Updated 2 August 2021
XEd Space Pty Ltd ABN 23 637 831 540 (XEd Space) is committed to providing quality services to you and this policy outlines how we manage your Personal Information. As at the date of this Statement, XEd Space is not an APP entity bound by the Privacy Act 1988 (Cth) (the Privacy Act) or the Australian Privacy Principles (APPs) in the Privacy Act. However we are guided by the APPs in how we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, twitter handles, phone numbers, your programs, program feedback, assessment responses etc.
This Personal Information is obtained in many ways including by telephone, email, via our website www.xedspace.com.au (including automatic collection via cookies), from your website, from media and publications, from other publicly available sources such as Linked In and Facebook -and from third parties such as your employer and our service providers. We don’t guarantee website links or the policies of authorised third parties.
We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
If we cannot collect your personal information, this may, for example, affect our ability to deliver you services or affect the quality of those services. If you are a service provider to us, this may affect your ability to perform the service.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing at firstname.lastname@example.org
The APPs allow for the possibility of not identifying yourself or using a pseudonym when you deal with us on a particular matter. However, an exception to this is where it would be impracticable for us to deal with an unidentified individual and this will commonly be the case for the services we provide.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties, such as where you would reasonably expect it (for example, from someone who booked a program for you) or where you have consented to your Personal Information being shared.
If you provide information about another person (for example, the name and details about a program participant), you must make sure that they have agreed to you providing this information to us. You must make them aware of this policy, such as providing a link to it.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
- To our service providers (such as program facilitators and coaches, technology and administrative providers and, where applicable, CCL as a program licensor.
- Other third parties where you consent to the use or disclosure.
- Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years. CCL may retain your Personal Information as part of its record of your completion of CCL programs.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing. XEd Space will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
This Policy may change from time to time and is available on our website. Any amendments to this Policy will be effective immediately, once posted to our website.
The Privacy Officer
XEd Space Pty Ltd
If you are unsatisfied with our response, you may seek legal advice or make enquiries with the Office of the Australian Information Commissioner. As at the date of this policy, XEd Space is not an APP entity under the Privacy Act 1988.