BKI Privacy Policy
BKI is committed to protecting and managing personal and health information fairly and lawfully in accordance with the Privacy and Data Protection Act 2014 (Vic), the Health Records Act 2001 (Vic), and to the extent they apply to our activities, the requirements of the Privacy Act 1988 (Cth).
This Privacy Policy applies to the Bendigo Kangan Institute including Bendigo TAFE, Kangan Institute, VETASSESS and eWorks
Information Privacy Principles
BKI complies with the Information Privacy Principles as set out in the Privacy and Data Protect Act 2014 (Vic) and the Health Privacy Principles as set out in Health Records Act 20001 (Vic). We observe the ten principles outlined below:
Information Privacy Principle 1 – Collection
BKI Students
If you are student with BKI, or applying to study with BKI, we will collect information including:
- your name.
- your mailing or street address.
- your email address, telephone number and other contact details.
- your age or date of birth.
- details of your previous education and qualifications.
- records of fee payments, financial aid, and scholarships information.
- your citizenship and/or visa status.
- information about your academic progress and standing, assessments, results and details of practical placements and other workplace training (if applicable).
- any assigned student numbers (unique identifiers).
- your Tax File Number and financial institution information for the purpose of fees, refunds, and financial support programs (if applicable).
- details of any disciplinary or conduct matters.
- your health information, where you disclose it to us and it is relevant to your study with BKI.
- other information relevant to your enrolment and education to facilitate appropriate academic and student services; and
- copies of identity documents (other than ‘citizenship and/or visa status’)
As a training services provider, BKI may be required by the Victorian State Government to collect personal information, including sensitive information relating to students on behalf of the State Government. In such cases, the collection of information will be identified as being for the purposes of the State Government and BKI will collect that information as agent of the State Government. BKI will not retain or use such information for its own purposes.
Collecting personal information for our student counselling service or other support services
We make a counselling service available to our students. If you receive counselling services from us, we may collect additional personal information about you, including health information about you, as part of providing this service. Health information includes any information or an opinion about an individual's physical, mental, or psychological health, any disability that an individual has and any details of any health or medical services provided to an individual.
We will only collect health information about you with your consent.
When you access any of our special category student support services, further information on the types of information we may collect, and our use and management of that information will be explained in the relevant privacy collection notices specific to those services.
Health and personal information about you collected for these services will only be used for the purpose of providing the services to you. Any counselling service that we provide is confidential and any information that you provide to us will be held in the strictest confidence. Any health information that we collect about you will be separately stored by our counsellors and will not form part of your student records.
VETASSESS Applicants
We will only collect personal information or health information that is relevant for our functions and activities which includes:
- Provision of skills assessment including assessment of qualifications and employment for migration to Australia
- Provision of skills assessment including assessment of qualifications and employment for non-migration purposes such as, seeking professional registration, employment, or stand-alone recognition of your skills
- Provision and/or administration of tests for assessment of your skills and/or knowledge
- Verification of the identity of applicants for skills assessment
- Improvement of the quality of our services
- Research and analysis relating to the quality of our services, the demand for our services and the expectations of our customers
We may also collect personal information or health information from an agent acting on your behalf and from third parties such as the:
- Australian Government Department of Employment and Workplace Relations (DEWR)
- Australian Government Department of Home Affairs (DHA)
- Australian Taxation Office (ATO)
- Australian government agencies, including Police and Defence Forces
- Overseas service providers, employers, and referees
Working at BKI
If you are an employee of BKI, or applying to work at BKI, we will collect information including:
- your name.
- your personal and emergency contact details.
- your date of birth.
- your gender.
- your referee details.
- your Tax File Number and bank account details.
- your citizenship, passport and/or visa details.
- your superannuation information.
- your health and disability details.
- your previous employment details.
- your qualifications.
- details of your paid outside work and directorships; and
- other information relevant to your employment and work-related matters.
If you are injured or become ill in the course of your employment or engagement as a contractor, we may also collect additional relevant information. This may include health information about your injury or illness, details of any Workcover claim that you make, your return-to-work plan and any other health-related declarations, statements, or assessments.
If you opt to provide it to us, we also collect information about your race/ethnicity, and sexual orientation/gender identity. This information is only used in aggregated reporting to help BKI provide the appropriate support services for its employees.
Other collections of personal information
If you register for events, campus tours, newsletters or are a supporter of, or a volunteer at BKI, we will hold the personal information provided by you during your interactions with us. You may also provide us with your personal information when you agree to participate in user experience research or provide other feedback. This is explained in the relevant privacy collection notices specific to those activities.
Where you provide BKI with the personal information of others (such as details of your emergency contacts) you are encouraged to inform those parties whose information you provide that:
- you are disclosing that information to BKI; and
- the information will be retained in accordance with this Policy.
Our websites may contain links to other websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
How does BKI collect personal information?
We will generally collect this information directly from you but may also collect personal information about you from professional associations, training providers, medical practitioners, or government agencies if you consent or if we are permitted to by law. We collect emergency contact details from students and employees. We may also collect information and metadata about you from your use of our IT systems.
What happens if I do not provide my personal information to BKI?
BKI students
If you do not provide us with your personal information, we may be unable to enrol you into a course, provide you with services, manage your application for employment, or otherwise respond to your request.
So far as is reasonably possible, BKI is happy to deal with you anonymously or under a pseudonym if you prefer. We are happy to provide information about our services without requiring you to provide contact details.
If you do deal with us under a pseudonym, we would prefer to know, so we avoid collecting inaccurate information. Similarly, if you have provided us with your contact details, and those details subsequently change, please contact us at information@bendigokangan.edu.au so we can ensure our records are accurate.
VETASSESS Applicants
If you fail to provide requested information, we may not be able to process your application.
Information Privacy Principle 2 – Use and Disclosure
BKI Students
If you are a student with BKI, or applying to study with BKI, we will use the personal information which we collect from you to:
- assess your application.
- verify your identity.
- communicate with you.
- provide you with services.
- report to Commonwealth and State Government as required by law; and
- after you graduate, maintain alumni relationships, maintaining and facilitating alumni networks, and promote BKI activities to alumni.
BKI may disclose your personal information to:
- contractors we engage to provide you with services on your behalf.
- Commonwealth and State Government.
- employers and other training providers, where you study a course which BKI delivers in collaboration with an employer to another training provider; or
- emergency services, healthcare providers, or your nominated emergency contact, in case of an emergency.
VETASSESS applicants
We may disclose your personal information or health information to the following third parties:
- Government agencies
- Department of Industry and Science,
- Department of Home Affairs
- Australian Taxation Office
- Domestic and overseas service providers
- Employers for verification of identity/data purposes
The information we collect about you may also be disclosed to third parties engaged in relevant research into matters such as migration patterns and skill levels. We may also disclose information to third parties to act on our behalf, including:
- Information technology suppliers
- Marketing and advertising agencies
- Mailing and logistics providers
- Professional advisors
Where we are requested to provide information to a third party we will:
- written confirmation of their intention to observe this requirement
- Require the recipient to store that information securely, not disclose it to any other person and return or destroy it when it is no longer required
- Require that the recipient update or delete any part of the information disclosed where we have agreed to update or delete our corresponding records
Sharing personal information with your nominated adult
If you are younger than 18 years of age, BKI shares your information with your nominated adult, such as parent or guardian. BKI will continue to share this information, for the duration of your enrolment, with your nominated adult after you turn 18, unless you specifically contact us to request a change to this arrangement or enrol in a different course after you turn 18.
Sharing personal information with the Victorian Government
The Victorian Government, through the Department of Education and Training (the Department), develops, monitors and funds vocational education and training (VET) in Victoria. BKI is required to provide the Department with student and training activity data. This includes personal information collected by BKI through enrolment and unique identifiers such as the Victorian Student Number (VSN) and the Commonwealth’s Unique Student Identifier (USI).
BKI provides data to the Department in accordance with the Victorian VET Student Statistical Collection Guidelines, available at https://www.education.vic.gov.au/training/providers/rto/Pages/datacollection.aspx.
Sharing personal information with other regulators
BKI may be required or permitted by law to disclose personal information with other regulators including:
- Commonwealth Government agencies and regulators located outside of Victoria pursuant to Funding Agreements in place between BKI and these agencies and regulators or specific legislation requiring BKI to disclose personal information with these agencies and regulators; and
- Agencies and organisations involved in quality assurance and planning for education such as the Australian Skills Quality Authority (ASQA), the Victorian Registration and Qualifications Authority (VRQA), the Tertiary Education Quality and Standards Agency (TEQSA), and the; National Centre for Vocational Education Research (NCVER), Department of Education and Training Victoria.
Sharing personal information with other third parties
We may also engage third parties to act on our behalf. For example, we may engage information technology suppliers, marketing and advertising agencies, mailing and logistics providers and professional advisors. When we do so, we take steps to ensure any contract governing these arrangements pass on obligations to third party organisations to require that they adopt the same Privacy Principles BKI does.
External training agencies
Some of the services we provide include the delivery of educational services to employers and/or in collaboration with other training organisations. Under these circumstances, we are frequently provided with personal information which has been collected by an employer or external training provider. In all situations where we obtain personal information from a third party, we are careful to confirm that the:
- information is accurate and was acquired in accordance with the Privacy and Data Protection Act 2014 (Vic).
- third party, is permitted to provide the information to us, and
- third party is authorised to use the information for the purposes for which they are supplying it.
As part of your course, you may be required to undertake work integrated learning such as practical placements or voluntary workplace activities. In those instances, we may be required to share your personal information with host organisations and/or their agents or representatives to enable you to participate in the placement program.
If you participate in an exchange program, dual enrolment, or similar arrangement with one of our international partners we may be required to share your personal information to the relevant partnering educational institution.
If you are an international student, we may disclose personal information about you to third parties located outside of Victoria in some circumstances. This may include:
- where we are required to disclose certain information about international students to the Commonwealth Government's Department of Home Affairs via Provider Registration and International Students Management System (PRISMS).
- if applicable, disclosing information about you to the recruitment agent in your home country (unless you request that we do not disclose such information).
- disclosing information about you to other third parties in your home country for marketing purposes, such as promoting our educational services in your home country.
- with your consent, disclosing information about you to AusTrade in relation to any scholarships you may be receiving; or
- where we have a partnership with an educational institute in another country that delivers our qualifications at which you have a dual enrolment or at which you are participating in an exchange program, we may disclose information to that overseas educational institution (including your results).
Before BKI discloses personal information about you to a third party, including any third party, BKI will take steps that are reasonable in the circumstances to ensure that the recipient:
- complies with its obligations under relevant privacy laws and only uses and processes the personal information for permitted purposes; and
- does not transfer personal information outside of Australia without BKI’s consent and unless the overseas recipient provides an undertaking that the personal information will be protected at a standard comparable to Australian privacy laws; and
- has in place appropriate security arrangement to prevent unauthorised access.
Working at BKI
We will use and/or disclose your personal information to manage processes associated with your employment relationship with us, including for:
- recruitment, selection, and appointment functions.
- verifying details for your employment including work rights and relevant qualifications,
- licenses or permits, health and background checks.
- payroll processing.
- superannuation administration.
- insurance purposes and the management of work-related travel.
- contacting or locating you or notifying the relevant authority or your emergency.
- contacting your nominated emergency contact, an emergency service or a government authority if there are reasonable grounds to be concerned about your welfare or safety.
- risk management, workplace health and safety and workers compensation matters.
- managing and investigating performance, conduct, and disciplinary matters.
- employees’ training and development.
- benchmarking, reporting, analysis, quality assurance and planning purposes.;
- employees’ appraisals, probation, and promotion.
- informing you about BKI news and events, activities, courses, and opportunities that may be of interest to you as an employee of BKI.
- compliance, where we are legally required to provide information to the Australian Taxation Office, the Department of Education and Training and Victorian Government Department of Treasury and Finance or other Victorian Government agencies; and
- additional specific services that are related to your employment. For example, for recruitment and travel management, BKI engages external service providers who will have access to your personal information. The providers performing these services are bound by BKI’s privacy and security requirements.
In addition, aggregated data about employees, with personal identifiers removed, is routinely provided to the Australian Bureau of Statistics, the Workplace Gender Equity Agency, Australian Higher Education Industry Association and various local and international education institutions ranking bodies.
Information provided by job applicants is used solely for the recruitment function. It is disclosed only to employees and/or relevant panel members involved in the selection process and is treated confidentially. This information is only retained for as long as it is required for the purpose it was collected and is then securely destroyed in accordance with our legislative obligations and our retention and disposal of records policies.
VETASESS applicants
We may disclose your personal information or health information to the following third parties:
- Government agencies
- Department of Industry and Science,
- Department of Home Affairs
- Australian Taxation Office
- Domestic and overseas service providers Employers for verification of identity/data purposes
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The information we collect about you may also be disclosed to third parties engaged in relevant research into matters such as migration patterns and skill levels.
We may also disclose information to third parties to act on our behalf, including:
- Information technology suppliers
- Marketing and advertising agencies
- Mailing and logistics providers
- Professional advisors
Where we are requested to provide information to a third party we will:
- Provide that information in an aggregated and/or de-identified format if reasonably practicable
- Inform them of their obligation to observe Australian Privacy Principles and request written confirmation of their intention to observe this requirement
- Require the recipient to store that information securely, not disclose it to any other person and return or destroy it when it is no longer required
- Require that the recipient update or delete any part of the information disclosed where we have agreed to update or delete our corresponding records
If a third party is collecting information for research purposes and proposes to publish or otherwise share the outcome of their research, we will require that neither the published or shared report nor any supporting information made available by VETASSESS contains any personally identifiable information. In addition, if the research includes de-identified data, we will require that it be sufficiently aggregated or otherwise presented such that it cannot be re- identified.
Information Privacy Principle 3 – Data Quality
We will take all reasonable steps to ensure the personal information or health information that is collected, used, or disclosed is complete, accurate and current.
If you wish to access or update your personal information or health information, we will provide all reasonable assistance to do so. Any request to update or correct the information we hold should be addressed to information@bendigokangan.edu.au
Information Privacy Principle 4 – Data Security
Personal information is created, stored, and transmitted in a variety of paper and electronic formats. We take all reasonable steps to ensure your information is protected from:
- Misuse
- Unauthorised access
- Modification or disclosure
We take reasonable steps to ensure that any personal information we (or third parties operating on our behalf) collect, transmit, store or otherwise process, is accurate and complete, and that appropriate measures are implemented and maintained to protect it from accidental or unlawful destruction, misuse, loss, alteration, or unauthorised access or disclosure.
In addition, we require third parties who hold or store your personal information on our behalf to comply with strict privacy obligations under our contracts with these third parties.
While we make all attempts to secure the personal information you may provide us, there is a possibility that it may be accessed. In the event of unauthorised access, or disclosure, of information that would be likely to result in serious harm to any of the individuals to whom the information relates, the affected individual will be notified, as is required by Section 26WL of the Privacy Act 1988.
All information not required will be destroyed in accordance with either:
- Privacy legislation or as required by other legislation
- Public Records Office Victoria recordkeeping Standards requirements
Using our websites and cookies
We may collect personal information about you when you use and access our websites.
We may record certain information about your use of our websites, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer. We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone, or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.
We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information. In some cases, our websites may use a customer relationship management system or plug-in software that allows us to identify you. We will handle any personal information collected by cookies or our other software in the same way that we handle all other personal information.
We may also use cookies for digital marketing purposes (whether those cookies contain personal information).
Our websites may contain links to other websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Information Privacy Principle 5 – Openness
We will take all reasonable steps to provide you with details of your personal information or health information being held by us upon request including placing this privacy statement on our website.
Information Privacy Principle 6 – Access and Correction
Contacting BKI
If you want to:
- Ask a question about how we collect, hold, use or disclose your personal information.
- Find out what personal information we hold about you.
- Update personal information which is not correct; or
- Make a complaint about how we have handled your personal information you can contact us at information@bendigokangan.edu.au
There may be circumstances where access to information cannot be granted as it may compromise the privacy of another individual. In those instances, BKI may require requests for access to be sought through the Freedom of Information Act 1982 (Vic).
Please include your name, email address and/or telephone number and clearly describe your request or complaint. We will acknowledge your request or complaint and respond to you within a reasonable period. If you think that we have failed to resolve the request or complaint satisfactorily, we will provide you with information about the further steps that you can take.
Information Privacy Principle 7 – Unique Identifiers
Sometimes BKI are required to collect unique identifiers to conduct our functions. If we do need this information the purposes for collection these numbers will be explained to you. Such information may include:
- Centrelink numbers
- Tax File Numbers
- Medicare Card Numbers
For VETASSESS we also may collect unique identifiers issued by foreign governments, such as:
- National Insurance numbers
- Social Security numbers
- Passport numbers
- ID card numbers
- Drivers licence numbers
- Student numbers
- Health insurance numbers
We will not use these unique identifiers for any other purposes than those for which they were collected.
If we ascribe a unique identifier to you for internal use, this will only be used for managing our dealings with you and monitoring the progress of your application or assessment. It will not otherwise be shared with any other body or person without your consent.
Information Privacy Principle 8 – Anonymity
You have the option of not identifying yourself when entering transactions with us wherever it is lawful and practicable.
Information Privacy Principle 9 – Transborder Data Flows
BKI may disclose personal information to regulators and Commonwealth department and agencies who are located outside of Victoria as outlined above. Some of our service providers are located outside of Victoria and/or Australia and, as a result, personal information collected and held by BKI may be transferred outside of Victoria or outside Australia.
Some BKI IT systems may use cloud computing services and are hosted in countries other than Australia. Depending on the service accessed this could include selected countries in the Americas, Europe, or Asia-Pacific region. Similarly, contracted service providers including third party software and technology platform providers which BKI may use to perform services on its behalf (such as course administration, identification verification services, credential verification services) or enables a student to access or use as part of their study may be based outside of Victoria or outside of Australia. To enable students to access these services BKI may be required to share student personal information to set up user accounts in accordance with the third-party provider’s end-user access requirements.
We take reasonable steps to ensure that any recipient located outside of Victoria will deal with such personal information in a way that is consistent with our privacy obligations, including, where appropriate, by entering contracts with these third parties that require these third parties to only use your personal information for specific purposes and to use appropriate security measures to protect the privacy of your personal information.
Information Privacy Principle 10 – Sensitive Information
We collect sensitive information about an individual only with the consent of the person or if required or permitted by law. ‘Sensitive information’ is information or an opinion about an individual's:
- Racial or ethnic origin
- Political opinions
- Membership of a political association
- Religious belief or affiliations
- Sexual orientation
- Criminal record
- Membership of a trade union
- Membership of a professional or trade association
AI, Website Usage and Cookies
Artificial Intelligence
We may use Artificial Intelligence (AI) technologies to support educational delivery, administrative efficiency and student engagement. These technologies may include tools such as chatbots, learning analytics platforms and generative AI.
Where AI systems collect, generate or infer personal information, we treat this information in accordance with the Privacy Act (1988) (Cth) and the Privacy and Data Protection Act 2014 (Vic). This includes ensuring that:
- Personal information is only collected, used, or disclosed where it is reasonably necessary for our functions or activities.
- Any AI-generated or inferred personal information is handled as personal information under applicable privacy laws.
- We do not input personal information into publicly available AI tools unless appropriate safeguards and consents are in place.
- Individuals are notified when AI tools are used in a way that may affect them, including where automated decision-making is involved.
- Human oversight is maintained over AI-assisted decisions that may have a significant impact on individuals, and.
- We conduct Privacy Impact Assessments (PIA’s) for high-risk AI implementations
We are committed to transparency and will update this policy as our use of AI evolves. If you have any questions about how we use AI or how your personal information is handled, please contact us at information@bendigokangan.edu.au
Use of website cookies
We may record certain information about your use of our websites, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer. We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone, or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.
We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information. In some cases, our websites may use a customer relationship management system or plug-in software that allows us to identify you. We will handle any personal information collected by cookies or our other software in the same way that we handle all other personal information in accordance with this Privacy and Freedom of Information Policy.
We may also use cookies for digital marketing purposes (whether those cookies contain personal information).
Freedom of Information Act 1982 (Vic)
You also have the right to request access to your information by making a Freedom of Information application as specified in the Freedom of Information Act 1982 (Vic). Our provision of access to your information outlined in this statement is in addition to any rights of access you may have under the Act.
How to contact us or make a complaint
If you feel that we have breached your privacy, or if you wish to make a complaint about the way we have handled your personal information, you can contact us on 03 5483 1319 or at information@bendigokangan.edu.au.
Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps that you can take.
How to make a complaint about how we have handled your personal information
BKI
We aim to act reasonably in resolving all complaints, but if you are dissatisfied with our response, you may wish to address your complaint to:
Office of the Victorian Information Commissioner (OVIC)
Website: www.ovic.vic.gov.au
Email: enquiries@ovic.vic.gov.au
Tel: Local calls 1300 006 842 (Monday – Friday 10am – 3pm)
International callers +61 3 8662 3400
VETASSESS applicants
If you are dissatisfied with our response to your request, you may wish to address your complaint to either:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Email: enquiries@oaic.gov.au
OR
Commissioner for Privacy and Data Protection
Email: privacy@cpdp.vic.gov.au
