UNSW Global Pty Limited is an innovator and market leader in the provision of international education, training and consulting services to individuals, the community, business, government and non-government organisations. It is a not for profit, wholly owned enterprise of the University of New South Wales (UNSW). It has 236 full-time staff with an annual turnover in excess of $75 million.

UNSW Global compromises a number of internationally renowned business groups:

• UNSW Foundation Studies delivers Australia's leading university preparation program
• UNSW Institute of Languages is Australia's most comprehensive English and language training and testing centre
• UNSW Study Abroad arranges for international university students to receive an accredited study and cultural experience in Australia
• Educational Assessment Australia conducts large-scale assessment testing programs in schools nationally and internationally
• Learn4Life offers community courses, business courses and customised business programs
• Consulting and Expert Opinion Services provides expert advice and consulting services to the public and private sectors in Australia and internationally.

UNSW Global has managerial oversight of the UNSW offshore offices in Hong Kong, India, Singapore, Thailand and Vietnam. It also manages various offshore initiatives including the Hong Kong based recruitment company, Australian Education Consultancy Limited.

All business groups conform to the UNSW Global Privacy Policy

UNSW Global is committed to providing the highest levels of customer service. Implicit in this is the protection of personal privacy.

This policy sets out UNSW Global's Privacy Protection Principles. These are the principles that UNSW Global has adopted in order to protect information about individuals, clients and businesses. These principles deal with the collection, use and disclosure of personal information, as well as access to information and intrusion issues.

It also sets out the principles that UNSW Global will adopt when considering the introduction of new technology or services.

UNSW Global has a responsibility to protect all personal information it collects and to protect the privacy of individuals generally. Much of this policy reflects the details contained in the UNSW Privacy Management Plan.

All UNSW Global staff with access to personal information are responsible for ensuring personal information is protected.

Legislation UNSW Global is covered by the Federal Privacy (Private Sector) Amendment Act 2000. The Act sets out privacy principles that regulate the way NCLT deals with personal information.

Personal information is information that relates to an identifiable person and includes, for example, names, addresses, phone numbers, photographs, dates of birth, passport numbers, student admission or ID numbers, Medicare numbers, and tax file numbers. An individual does not have to be clearly identified by the information, it is only necessary that identity can be reasonably ascertained form the information.

As a general practice, information regarding course participants, consultants, contractors, customers or staff is not disclosed to a third party without that individual's consent.

In the case of an emergency or in exceptional circumstances such as a legal requirement, the Director of a business group of UNSW Global or a delegated officer, at his or her discretion, may authorise the release of personal information.

UNSW Global has in place mechanisms and normal administrative practices which allow the routine handling of requests for access to information, such as course enrolments or for alterations to information such as changes of address.

An individual may request access to their personal information or for their personal information to be amended so that it is accurate, complete and not misleading.

The Privacy Officer at UNSW Global is the point of contact for requests for access to, or alteration of, personal information under the Act.
The Privacy Officer can be contacted by:

Email	m.ferrara@unsw.edu.au
Telephone	612 9385 3666 (9.00am - 5.00pm Monday to Friday)

or by writing to the address below:
Privacy Officer
Corporate Services
UNSW Global Pty Limited
PO Box 6666 UNSW Sydney NSW 1466 Australia

A person who has a complaint in relation to a privacy matter is entitled to request UNSW Global to carry out an internal review.

An application for an internal review must be made in writing, with a return address, to the:
Privacy Officer
Corporate Services
UNSW Global Pty Limited
PO Box 6666 UNSW Sydney NSW 1466 Australia

The written application must be made within 6 months of the time the applicant becomes aware of a contravention of the privacy policy. The applicant should identify the conduct which is the basis for the complaint, and be as specific as possible about the details of the complaint.

There are no fees for lodging an application but fees may be charged for the conduct of the review on the same basis as those allowed under the Freedom of Information Act 1989. Payment may be required in advance.

In most cases, the Privacy Officer will conduct an internal review. Another officer of UNSW Global may deal with the review if the Privacy Officer is substantially involved in the matter, or if the subject of the matter would be more appropriately dealt with by someone other than the Privacy Officer. Internal reviews will be completed as soon as is reasonably practicable and within 60 days of the application being received by the Privacy Officer. Applicants will be advised of the finding of the internal review within 14 days of completion of the internal review.

The NSW State Privacy Commissioner will be notified by the UNSW Global Privacy Officer within 14 days of receiving an application for internal review and will be kept informed of the progress of the review through an interim briefing 30 days after the internal review has commenced. A summary of findings, which may include proposed actions, will also be provided to the Commissioner within 14 days of the completion of the internal review.

As a result of an internal review, UNSW Global may do one or more of the following:

• take no further action on the matter;
• make a formal apology;
• take such remedial action as it thinks appropriate;
• provide undertakings that the conduct will not occur again;
• implement administrative measures to ensure that the conduct will not occur again.

An applicant who is not satisfied with the findings of the UNSW Global review or the action taken by UNSW Global, or because the review was not completed within the 60-day period, may apply to the Administrative Decisions Tribunal for a review of the conduct which was the subject of the application.

Complaints can also be made directly to the Privacy Commissioner. However, individuals are encouraged to make a complaint to UNSW Global in the first instance. This gives UNSW Global the opportunity to resolve the complaint quickly, and addressed matters sooner within UNSW Global.

UNSW Global agents, contractors or service providers are required to conform to the privacy policy detailed in this document. References to UNSW Global in this document are to be taken to include references to those agents, contractors or service providers.

UNSW Global and its business groups will only collect personal information directly from the individual where it is reasonably necessary for the purpose it is being collected. The method of information collection will be lawful, fair and not unreasonably intrusive.

The individual will be informed as to why their personal information is being collected, what will be done with it, the consequences of not supplying it (if any) and their right of access to, and correction of, the information.

UNSW Global will not use personal information for any purpose (the secondary purpose) other than the primary purpose of collection, unless:

• it could be reasonably expected to be used for the secondary purpose;
• the individual has consented;
• there is an opt out option (applies only to direct marketing);
• it is necessary for health research;
• there is a threat to life or health;
• it is required or authorised by law; or
• it is reasonably necessary for law enforcement.

UNSW Global will take reasonable steps to ensure personal information is accurate, complete, up-to-date, relevant and necessary to the undertaking.

UNSW Global will take reasonable steps to protect personal information from misuse, loss or unauthorised access, modification or disclosure. Personal Information will be disposed of securely when it is no longer of use.

UNSW Global will take all reasonable steps to inform people how their personal information is handled and make the information available on request.

An individual has the right of access to their personal information, unless:

• there is a threat to life or health or other people's privacy;
• the request is frivolous or vexatious;
• there are legal proceedings in train;
• negotiations would be prejudiced;
• access is unlawful;
• denying access is required or authorised by law;
• it would prejudice investigation of an unlawful activity or law enforcement or for National security reasons.

If access is denied, a reason will be given.

A government identifier cannot be used as the organisation's identifier. For example, Medicare numbers or Tax File numbers cannot be used as a UNSW Global identification number.

Where lawful and practicable, UNSW Global will do business with people without requiring identification. For example, UNSW Global will not require a person visiting our website to provide us with personal information, until they make a request which requires information in order to meet their request.

UNSW Global cannot send personal information out of the country, unless:

• the recipient is subject to information privacy laws substantially the same;
• the individual consents;
• it is necessary to perform the contract between the individual and the organisation; or
• reasonable steps have been taken to ensure the recipient will deal with the information in line with policies in Australia.

Sensitive information is information about an individual's racial or ethnic origin, political opinions, membership of a political associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of trade union, sexual preferences or practices, criminal record or health information.

UNSW Global can only collect sensitive information if the individual has consented, collection is required by law, there is a threat to life or health, or in relation to legal proceedings.

While users of the UNSW Global website are covered by the same privacy principles, UNSW Global undertakes some additional agreements in relation to such users:

• We destroy all credit card numbers and expiry dates used for a transaction after that transaction has been completed.
• We do not use credit card details for any purpose other than the intended transaction, however, we do retain the name and address information to ensure all transactions are processed correctly and the appropriate service is delivered.
• From time to time we may use the name and address to inform you of new publications or information.

UNSW Global customers are covered by other appropriate fair trading and retail laws.

UNSW Global Pty Limited is a not-for-profit, wholly owned enterprise of the University of New South Wales and in appropriate circumstances also adheres to the Privacy Policy of the University of New South Wales.

This Policy can be found at: Privacy and the University page.

August 2008