iTRA Pty Ltd : Privacy Policy

Date: 1 August 2016

1. Background

iTRA Pty Ltd ABN 67 119 274 181 (we, us, our) provides a platform for managing and recording training together with a range of online training courses and services.  In providing these services, we collect, use and disclose personal information. Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is either identified or reasonably identifiable.

We are committed to protecting the privacy of your personal information. This Privacy Policy explains how we collect, use, disclose and otherwise handle personal information. It also tells you how you can ask to access and correct the personal information we hold about you or complain about a suspected privacy breach.

We are required to comply with the Australian Privacy Principles (APPs) inthe Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled.

We are also required to comply with more specific privacy legislation in some circumstances, such as applicable State and Territory health privacy legislation, the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006(Cth).

2. What types of information do we collect?

2.1 Personal Information

The type of personal information that we collect and hold about you depends on the type of dealings that you have with us. If we need to identify you or verify your identity, we may collect your name, gender, date of birth, driver’s licence, student ID number, username and/or password. If we need to communicate with you, we may collect your email, residential and postal addresses and telephone numbers. Depending on the type of training you are completing, we may collect details of your educational qualifications, year of completion, and the contact details for your next of kin.

2.2 Sensitive information

Sensitive information is personal information such as health information and information about racial or ethnic origin that is generally afforded a higher level of privacy protection.

In order to comply with our obligations under Australian law, we may collect sensitive information on behalf of the Australian Government, including your language background, citizenship status, status as an indigenous Australian, and disability status.

We only collect sensitive information where it is reasonably necessary for our business functions and you have consented, or we are required to do so by law.

2.3 Information other than personal information (“non-personal information”)

When you visit our website, some of the information that is collected about your visit is not personal information, because it does not reveal your identity. We use this information to help us improve our services. We may aggregate this information for our own statistical purposes. We will NEVER disclose this information to a third party.

Site visit information

We may record your server address, the date, time and duration of your visit, search terms you used, the pages you viewed, and the type of device, browser and operating system you used.

Cookies

A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users.

We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website.

Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our websites.

3. How do we collect personal information?

3.1 Methods of collection

We will collect personal information by lawful and fair means as required by the Privacy Act. We will also collect personal information directly from you where this is reasonable and practicable.

We collect personal information in a number of ways, including:

  • directly from you in person, over the phone, through written communications (either on paper or electronic) or by you completing forms or answering questions on our websites;
  • from third parties, including government agencies, our related companies and your authorised representatives;
  • from our own records of your use of our services.

3.2 Collection notices

Where we collect personal information directly from you, this information will be stored securely by us for the purposes of conducting our business.  We do not issue Collection Notices.

Where we collect information about you on behalf of the Australian Government, you should note that the Australian Government may use and disclose your personal information in ways that are different from how we use and disclose your personal information.

Where we collect information about you from your authorised representative, we will take reasonable steps to make sure that you are made aware of the collection.

If you provide to us personal information about someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.

4. Why do we collect, hold, use and disclose your personal information?

4.1 General

The main purposes for which we collect, hold, use and disclose personal information are:

  • to identify you and verify your identity;
  • to communicate with you about our services;
  • to provide our services to you, including:
  • facilitating your registration into the online training system;
  • facilitating your access to online training;
  • producing a certificate of completion of training; and
  • obtaining payment for our services;
  • for purposes required or authorised by or under law;
  • to help us improve our services;
  • for any other purposes that you have consented to.

 

4.2 Direct marketing

Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your personal information to send you information about the services we offer, as well as other information. We may send this information by mail, email, SMS and telephone.

Opting out

You can opt out of receiving these communications at any time, in the following ways:

  • contact us (see section 10 below) and tell us.

5. To whom do we disclose your personal information?

We may disclose your personal information to any of the organisations that we deal with in the ordinary administration of our business for the purposes set out in section 4 above, including:

  • the Australian Government;
  • your employer;
  • your employer’s assessors;
  • your employer’s training administrators;
  • third party RTO;
  • third party training provider.

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you.

We may de-identify and aggregate the personal information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.

If you apply for a job with us, we may discuss your application with your nominated referees.

6. Cross border disclosure of personal information

It is our current policy not to disclose personal information to third parties located overseas.

If we change our policy at some time in the future, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information and this Privacy Policy will be amended accordingly.

7. Data quality and security

7.1 General

We hold personal information in a number of ways, including in electronic databases, and email contact lists. We take reasonable steps to:

  • make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
  • protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure;
  • destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.

7.2 Security

The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.

Payment security

We process payments using phone and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

Website security

While we strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (see section 10 below).

You can also help to protect the privacy of your personal information by maintaining the confidentiality of your account (including your password), and by ensuring that you log out of your training site on our website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.

8. How can you access and correct your personal information?

You can request access to the personal information that we hold about you and request corrections by contacting our Privacy Officer (see section 10 below).

If you have login credentials to one of our training portals, you can access and change some of your personal information by logging in and following the instructions on the site.

9. Complaints

If you have a complaint about how we have handled your personal information, please contact our Privacy Officer (see section 10 below).

Our Privacy Officer will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week.

If your complaint can’t be resolved at first instance, we will ask you to complete a Privacy Complaint Form.

Complaints process

We will endeavour to acknowledge receipt of the Privacy Complaint Form within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner.

In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the Privacy Complaint Form. If our investigation may take longer, we will let you know.

If you are unhappy with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information) or, in some instances, other regulatory bodies, such as the Victorian Health Services Commissioner (see here) or the Australian Communications and Media Authority (see here).

10. Further information

Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details for privacy queries are set out below.

Privacy Officer
iTRA Pty Ltd
Mail: Unit 10/3 King Edward Road, Osborne Park, Western Australia
Email: support@itra.com.au
Telephone: 08 9242 8377

11. Changes to this Policy

We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained from our Privacy Officer.