Privacy and Data Use Policy
1. About this policy
This policy applies to personal information collected by The Front Project Ltd (The Front Project), an independent national enterprise that works to improve quality and create positive change in Australia’s early childhood education system. It also applies to personal information handled by incentives run by The Front Project, such as the Upskill program and Online Community.
The Front Project is bound by the provisions of the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs). The APPs set out standards, rights and obligations for how we handle and maintain people’s personal information. This includes how we collect, store, use, disclose, quality assure and secure personal information, as well as your rights to access or correct your personal information.
2. Remaining anonymous
You will often be able to remain anonymous or use a pseudonym when interacting with us. However, this is not always possible, for example when we assess your eligibility for a program, or when we are authorised or required to deal with you as an identified individual. In such cases, we will inform you if you are unable to remain anonymous or use a pseudonym.
3. Our commitment to privacy protection
We are committed to respecting and protecting the privacy of all people connected with the activities of The Front Project. This policy tells you the kind of personal information we, or others on our behalf, collect and hold. It also explains how and why we collect, hold and use that information.
Personal information is information or opinion about an individual whose identity is reasonably identifiable. Examples include a person’s name, address, date of birth and employment details.
In dealing with personal information, we abide by the obligations imposed on us under the Privacy Act.
4. Our personal information handling processes
4.1 What kind of personal information do we collect and hold?
We collect and hold personal information where it is reasonably necessary for us to carry out our activities. The personal information we collect and hold can include, but is not limited to, your:
- city / town of residence;
- email address;
- home address;
- phone number/s;
- job title or role; and
- areas of interest in our work.
In addition to the above list, as part of our Upskill program and Online Community we may also collect and hold personal information regarding your:
- education qualifications;
- education institution (that you are attending, have attended or plan to attend);
- organisation or employer; and
- age range.
We also collect personal information about employees and prospective employees in order to conduct employment and employment-related activities such as payroll services, recruitment and selection, performance management, reporting and work health and safety.
4.2 How do we collect and hold personal information?
We usually collect personal information by the following methods:
- via digital advertising, including social media posts;
- opt-in surveys, including of third parties and individuals who work in or are interested in early childhood education; and
- through our website (www.thefrontproject.org.au), in particular via application forms, subscriptions and ‘Contact Us’ pages.
For the purpose of the Upskill program, we may also collect personal information from:
- education providers such as schools and universities; and
- early learning centres in their roles as employers.
Where possible, we always collect personal information directly from the relevant individual, with the consent of them or their authorised representative. Where we collect information from a third party, we only do so if the individual would reasonably expect us to collect their information in this way.
Generally, we will only collect sensitive information (such as health or criminal history information) if you consent and it is reasonably necessary for, or directly related to, one or more of our functions or activities.
When we collect personal information, we are required under the Privacy Act to notify you of a number of matters, if it is reasonable to do so. These matters include the purposes for which we collect the information, whether the collection is required or authorise by law, and any person or body to whom we usually disclose the information. To achieve this, we will mainly use privacy collection notices on our forms and online portals.
4.3 How do we use and disclose personal information?
We use and disclose personal information for the purpose of operating The Front Project’s activities. This includes but is not limited to:
- supporting early childhood education students and prospective students with mentoring, work placements and upskilling; and
- researching and reporting on early childhood education for the benefit of early childhood education providers and educators, governments, universities, and the broader public.
All our personnel are issued with staff email addresses. When we need to use personal information for our business purposes, we will limit this use to only those The Front Project personnel and partners who need to know that information, always using our official email channels.
If we need to disclose personal information outside of The Front Project and its programs, we will de-identify the information prior to disclosure if it is practicable to do so.
The de-identified personal information we or our programs may share with a third party includes a person’s:
- city / town of residence;
- education qualifications;
- relevant education institution; and
- organisation / employer.
We will not share the following personal information with a third party without the individual’s consent:
- email address;
- home address;
- phone number; and
- job title or role.
We may rely on third parties to undertake the collection of personal information on our behalf, for example to conduct surveys on our behalf. Where this occurs, the third party will be contractually required to handle all personal information with care and confidentiality and in accordance with this policy.
We will not sell or rent your information to anyone and will not transfer your information overseas unless you agree to this.
4.4 How do we deal with Tax File Numbers?
If a person gives us their Tax File Number (TFN), we keep that information secure.
Due to legal restraints on the disclosure of TFNs, if a person asks us for their TFN, we will not be able to provide it to them. If a person wants to obtain their TFN they will need to obtain this from the Australian Taxation Office directly.
In limited circumstances, the Australian Taxation Commissioner can be required by law to provide a person’s TFN to us.
5. Quality of personal information
The Privacy Act requires us to take reasonable steps to ensure that the personal information we hold is safe and secure. We are also required to take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete. This may include correcting your personal information where it is appropriate to do so.
6. Protection of personal information
We take steps to ensure that no one outside The Front Project and its programs (such as the Upskill program) can access information we hold about someone without that person’s consent, unless that access is authorised or required under law.
All personal information held by The Front Project and its programs is stored in electronic format wherever possible on our secure servers and, where necessary, in secure physical filing systems.
We have systems and procedures in place to protect personal information from misuse and loss, as well as from unauthorised access, modification or disclosure. These systems include:
- paper records being held securely;
- access to personal information being strictly on a need-to-know basis, by authorised personnel;
- premises requiring secure access; and
- storage and data systems and protections being regularly updated and audited.
When no longer required, personal information is destroyed in a secure manner.
7. Data Quality
We take all reasonable steps to make sure that the personal information we collect and store is accurate, up-to-date, complete, relevant and not misleading.
8. Our website and social media channels
This part of the policy explains the kinds of information that we collect in managing and operating our website and social media channels, how such information is used and under what circumstances and to whom it may be disclosed.
We also provide services through our website. Users are advised that there are inherent risks in transmitting information across the internet, including the risk that information sent to or from a website may be intercepted, corrupted or modified by third parties.
8.1 What is clickstream data? What data do we collect through clickstream data?
Clickstream data is the process of collecting, analysing and reporting aggregate data about which pages a website visitor visits - and in what order.
When you navigate our website, our servers may record clickstream data.
The clickstream data we may collect includes:
- the user's server (IP) address and machine name;
- the location details such as longitude, latitude, city, region and country;
- the date and time of visit to the site;
- the top-level domain name;
- the pages accessed and documents downloaded;
- the number of bytes transmitted and received for each request;
- the previous site or page visited;
- search terms used; and
- The type of browser and device used.
We may examine this information to determine the traffic through the server and to specific pages. No attempt will be made to identify users or their browsing activities except in the unlikely event of an investigation or where a law enforcement agency may exercise a warrant to inspect server logs. The statistics and log files may be preserved indefinitely and used at any time and in any way necessary to prevent security breaches and to ensure the integrity of the information supplied by the website.
8.2 How do we use and disclose information collected from our websites?
We will only use personal information submitted through our websites for the purposes for which the information was provided.
For example, email addresses provided through website queries will only be used for the purpose of responding to those queries and will not be added to any mailing lists (unless that person has elected to subscribe to our mailing list). We will not use or disclose an email address for any other purpose without the relevant person’s consent.
A "cookie" is a small file supplied by us and stored by the web browser software on a person’s computer when they access our websites. Further information about cookies can be found at: https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising/.
You are welcome to remain anonymous while using our websites and not reveal any of your personal data. However, when you first visit our websites we will ask for your consent to place cookies on your device and to track your website usage behaviour. This helps us to better understand how visitors use our websites and to improve our websites’ offering and services.
We may analyse non-identifiable website traffic data (including through the use of third party service providers) to improve our services and for statistical purposes. No attempt will be made to identify anonymous users or their browsing activities.
8.4 External links to third party websites
Our websites may contain external links and applications operated by certain third parties, such as Facebook, YouTube, Twitter and Instagram. From time to time we also link to relevant content such as research on early childhood education, or information about events hosted by third-party organisations (for example, government and early childhood providers hosting information forums). We are not responsible for the privacy practices of these third parties, or the accuracy, content or security of their websites. You should examine each website's privacy policies and use your own discretion regarding use of their site.
8.5 Can I turn off data tracking?
Yes. Google recommends consumer choice tools created under self-regulation, such as the US-based AboutAds. For more information, visit http://www.aboutads.info/choices. You can also manage cookies in your web browser.
9. Access to and alteration of records containing personal information
You have a right under the Privacy Act to access personal information we hold about you. You also have a right under the Privacy Act to request corrections to any personal information that we hold about you if you think the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
If you think we may have breached your privacy you may contact us to make a complaint using the details in the Contact Us section below. In order to ensure that we fully understand the nature of your complaint and the outcome you are seeking we prefer that you make your complaint in writing.
11. Contact Us
If you have any enquiries or complaints about privacy, or if you wish to access or correct your personal information, please contact the The Front Project by email at firstname.lastname@example.org or by writing to:
The Front Project
Level 18, 1 Nicholson St
East Melbourne VIC 3002