We collect and hold information about:

• prospective and current apprentices
• employers of apprentices
• apprentice’s parents, guardians and care providers (as relevant to the apprentices age and circumstances)
• representatives of registered training organisations delivering training to apprentices
• contractors and third-party providers
• members of the public we are interacting with.

We collect your personal information directly from you when you:

• interact with us over the phone or in person
• interact with us online, including completing our contact us and feedback forms on our website
• attend an event we are hosting
• complete the signup process
• engage with us for mentoring and personal support.

Notice of collection

Where we collect your personal information directly from you, we will take reasonable steps to ensure that you are aware of:

• our identity and contact details
• the fact that you can gain access to the information
• the purpose for which the information is collected (“the primary purpose”)
• to whom (or the types of individuals or organisations to which) we usually disclose information of that kind
• any law that requires specific information to be collected
• the main consequences (if any) for you if all or part of the information is not collected.

Collection of information from third parties

We may also collect your personal information from third parties or through publicly available sources, for example from Department of Employment and Workplace Relations. We collect your personal information from these third parties so we can provide our services.

We will take all reasonable steps to ensure you are aware that personal information has been collected about you and the circumstances of collection if the:

• information has been collected from another person or entity
• you could not reasonably be expected to know that the information has been collected.

The Notice of Collection section above sets out the information that will be provided to you, where practicable.

Your personal information is collected for the purpose of:

• enabling you access and use our website
• marketing and providing information about the services we offer
• responding to your questions or feedback
• sending messages, reminders, updates and information
• providing a range of support services to apprentices and employers
• meeting legislative, regulatory and contractual obligations.

We use or disclose personal information for the reason it was collected (the primary purpose). In some situations, we may need to use or disclose personal information for a secondary purpose, this can occur where:

1. You have given your consent for us to use or disclose your information for that secondary purpose.
2. The secondary purpose is related to the primary purpose and a person in a similar situation would reasonably expect the information to be used or disclosed for that secondary purpose.
3. Use or disclosure of the personal information is required or authorised by or under law, such as relevant legislation or a court/tribunal order.
4. The use or disclosure is necessary for research, or the compilation or analysis of statistics, in the public interest, other than where the information will be disclosed in a publication in a form that identifies any individual and:
   i) it is impracticable for us to seek your consent before the use or disclosure
   ii) in the case of disclosure, we reasonably believe that the recipient will not disclose the information.
5. We reasonably believe that the use or disclosure is necessary to lessen or prevent a serious threat to:
   i) your life, health, safety or welfare
   ii) public health, public safety or public welfare.
6. We have reason to suspect that unlawful activity has been, is being or may be engaged in, and we use or disclose the personal information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities.
7. We reasonably believe that the use or disclosure of the information is reasonably necessary for specified types of law enforcement functions conducted by, or on behalf of, a law enforcement agency.

Disclosure to third parties

We may also disclose apprentices’ and employers’ personal information to third parties in accordance with this policy. For example, we may disclosure your personal information to:

• our third-party service providers (eg the sub-contracted TAFE institutes providing services on behalf of Apprentice Success)
• government and regulatory bodies where this is required under legislation, a court/tribunal order or in compliance with contractual and funding arrangements (eg the Department of Employment and Workplace Relations, the Victorian Registration and Qualifications Agency and Apprenticeships Victoria.
• a third-party where you have provided consent.

Direct marketing

We may use or disclose personal information about you for direct marketing activities if:

• we collected the information from you
• you have consented to receive direct marketing or would reasonably expect us to use or disclose your information for that purpose
• we provide a simple means for you to request that we stop sending direct marketing (also known as opting out)
• you have not made such a request to us.

Cookies

The Apprentice Success website may use cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website before, so we can distinguish you from other users of the website.

We do not use cookies to identify you, just to improve your experience on our website. If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

Website analytics

Our website may use analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.

We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. To ensure the quality of personal information, we request that you provide relevant and accurate information and notify us where that information requires updating.

We will take reasonable steps to ensure that the personal information we hold is protected from misuse, loss, or unauthorised access, modification or disclosure. We incorporate information security controls to minimise the risk of data loss or misuse by:

• implementing industry-standard security measures, including encryption, firewalls, and access control mechanisms, to protect information
• ensuring that data creation, storage, and processing occur on approved ICT systems
• providing induction and ongoing information security training for staff
• documenting and assigning security roles and responsibilities to employees with specific information security functions
• classifying data in accordance with the current Victorian Protective Data Security Guidelines
• conducting risk assessments on information assets containing personally identifiable information
• ensuring that the disposal of personal information is authorised and complies with the Privacy and Data Protection Act 2014 (Vic) and the Privacy Act 1988 (Cth)
• requiring that our sub-contractors be bound by Victoria’s and Australia’s privacy principles and ensuring that information exchanged is handled in accordance with security standards, privacy principles, and contractual agreements.

When handling personal information received from third parties, we do so according to the originator’s instructions.

If we become aware that your personal information has been inappropriately handled, we will inform you of the incident and take appropriate action to ensure such mishandling does not occur again.

We will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose. This obligation is subject to the Public Records Act 1973 (Vic), which requires us to keep full and accurate records and to retain them for periods of time. As Holmesglen Institute operates Apprentice Success, destruction of personal information will be carried out according to Holmesglen’s retention and disposal schedule and its Records Management Policy.

We will only transfer personal information about you to someone (other than ourselves or you) who is outside Victoria if:

• we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the privacy principles set out in the Privacy and Data Protection Act 2014 (Vic) (Information Privacy Principles) and the Privacy Act 1988 (Cth) (Australian Privacy Principles)
• you consent to the transfer
• the transfer is necessary for the performance of a contract between us or for the implementation of pre-contractual measures taken in response to your request
• the transfer is necessary for the performance of a contract concluded in your interest between us and a third party
• all the following apply:
  • the transfer is for your benefit
  • it is impracticable to obtain your consent to that transfer
  • if it were practicable to obtain that consent, you would likely give it
• we have taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the privacy principles.

Holmesglen operates Apprentice Success and is subject to the Freedom of Information Act 1982 (Vic). Therefore, we are required to manage requests for access to and correction of personal information under that legislation. Please refer to Holmesglen’s Freedom of Information Policy or contact the Freedom of Information Officer for further assistance on foi@holmesglen.edu.au

You may, in some circumstances where it is lawful and practicable, be able to request and receive information from us anonymously.

We will not be able to offer anonymity if:

• we are required or authorised by law, including by a court or tribunal order, to deal with certain individuals
• it is impractical for us to deal with individuals who have not identified themselves.

This Privacy Policy is available on our website and upon request to Apprentice Success (1300 360 921 or info@apprenticesucess.com.au)

As Holmesglen Institute operates Apprentice Success, Holmesglen’s Privacy Officer can also be contacted about this policy (privacy@holmesglen.edu.au). If requested, Holmesglen’s Privacy Officer will take reasonable steps to let you know, generally, what sort of personal information we hold, for what purposes, and how we collect, hold, use and disclose that information.

In the first instance, alleged privacy breaches or complaints about the way we have handled your personal information should be referred to Apprentice Success on 1300 360 921 or feedback@apprenticesucess.com.au. Our complaint handing process is outlined on our website.

If a satisfactory resolution cannot be reached with Apprentice Success, the alleged breach or complaint should be submitted in writing to Holmesglen’s Privacy Officer (privacy@holmesglen.edu.au ). All matters received through this process will be managed in accordance with Holmesglen’s complaint resolution process.