Early Learning Association Australia (ELAA, we, our) respects your right to the privacy of your personal information. This policy outlines how we handle your personal information in our organisation and on our website, including the types of personal information we collect, the purposes of its use and/or disclosure and how it is handled.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and the Information Privacy Principles (IPPs) under the Victorian Privacy and Data Protection Act 2014 (PDP Act). The APPs and IPPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information. ELAA is also subject to the Health Privacy Principles (HPPs) under the Health Records Act 2001 (Vic) (HR Act) in respect of health information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner. A copy of the Information Privacy Principles may be obtained from the Office of the Victorian Information Commissioner.
Collection of your personal information
What we collect
Personal Information is information or an opinion about an individual who is reasonably identifiable. The information can be a written record, or video, audio, verbal or photographic material.
Examples of Personal Information we collect are: names, addresses, email addresses and phone numbers.
Examples of Personal Information we collect via our website include names, billing addresses, payment information (including credit card numbers), email addresses and phone numbers, and job position or title.
Examples of Sensitive Information we collect include: vaccination status.
How we collect
This Personal Information is obtained in many ways including correspondence by telephone, email (professional support), online forms, professional learning, event registrations, subscribing to receive electronic publications and downloading resources via our website www.elaa.org.au.
Sensitive information is collected directly from the individual, including via email or in person.
Why we collect
We collect your Personal Information for the primary purpose of providing our services to you, offering products/resources for sale, online training, fulfilling of your order, and keeping you up to date on new products, services, and offers. Our primary services are collaboratively deliver solutions with members, governments and partners to ensure excellence and equity in early childhood education and care. We advocate to all levels of Government, as well as member advisory, product and partner offerings.
We collect Sensitive Information from ELAA employees, board members and contractors for the purpose of preventing or managing COVID-19. Vaccination status is provided freely and with consent from the individual.
When we collect
When we collect Personal and Sensitive Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. Any other type of use and disclosure will require your consent or be in accordance with prescribed exemptions under privacy laws.
Anonymity
It is impracticable for ELAA to deal with individuals do not want to identify themselves because we need to know we are dealing with the correct people within our member organisations and other organisations we deal with.
Where practicable, such as in surveys, ELAA may provide individuals the opportunity to not identify themselves.
Candidates for employment are required to provide accurate and up to date personal information. ELAA cannot consider applications for employment on an anonymous basis.
Use and Disclosure of personal information
The main purpose for which ELAA uses your Personal Information is providing services to our members. Other purposes we use Personal Information for include:
- to conduct our organisational objectives;
- to provide advisory services and supports to you directly: we use your Personal Information to tailor our services based on your needs;
- to provide information or market our services that may be of interest to you;
- to communicate with you and manage our relationship with you; and
- to communicate with sponsors and organisations about our members.
We may occasionally hire other companies to provide services on our behalf, including but not limited to consultancies, IT support, Customer Record Management systems. We will only disclose to these companies the Personal Information they need to deliver the service. ELAA takes reasonable steps to ensure these companies are bound by confidentiality and privacy obligations in relation to the security and protection of your Personal Information.
ELAA discloses Personal Information for the purposes for which it was collected and related purposes. Related purposes for which we disclose Personal Information include:
- Third parties who assist us with delivery of our services or the operation of our business (such as preferred partner consultants, sub-contractors, lawyers and barristers, auditors, accountants) and are bound by our Privacy Policy and equivalent privacy laws;
- Preferred partner and sponsors;
- Government organisations or in compliance with our funding obligations;
- Courts, tribunals and regulatory authorities (such as DET, Fair Work);
- Other third parties where you consent to the use or disclosure; and
- Where required or authorised by law.
We don’t not rent, share or trade Personal Information.
Cross boarder disclosure
ELAA does not disclose your Personal Information to recipients located outside Australia, unless:
- we have your consent; and
- the disclosure complies with the APPs.
ELAA is not responsible for the cyber security of our suppliers and providers however we ensure that we only engage with suppliers and providers that can demonstrate they meet basic cyber security benchmarks in accordance with our own policies. In the case of any breach that may affect your information, we will attempt to inform you as soon as we become aware of it.
Security of Personal Information
We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your data and protect your Personal and Sensitive Information from misuse, loss, unauthorised access, modification or disclosure.
Security measures
- Physical safeguards include:
- locking filing cabinets and unattended storage areas;
- physically securing the areas in which the Personal Information is stored;
- not storing Personal Information in public areas; and
- positioning computer terminals and fax machines so that they cannot be seen or accessed by unauthorised people or members of the public.
- Technical safeguards include:
- using passwords to restrict computer access, and requiring regular changes to passwords;
- establishing different access levels so that not all staff can view all information;
- ensuring information is transferred securely where possible or where not possible ensuring that appropriate safeguard measures have been taken; and
- installing virus protections and firewalls.
Storage and retention
ELAA stores its electronic data on servers that are either owned or leased by ELAA in Melbourne, Victoria. ELAA rents space for our servers from a dedicated hosting service provider that is compliant with ISO 27001 standards of security.
ELAA will only retain Personal Information for as long as necessary to fulfil the purposes we collected it for, and for the purposes of satisfying any legal, accounting, or reporting requirements. When your Personal Information is no longer needed for the purpose for which it was obtained, we take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information held by ELAA is, or will be, stored in client files that we keep for a minimum of 7 years.
Credit card and online security
ELAA does not keep or record credit card numbers via its website e-commerce system. Those details are routed direct via a secure link to our e-commerce payments gateway and, through them, to your financial institution. When credit cards numbers are entered on ELAA’s registration or membership forms, that information is encrypted using secure socket layering (SSL). ELAA observes commonly accepted industry standards to protect the Personal Information submitted, both during transmission and once it is received. While we take reasonable and appropriate measures to protect data that you submit directly to us, remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and we cannot promise, and you should not expect, that we will be able to protect your information at all times and in all circumstances.
Cookies
We use cookies to enhance the online experience for our members on our Site. A cookie is a small amount of information that is downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance, whether it’s their first time visiting or if they are a frequent visitor.
If you would prefer not to receive cookies, you can alter your security settings on your web browser to disable cookies or to warn you when cookies are being used.
Member Login
ELAA does not store passwords information for the ELAA website. It is the members’ responsibility to protect their password and login information.
Analytics
We may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. Reports generated by Google Analytics help us understand website traffic and webpage usage. By using our website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work
You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/
Accessing your Personal Information
You have a right to access your Personal Information. You may request to access the Personal Information we hold about you and ask us to correct it. If you wish to access your Personal Information, please contact us in writing using the contact details provided at the end of this policy.
ELAA will not charge any fee for your access request but may charge an administrative fee for providing you a copy of your Personal Information. In order to protect your Personal Information, we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We take reasonable steps to make sure your Personal Information is accurate, complete and up-to-date. One way we do this is by requesting members complete a renewal form annually which updates the contact information of people in a member organisation. We then update your Personal Information in our Customer Relationship Management platform.
If you find the information we have about you is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Policy Updates
ELAA may amend this Privacy Policy at any time.
Privacy Policy Complaints and Enquiries
ELAA welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday. You may also make a complaint about how handling of your Personal Information by using the contact details below. Complaints about how we handle your Personal Information must be made to ELAA in the first instance. If you are not happy with how we resolve your complaint, you may make a complaint to the Office of the Australian Information Commissioner.
Early Learning Association of Australia