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Privacy policy

Leadership Management Australia is committed to maintaining the privacy and confidentiality of its Registered Training Organisation personnel and Participant records. Leadership Management Australia complies with the Privacy Act 1988 including the 13 Australian Privacy Principles (APPs) as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

Leadership Management Australia manages personal information in an open and transparent way. The following sections of this policy outline how we manage personal information in compliance with the Australian Privacy Principles.

Australian Privacy Principle 1 – Open and transparent management of personal information.
Australian Privacy Principle 2 – Anonymity and pseudonymity
Australian Privacy Principle 3 — Collection of solicited personal information
Australian Privacy Principle 4 – Dealing with unsolicited personal information
Australian Privacy Principle 5 – Notification of the collection of personal information
Australian Privacy Principle 6 – Use or disclosure of personal information
Australian Privacy Principle 7 – Direct marketing
Australian Privacy Principle 8 – Cross-border disclosure of personal information
Australian Privacy Principle 9 – Adoption, use or disclosure of government related identifiers
Australian Privacy Principle 10 – Quality of personal information
Australian Privacy Principle 11 — Security of personal information
Australian Privacy Principle 12 — Access to personal information
Australian Privacy Principle 13 – Correction of personal information
Using our website

Australian Privacy Principle 1 – Open and transparent management of personal information
Leadership Management Australia retains a record of personal information about all individuals with whom we undertake any form of business activity. Leadership Management Australia must collect, hold, use and disclose information from our clients and stakeholders for a range of purposes, including but not limited to:
Providing services to clients;

  • Managing employee and contractor teams;
  • Promoting products and services;
  • Conducting internal business functions and activities; and
  • Requirements of stakeholders.

As a government Registered Training Organisation, Leadership Management Australia is required by state and federal law to collect, hold, use and disclose a wide range of personal information on participants in nationally recognised training programs.

It is further noted that, aligned with these legislative requirements, Leadership Management Australia delivers services through a range of Commonwealth and State Government funding contract agreement arrangements, which also include various information collection and disclosure requirements.

Individuals are advised that due to these legal requirements, Leadership Management Australia discloses information held on individuals for valid purposes to a range of entities including:

  • Governments (Commonwealth, State or Local);
  • Australian Apprenticeships Centres;
  • Employers (and their representatives), Job Network Providers, Schools, Guardians; and
  • Service providers such as credit agencies and background check providers.

Kinds of personal information collected and held
The following types of personal information are generally collected, depending on the need for service delivery:

  • Identity details;
  • Contact details;
  • Employment details;
  • Educational background;
  • Demographic Information;
  • Course progress and achievement information; and
  • Financial billing information.
  • Employee details & HR information;
  • Complaint or issue information;
  • Disability status & other individual needs;
  • Indigenous status

How personal information is collected
Leadership Management Australia’s approach to collecting personal information is to collect any required information directly from the individuals concerned. This may include the use of enrolment forms and the use of web based systems (such as online enquiry forms, web portals or internal operating systems).

Leadership Management Australia does receive solicited and unsolicited information from third party sources in undertaking service delivery activities. This may include information from such entities as:

  • Governments (Commonwealth, State or Local);
  • Australian Apprenticeships Centres; and
  • Employers (and their representatives), Job Network Providers, Schools, Guardians.

How personal information is held
Leadership Management Australia’s approach to holding personal information includes robust storage and security measures at all times. Information collected is stored in secure, password protected systems, such as our student management system; and monitored for appropriate authorised use at all times.

Only authorised personnel are provided with login information to each system. Leadership Management Australia ICT systems are hosted with robust security to physical server locations and server systems access. Virus protection, backup procedures and ongoing access monitoring procedures are in place.

Destruction of paper based records occurs as soon as practicable in every matter, through the use of secure shredding and destruction services at all Leadership Management Australia sites.

Accessing and seeking correction of personal information
Leadership Management Australia confirms all individuals have a right to request access to their personal information held and to request its correction at any time. In order to request access to personal records, individuals are to make contact with:
Leadership Management Australia Quality and Compliance Manager
03 9822 1301
info@lma.biz

A number of third parties, other than the individual, may request access to an individual’s personal information. Such third parties may include employers, Australian Apprenticeships Centres, Governments (Commonwealth, State or Local) and various other stakeholders.

In all cases where access is requested, Leadership Management Australia will ensure that:

  • The individual to whom the information relates will be contacted to confirm consent (if consent has not previously been provided for the matter); and
  • Only appropriately authorised parties, for valid purposes, will be provided access to the information

Making our APP Privacy Policy available
Leadership Management Australia provides our APP Privacy Policy available free of charge, with all information being available from our website (link) and included in our Participant Handbook.

Australian Privacy Principle 2 – Anonymity and pseudonymity
As a Registered Training Organisation, Leadership Management Australia is required to confirm the identity of individuals enrolling in nationally recognised course programs.

However, for general course enquires or other situations in which an individuals’ information is not required, Leadership Management Australia provides individuals with the option of not identifying themselves, or of using a pseudonym.

Australian Privacy Principle 3 — Collection of solicited personal information
Leadership Management Australia only collects personal information that is reasonably necessary for our business activities.
All information is collected by lawful and fair means.

We collect solicited information directly from the individual concerned, or in situations where an employer is nominating a participant for a course and it is more practical to do so, we may collect information from the employer.

Australian Privacy Principle 4 – Dealing with unsolicited personal information
Leadership Management Australia may from time to time receive unsolicited personal information. Where this occurs we review the information to decide whether or not we would have collected the information for the purpose of our business activities. Where this is the case, we may hold, use and disclose the information appropriately as per the practices outlined in this policy.

Where we would not have collected this information for a valid business purpose we will immediately destroy or de-identify the information.

Australian Privacy Principle 5 – Notification of the collection of personal information
Whenever Leadership Management Australia collects personal information about an individual, we take reasonable steps to notify the individual that this information is being collected. This notification occurs at or before the time of collection, or as soon as practicable afterwards.

Collection from third parties (such as employers)
Where Leadership Management Australia collects personal information from a third party, we:

  1. Confirm whether the other party has provided the relevant notice to the individual; or
  2. If this has not occurred, we will provide notification to ensure the individual is fully aware of the information collection.

Australian Privacy Principle 6 – Use or disclosure of personal information
Leadership Management Australia only uses or discloses personal information it holds about an individual for the particular primary purposes for which the information was collected, or secondary purposes in cases where:

  • An individual consented to a secondary use or disclosure;
  • An individual would reasonably expect the secondary use or disclosure; or
  • Using or disclosing the information is required or authorised by law.

Australian Privacy Principle 7 – Direct marketing
Leadership Management Australia does not use or disclose the personal information that it holds about an individual for the purpose of direct marketing, unless:

  • The personal information has been collected directly from an individual, and the individual would reasonably expect their personal information to be used for the purpose of direct marketing; or
  • We provide a simple method for the individual to request not to receive direct marketing communications (also known as ‘opting out’).

Australian Privacy Principle 8 – Cross-border disclosure of personal information
Before Leadership Management Australia discloses personal information about an individual to any overseas recipient, we undertake reasonable steps to ensure that the recipient does not breach any privacy matters in relation to that information.

Information may be provided to an overseas parent company in cases where and individual’s training is being paid for by the employer.

Australian Privacy Principle 9 – Adoption, use or disclosure of government related identifiers
Leadership Management Australia does not adopt, use or disclose a government related identifier related to an individual except:

  • In situations required by Australian law or other legal requirements;
  • Where reasonably necessary to verify the identity of the individual; or
  • Where reasonably necessary to fulfil obligations to an agency or a State or Territory authority.

Australian Privacy Principle 10 – Quality of personal information
Leadership Management Australia takes reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete.
Quality measures in place supporting these requirements include:
Internal practices, procedures and systems to audit, monitor, identify and correct poor quality personal information);

  • Protocols that ensure personal information is collected and recorded in a consistent format, from a primary information source when possible;
  • Ensuring updated or new personal information is promptly added to relevant existing records;
  • Providing individuals with a simple means to review and update their information on an on-going basis through our online portal;
  • Reminding individuals to update their personal information at critical service delivery points (such as completion) when we engage with the individual; and
  • Contacting individuals to verify the quality of personal information where appropriate when it is about to used or disclosed, particularly if there has been a lengthy period since collection.

Australian Privacy Principle 11 — Security of personal information
Leadership Management Australia takes active measures to ensure the security of personal information we hold. This includes reasonable steps to protect the information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

We destroy or de-identify personal information held once the information is no longer needed for any purpose for which the information may be legally used or disclosed.

Access to Leadership Management Australia offices and work areas is limited to our personnel only – visitors to our premises must be authorised by relevant personnel and are accompanied at all times. With regard to any information in a paper based form, we maintain storage of records in an appropriately secure place to which only authorised individuals have access.

Regular staff training is conducted with Leadership Management Australia personnel on privacy issues, and how the APPs apply to our practices, procedures and systems. Training is also included in our personnel induction practices.
We conduct ongoing internal audits (at least annually and as needed) of the adequacy and currency of security and access practices, procedures and systems implemented.

Australian Privacy Principle 12 — Access to personal information
Where Leadership Management Australia holds personal information about an individual, we provide that individual with access to the information (free of charge) on their request. In processing requests, we:

  • Ensure through confirmation of identity that the request is made by the individual concerned, or by another person who is authorised to make a request on their behalf;
  • Respond to a request for access:
  • Within 14 calendar days, when notifying our refusal to give access, including providing reasons for refusal in writing, and the complaint mechanisms available to the individual; or
  • Within 30 calendar days, by giving access to the personal information that is requested in the manner in which it was requested.

Australian Privacy Principle 13 – Correction of personal information
Leadership Management Australia takes reasonable steps to correct personal information we hold, to ensure it is accurate, up-to-date, complete, relevant and not misleading.

Individual Requests
On an individual’s request, we:

  • Correct personal information held; and
  • Notify any third parties of corrections made to personal information, if this information was previously provided to these parties.
  • In cases where we decline to update personal information, we:
  • Give a written notice to the individual, including the reasons for the refusal and the complaint mechanisms available to the individual;
  • Upon request by the individual whose correction request has been refused, take reasonable steps to associate a statement with the personal information that the individual believes it to be inaccurate, out-of-date, incomplete, irrelevant or misleading;
    • Respond within 14 calendar days to these requests; and
    • Complete all actions free of charge.

Correcting at Leadership Management Australia’s initiative
We take reasonable steps to correct personal information we hold in cases where we are satisfied that the personal information held is inaccurate, out-of-date, incomplete, irrelevant or misleading (that is, the information is faulty). This awareness may occur through collection of updated information, in notification from third parties or through other means.

Using our website

  •   If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit a Leadership Management Australia website. In most cases, a cookie does not identify you personally but it may identify your internet service provider or computer.
  • However, in some cases, cookies may collect and store personal information about you. Leadership Management Australia extends the same privacy protection to your personal information, whether gathered via cookies or from other sources, as detailed in this Privacy Policy. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our web sites or take advantage of the improved website experience that cookies offer.
  • We also use permanent cookies to enable basic web traffic analysis using Google Analytics which, for example, shows us which areas of our website are popular against those that are not visited often. This allows us to prioritise our enhancements to our website and increase the productivity of our website. We also use remarketing with Google Adwords and Analytics to display content specific advertisements to visitors that have previously visited our website when those visitors go to other websites that have implemented the Google Display Network.
  • We undertake the following Google features on our website, Google Analytics, Google Adwords, Remarketing and DoubleClick. These features do not use any sensitive personal information you have provided us, nor do they use any identifiable personal information.
  • Google may include in-ads notice labels to disclose interest-based advertising to you. Third-party vendors, including Google, will show Leadership Management Australia ads on websites across the Internet. Leadership Management Australia and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on an individual’s past visits to the Leadership Management Australia website.
  • As a visitor to our website, you can opt out of Google’s use of cookies by visiting Google’s Ads Settings www.google.com.au/settings/ads. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt out page http://www.networkadvertising.org/choices/.
  • We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
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