanuel Primary’s School’s activities, we manage and protect personal information in accordance with the Privacy Act 1988 (Cth)(Privacy Act) and the 13 Australian Privacy Principles (APPs).

Scope of policy

This policy outlines the circumstances in which we obtain personal information, how we use and disclose that information and how we manage requests to access and/or change that information.

Policy Detail

What is personal information and how do we collect it?

Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as a student, contractor, volunteer, stakeholder, job applicant, alumni, visitors or others that come into contact with the school.

In the course of providing services we may collect and hold:

As part of our recruitment processes for employees, contractors and volunteers, we may collect and hold:

Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).

It is noted that employee records are not covered by the APPs where they relate to current or former employment relations between the school and the employee.

Collection of personal information

The collection of personal information depends on the circumstances in which Immanuel Primary School is collecting it. If it is reasonable and practical to do so, we collect personal information directly from the individual.

Solicited Information

Immanuel Primary School has, where possible, attempted to standardise the collection of personal information by using specifically designed forms (e.g. an Enrolment Agreement Form).  However, given the nature of our operations we also receive personal information by email, letters, notes, via our website, over the telephone, in face-to-face meetings, through financial transactions and through surveillance activities such as the use of CCTV security cameras or email monitoring.

We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources. However, we will only do so where it is not reasonable and practical to collect the personal information from the individual directly.

We may collect information based on how individuals use our website. We may use ‘’cookies’’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic.  We do not use this information to personally identify individuals.

Unsolicited information

Immanuel Primary School may be provided with personal information without having sought it through our normal means of collection.  This is known as “unsolicited information” and is often collected by:

Unsolicited information obtained by Immanuel  will only be held, used and or disclosed if it is considered as personal information that could have been collected by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the personal information as appropriate.

Collection and use of sensitive information 

We only collect sensitive information if it is:

We may share sensitive information to other entities in our organisation structure, but only if necessary for us to provide our products or services.

How do we use personal information?

Immanuel Primary School only uses personal information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented.

Our primary uses of personal information include, but are not limited to:

We will only use or disclose sensitive or health information for a secondary purpose if you would reasonably expect us to use or disclose the information and the secondary purpose is directly related to the primary purpose.

We may share personal information to related bodies corporate, but only if necessary for us to provide our services.  The school may disclose information about an individual to overseas recipients only when it is necessary, for example to facilitate a student exchange program. The school will not however send information about an individual outside of Australia without their consent.

Storage and Security of Personal Information

Immanuel Primary School stores Personal Information in a variety of formats including, but not limited to:

Immanuel Primary School takes all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

These steps include, but are not limited to:

Our public website may contain links to other third-party websites outside of Immanuel Primary School. Immanuel Primary School is not responsible for the information stored, accessed, used or disclosed on such websites and we cannot comment on their privacy policies.

Responding to data breaches

Immanuel Primary School will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.

Disclosure of personal information

Personal information is used for the purposes for which it was given to Immanuel Primary School, or for purposes which are directly related to one or more of our functions or activities.

Personal information may be disclosed to government agencies, other parents, other schools, recipients of school publications, visiting teachers, counsellors and coaches, our services providers, agents, contractors, business partners, related entities and other recipients from time to time, if the individual:

Immanuel Primary School may disclose personal information without consent or in a manner which an individual would reasonably expect if:

Disclosure of your personal information to overseas recipients

Personal information about an individual may be disclosed to an overseas organisation in the course of providing our services, for example when storing information with a “cloud service provider” which stores data outside of Australia

We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

Personal information of students

The Privacy Act does not differentiate between adults and children and does not specify an age after which individuals can make their own decisions with respect to their personal information.

At Immanuel Primary School we take a common sense approach to dealing with a student’s personal information and generally will refer any requests for personal information to a student’s parents/carers.  We will treat notices provided to parents/carers as notices provided to students and we will treat consents provided by parents/carers as consents provided by a student.

There may also be occasions where parents/carers are denied access to information with respect to their children, because to provide such information would have an unreasonable impact on the privacy of others, or result in a breach of the school’s duty of care to the student.

The quality of personal information

We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.

If Immanuel Primary School becomes aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information. 

Access and correction of personal information

You may submit a request to us to access the personal information we hold, or request that we change the personal information. Upon receiving such a request, we will take steps to verify your identity before granting access or correcting the information.

If we reject the request, you will be notified accordingly. Where appropriate, we will provide the reason/s for our decision. If the rejection relates to a request to change personal information, an individual may make a statement about the requested change and we will attach this to their record.


You can make a complaint about how Immanuel Primary School manages personal information, including a breach of the APPs, by notifying us in writing as soon as possible.  We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we make seek further information in order to provide a full and complete response. Immanuel Primary School does not charge a fee for the handling of complaints. If the individual is not satisfied with our response, they may refer the complaint to the OAIC.  A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.

How to contact us

Immanuel Primary School can be contacted about this Privacy Policy or about personal information generally, by:

If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so.

This Privacy Policy was last reviewed: 30 May, 2020

General Information Collection Notice: Students

This Collection Notice explains in general terms how we protect the privacy of the personal information you provide when you are enrolling your child or your child is enrolled at Immanuel Primary School. In reviewing this Collection Notice and providing us with your personal information, you consent to our collection, use and disclosure of that information in the manner set out below, unless you tell us otherwise.

  1. The School collects personal information, including sensitive information about students and parents or guardians and family members before and during the course of a student’s enrolment at the School. This may be in writing or in the course of conversations. The primary purpose of collecting this information is to enable the School to meet its educational, administrative and duty of care responsibilities to the student to enable them to take part in all the activities of the School.
  2. Some of the information the School collects is to satisfy the School’s legal obligations, particularly to enable the School to discharge its duty of care.
  3. Laws governing or relating to the operation of a School require certain information to be collected and disclosed. These include relevant Education Acts and Public Health and Child Protection laws.
  4. The School may request medical reports and health information about students from time to time to discharge its legal duty of care to the student and to other students and staff. This includes a student’s asthma and anaphylaxis action plans, as well as any other health or medical information which is reasonably likely to impact on the School’s ability to provide educational, first aid and related services
  5. A student’s health and medical information will be disseminated and used within the School to best meet the School’s duty of care responsibilities. This may include the use of photographs with health action plans to facilitate the identification of students who may be at heightened risk.Health information about students is sensitive information within the terms of the Australian Privacy Principles (APPs) under the Privacy Act 1988.
  1. The School may disclose personal and sensitive information for administrative, educational and support purposes (or may permit the information to be directly collected by third parties). This may include to:
  1. If this information is not provided to us, the School:
    1. views this as an unacceptable risk and may not proceed with the enrolment and
    2. may not be able to fully discharge its duty of care to its students and staff.
  2. The School will engage in fundraising activities from time to time. Information received from you may be used for these purposes. It may also be disclosed to the School’s Parent & Friends Association who assist in the fundraising activities of the School. We will not disclose your personal information to third parties for their own marketing purposes without your consent.
  3. The School may also use cloud computing service providers to store personal information (which may include sensitive information) on their servers in the ‘cloud’. These servers may be located in or outside Australia. This may mean that personal information may be stored or processed outside Australia. The School’s Privacy Policy contains further information about its use of cloud and other third-party service providers and any of their overseas locations.
  4. The School’s Privacy Policy is accessible via the School website or from the School office. The policy sets out how parents, guardians or students may seek access to, and correction of their personal information which the School has collected and holds. However, access may be refused in certain circumstances such as where access would have an unreasonable impact on the privacy of others, or may result in a breach of the School’s duty of care to the student, or where students have provided information in confidence. Any refusal will be notified in writing with reasons if appropriate.
  5. The School’s Privacy Policy also sets out how parents, guardians, students and their family can make a complaint about a breach of the APPs and how the complaint will be handled.
  6. On occasions information such as academic and sporting achievements, student activities and similar news is published in School newsletters and magazines, on physical displays throughout the School and on our intranet. This may include photographs and videos of student activities such as sporting events, School camps and School excursions.The School will obtain separate permissions from the student’s parent or guardian (and from the student if appropriate) prior to including such photographs or videos or other identifying material in our promotional material or otherwise making this material available to the public, such as on the internet.The School will obtain separate permissions from the student’s parent or guardian prior to including personal information on class lists or School directories.
  7. If you provide the School with the personal information of others, such as other family members, doctors or emergency contacts, we encourage you to inform them that you are disclosing that information to the School and why, that they can request access to and correction of that information if they wish and to also refer them to the School’s Privacy Policy for further details about such requests and how the School otherwise handles personal information it collects and complaints it receives.

This General Information Collection Notice: Students was last reviewed 30 May 2020.