2. Lee’s Learning owns and operates each local Lee’s Learning childcare centre (Services).
3. Lee’s Learning collects and holds personal information about you or your child (that is, information relating to an individual or which can be used to identify an individual), that is reasonably necessary for or related to our activities and the services we provide. The purposes for which your personal information is collected will usually be obvious at the time it is collected. Lee’s Learning collects personal information of parents and guardians, children, employees and stakeholders for the primary purposes of providing early childhood education and care services and advocating for the well-being, protection and development of children. Lee’s Learning will only use your personal information for the purpose it was collected or a reasonably expected or related secondary purpose.
6. We understand that when enrolling you and your child at a local Lee’s Learning childcare centre and engaging with Lee’s Learning, the privacy and confidentiality of Personal
Information (as defined under the Privacy Act) is important to you. That’s why we fully respect your and your child’s right to privacy and are committed to protecting the
7. We are committed to protecting the privacy of any parent, guardian, child, employee or stakeholder who uses our Services or our Online Platforms and/or engages with us, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with current applicable laws in relation to privacy including the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
THE INFORMATION WE COLLECT
8. We may collect Personal Information that allows us to identify who a parent, guardian or child is, and share any other Personal Information that may be required in order for us to provide the Services and facilitate our dealings with you.
9. The type of information we may collect includes:
- Personal Information – we may collect personal details such as an individual’s name, location, occupation, date of birth, gender, nationality, family status, custody arrangements, allowing us to identify who the individual is.
- Additional specific information Lee’s Learning collects and holds about children may include – their name, former name, gender, address, Centrelink Customer Reference Number, immunisation status, date and place of birth, birth certificate, Medicare number, custody arrangements or parenting orders, dietary requirements, languages spoken, doctor’s details, medical conditions , additional needs, photographs and videos of children, samples of children’s work and general information about your child and your family that assists us in providing individualised early learning and care to children.
- Contact Information – we collect information such as an individual’s email address, telephone number, third-party user names, residential, business and postal address, emergency contacts and authorizations and other information that allows us to contact the individual.
- Social Media Information – we collect information about social media accounts linked to you, including data from your and your child’s profiles regarding reach, impressions and demographics of your and your child’s followers.
- Financial Information – we collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services.
- Medical Information – we collect financial information such as allergies, dietary requirements, speech, sight or hearing difficulties, medical conditions, operations, illnesses, disabilities, medicinal needs, physical disability or delay, including intellectual, sensory or physical impairment, immunizations and any other information that allows us to properly adhere to the child, parent or guardian and/or provide them with our necessary Services.
- Statistical Information – we collect behavioral and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms. This may include information collected from your and your child’s device such as your and your child’s device ID, geo-location information, IP address, browsing information and any Personal Information that you may provide directly or indirectly to us via websites, WI-FI services and mobile applications.
WHY WE COLLECT PERSONAL INFORMATION
10. We collect your and your child’s Personal Information so that we can carry out the following actions:
- to provide our Services;
- to enable you to use our Online Platforms;
- to communicate with you, including about our Services and offers which might interest you;
- to provide you with information or advice;
- to process payments by or to you in connection with our Services;
- to create accounts, tax invoices or receipts;
- to comply with our legal obligations;
- to consider and respond to complaints made by you;
- to help us manage, develop and enhance our Services (including any collaborations or other activities that involve us sharing your and your child’s Personal Information and data with our third parties);
- to investigate incidents (including potential incidents) which occur on or at our premises; and
- for the general management and conduct of our business.
11. We may disclose additional purposes for collection of your and your child’s Personal Information in collection statements at the point of collection.
HOW INFORMATION IS COLLECTED
12. Personal Information will generally be collected from you directly through the use of our standard forms, over the internet via our website, via email or written communication with you, or through a telephone conversation with you. Photos and videos of children and children’s work samples are collected at their Lee’s Learning centre. Name, address and phone numbers of children’s additional emergency contact people are collected from children’s parents or guardians.
WHEN PERSONAL INFORMATION IS USED & DISCLOSED
13. We will not use any Personal Information other than for the purpose for which it was collected (or a related purpose) other than with the individual’s permission or we are permitted to do so by law.
14. We may disclose your and child’s Personal Information to any third-party purchaser of our business or local Lee’s Learning centre.
16. Subject to clause 24, we will not sell an individual’s Personal Information to unrelated third parties.
17. There are some circumstances in which we must disclose an individual’s information:
- where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
- as required by any law (including the Privacy Act); and/or
- in order to sell our business (in that we may need to transfer Personal Information to a new owner).
- If we believe there is a near or imminent danger/threat to you or your child’s safety, that a governmental authority, child protection agency or family support agency should be made aware of.
18. Sensitive information is information about you that reveals your and your child’s racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
19. We are also required by the Education and Care National Regulations to collect and hold details of your child’s medical conditions, immunization history and additional needs. We collect this information as it is reasonably necessary for ensuring the well-being, protection and development of children in our care.
20. It is our policy to only collect your and your child’s sensitive information where it is reasonably necessary for our functions or activities and either you have consented or we are required or authorised under law to do so.
OPTING “IN” OR “OUT”
21. If you do not wish for your personal information to be collected you should discuss this with a Lee’s Learning employee. Lee’s Learning employees will act strictly in accordance with this policy and will be happy to discuss the reasons for seeking to collect your personal information. They will also discuss with you any consequences of not providing your personal information, or providing incomplete or inaccurate personal information, which may include an effect on what services Lee’s Learning can provide to you and/or your child.
22. We and/or our carefully selected third party business providers may contact you with direct marketing communications and information about the Services offered by us via telephone, email, SMS, or regular mail.
23. At any time you may opt out of receiving commercial electronic messages from us. Each of our commercial emails will have an unsubscribe function which will allow you to unsubscribe from all future communications related to that purpose only.
24. If you would like to opt out of other Lee’s Learning communications, please follow the opt out instructions in those emails. You can also opt out from receiving communications by contacting us via the contact details set out in clause 50.
25. We may use your and your child’s Personal Information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) to assist us in running our business. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties.
26. When your and your child’s Personal Information is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data.
THE SAFETY & SECURITY OF PERSONAL INFORMATION
27. We may hold your and your child’s Personal Information in either electronic or hard copy form.
28. If you provide information to us electronically we retain this information in our computer systems and databases. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.
29. We will take reasonable steps to protect the personal information that we hold from misuse, loss, unauthorized access, modification or disclosure and we use industry standard security measures to safeguard and protect your and your child’s information.
30. We may disclose your and your child’s Personal Information to third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that any such transfer of Personal Information will only be undertaken in compliance with the Privacy Act and does not breach the privacy obligations relating to your and your child’s Personal Information.
32. If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
33. We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
HOW TO ACCESS AND/OR UPDATE INFORMATION
34. If you would like us to update or amend your and your child’s Personal Information, please contact us and we will make the requested amendments.
35. If you would like us to provide copies to you of your and your child’s Personal Information which we hold, please contact us and we will comply with your and your child’s request to the extent required by law.
36. We may ask you to verify your and your child’s identity to ensure that Personal Information we hold is not improperly accessed.
RIGHT TO BE FORGOTTEN
37. In the event that you decide that you no longer want us to hold your and your child’s Personal Information, you may notify us in writing of your and your child’s desire for us to delete your and your child’s Personal Information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your and your child’s Personal Information, unless we are required by law to retain such information.
40. We may use temporary (session) cookies or permanent cookies when you access our Online Platforms and/or Products. This allows us to recognise your and your child’s browser and track the web pages you have visited. You can switch off cookies by adjusting the settings on your web browser.
COMPLAINTS AND DISPUTES
42. If an individual needs to contact us or has a complaint about our handling of their Personal Information, they should address their communication in writing to the details below:
The Privacy Officer
43. If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
44. If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed. If there is a breach of privacy involving your and your child’s Personal Information, we will comply with any legal obligations in the Privacy Act.
45. If you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the Office of the Information Commissioner (Australia).
ADDITIONS TO THIS POLICY
Version Date: 5 July 2021