Privacy policy

1. Purpose

NextEd Group Limited, the Company, has developed this Privacy Policy in order to ensure compliance with its obligations regarding the collection, use, disclosure and retention of personal information.

The Company is committed to complying with the Australian Privacy Principles under the Privacy Act 1988 (Cth).

2. Scope

This Policy applies to all personal information collected by the Company in the course of its business.

3. Collection and retention of information

The Company may collect for inclusion in a record and hold the following types of personal information:

1. Name, address, date of birth and information or opinion about character, capabilities, performance and other attributes of staff and potential staff members and potential and actual contractors and tax identifiers, bank account details and insurance information, including workers compensation insurance information, about contractors, collected in the course of recruitment, employment, selection, engagement or dealings with contractors.
2. Name, address, date of birth and other relevant information about students collected in the course of their selection and enrolment with the Company to enable proper administration of the student's course of study and contact before, during or after study, internal planning, relevant health and welfare programs, alumni activities, government and regulatory reporting and funding assistance administration.
3. Name, address, financial product holdings and dealings, bank account details, and tax and other identifiers of holders or potential holders of financial products issued by the Company, collected in the course of responding to applications, maintaining existing relationships and maintaining security registers, including external securities registers or as may be required by the Corporations Act 2001 (Cth).
4. Information disclosed by users of the Company's information technology systems, which are typically systems that store data, collected in the ordinary course of those users' use of such systems.
5. Name, address, email address and information about roles, means of communication with and personal attributes of officers, employees, contractors, and representatives of corporations and entities with whom the Company deals, collected incidentally in the course of dealing with those corporations and entities.

The Company may collect or hold sensitive information as required by Australian law, by a government department or agency, or in order to fulfil its employee and international student visa obligations or comply with the policies of the Company. Unless the collection is required by Australian law, the Company will obtain consent from the individual before it collects sensitive information.

If the Company receives unsolicited personal information, including sensitive information, about individuals from the individual or from other persons, the Company will only collect and hold the information in a record if it is reasonably necessary for the Company's functions or activities and will hold such information only in accordance with the Privacy Act.

The Company will use only lawful and fair means of collecting personal information.

Personal information is held in hard copy and electronic records. Where information is held electronically, it will be held in data storage systems that permit lawful access only by Company staff members who need access to perform their functions.

4. Use and disclosure of information

The Company uses and discloses the above types of information only for the following purposes:

1. Delivering the Company's services, including English language courses, animation, interactive media, games design, colour and interior design courses, and other courses provided from time to time by the Company.
2. Providing student recruitment services.
3. Promoting the Company's services.
4. Administration of the Company's business, including the selection, recruitment, teaching and assessment of students, administration of students' course of study, regulator reporting, funding assistance reporting, visa compliance reporting, internal planning, health and welfare programs, alumni activities, receiving and making payments, and communicating with individuals concerned.
5. Complying with the Company's legal obligations.

The Company will generally not disclose personal information to anyone except:

1. In the manner described in this Policy.
2. When the individual consents to a particular disclosure.
3. Where the identifying data can be removed.

The Company will disclose personal information to third parties only for the purposes discussed in this Policy. When the Company discloses personal information to third parties, it will make all reasonable efforts to ensure it discloses only relevant information that is accurate, complete and up to date, and that the third parties commit to complying with the Privacy Act if applicable.

There may be other disclosures where:

1. The individual would reasonably expect the disclosure to occur, for example for quality assurance, training or enhancing the Company's services.
2. It is required for the Company to recover unpaid fees owing to it.
3. The Company is authorised or compelled by law to disclose.
4. It will prevent or lessen a serious threat to someone's life, health or safety or a threat to public health or safety.
5. It is necessary to take appropriate actions in relation to suspected unlawful activity or serious misconduct.
6. It is necessary to locate a missing person, subject to compliance with rules made by the Australian Information Commissioner.
7. It is necessary as part of the establishment, exercise or defence of a legal claim.
8. It is requested by an enforcement agency such as the police.
9. It is a necessary part of an investigation following a complaint or incident.
10. It is necessary for a confidential alternative dispute resolution process.

The Company is unlikely to disclose personal information overseas except where disclosure may be necessary or appropriate to the Company's business unit GoStudy, if a student or potential student will be dealing with GoStudy and the services offered by GoStudy. The Company will disclose personal information overseas only if the individual consents or if the Company reasonably believes the personal information is protected overseas in a substantially similar way to its protection under the privacy laws and privacy principles that apply to the Company in Australia.

The Company has processes in place to ensure records of personal information remain accurate, complete and up to date. The Company has systems and procedures in place to protect personal information from misuse and loss, and from unauthorised access, modification or disclosure.

If personal information is no longer required by the Company for any purpose for which it was collected, or the Company is no longer able to ensure the personal information is accurate, complete or up to date and it is no longer required by law to be retained, the Company will permanently destroy or de-identify the personal information.

5. Access and correction of information

The Company has measures in place to ensure the personal information it holds is accurate, complete and up to date before acting on it. If an individual learns that personal information the Company holds about them, such as address and contact details, is inaccurate, incomplete or not up to date, the individual should contact the Company so the information can be promptly updated.

If an individual wishes to see what information the Company holds about them, they may contact the Company and ask for a copy. Sometimes it may not be possible for the Company to provide a copy, including where information was provided anonymously, contains details about other people the individual is not authorised to access, or would be unsafe to provide because it might lead to harm being done to another person.

If the Company refuses to provide an individual with access to the individual's record or to update the record in the way the individual requests, the Company will provide written reasons.

If the Company refuses to correct or update an individual's personal information, the individual may request that the Company make a note on the record that the individual is of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading.

The Company will not charge an individual for lodging a request for a copy of their personal information but may ask the individual to pay a reasonable fee for the work involved in providing the information and associated costs such as photocopying. The individual will be notified of any likely costs before the request is processed.

6. Privacy notice - EU and Brazilian citizens only

When collecting the personal information of European Union citizens and Brazilian citizens, this data will be protected, retained, and managed in accordance with the requirements of the General Data Protection Requirements (EU) and the General Personal Data Protection Law (Brazil), as well as the Privacy Act 1988 (Cth) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). Information collected will only be that data determined to be necessary to enrol students into courses and in accordance with the requirements of government departments and agencies.

7. Privacy complaints

If an individual has a privacy complaint or concern, especially if they think their privacy has been affected or wish to complain about the Company's refusal to update or grant access to personal information, the individual should contact the Company's privacy officer, who will examine the complaint.

If the individual is dissatisfied with how the Company's privacy officer deals with the complaint, the individual can subsequently complain about the privacy matter to the Australian Information Commissioner. See www.oaic.gov.au for how to make a complaint.

8. Contact the Privacy Officer

For further information on this Policy or to lodge a privacy complaint, please contact: