College of Therapy Yoga & Zen Shiatsu Pty Ltd (COTY) is a Registered Training Organisation with responsibility for delivering vocational education and yoga teacher training. COTY collects and stores personal information on our learners and industry clients. In addition, COTY provides other services and products which it collects and stores personal information including teaching yoga, acupuncture, traditional Chinese medicine consultations, Zen shiatsu, IPL etc.
COTY complies with the Privacy Act 1988 (Commonwealth). This policy describes how COTY collects, manages, uses, discloses, protects, and disposes of personal information in accordance with the thirteen Australian Privacy Principles (APPs) outlined in Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
We may also collect personal information to be able to develop and identify products and services that may interest you, to conduct market or customer satisfaction research or to develop, establish and administer alliances and other arrangements with other organisations in relation to the promotion and use of our respective products and services.
Under the Privacy Act 1988 and Privacy Amendment (Enhancing Privacy Protection) Act 2012 (s6(1)), personal and sensitive information is defined as follows:
Personal information: “information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.”
Sensitive information: “(a) information or an opinion about an individual’s: (i) racial or ethnic origin, or (ii) political opinions, or (iii) membership of a political association, or (iv) religious beliefs or affiliations, or (v) philosophical beliefs, or (vi) membership of a professional or trade association, or (vii) membership of a trade union, or (viii) sexual preferences or practices, or (ix) criminal record, that is also personal information; or (b) health information about an individual; or (c) genetic information about an individual that is not otherwise health information; or (d) biometric information that is to be used for the purposes of automated biometric verification or biometric identification; or (e) biometric templates”.
COTY is an approved Registered Training Organisation by the Australian Skills Quality Authority. This registration is issued under the authority of the National Vocational Education and Training Regulator Act 2011. This legislation requires COTY to collect personal and sensitive information from its learners. This requirement is specified in the Data Provision Requirements 2012 which is one of five legislative instruments that COTY must comply with as a condition of its registration.
The data provision requirements require COTY to collect data from learners in accordance with the Australian Vocational Education and COTY Information Statistical Standard (AVETMISS). This is a complex information standard that defines information about who the learner is, where the training is delivered and what they are studying. The Standards for Registered Training Organisations require COTY to retain and store this information for up to 30 years and to report training activity to government agencies in accordance with mandatory reporting requirements.
Together these requirements form a statutory obligation to collect, store and report information of any learner participating in nationally accredited training. The publications referred to in this section can be accessed from the ASQA website.
COTY collects personal information, either directly or indirectly, that is reasonably necessary for, or directly related to its delivery of the services it offers. Some of the information collected may be regarded as ‘sensitive’ as defined by the Privacy Act.
Contact information such as name, organisation, position, address, telephone, and email are collected for marketing, support services, mandatory reporting and for communicating with stakeholders as part of our day to day operation.
Names, addresses, phone numbers, emergency contact details, bank account details and other employment related information is collected for the purpose of managing human resources. The management of staff personal information complies with this policy.
Learner personal and sensitive information as well as training activity information is prescribed by the AVETMIS Standard. This information is collected directly from our learners using enrolment forms which may be paper based or electronic and other administrative forms including but not limited to complaint forms, recognition application, request for refund, transfer application, etc. Much of this information is entered into our learner management software called “RTO Data”. Hard copy records are retained within our learner files.
Survey responses are collected using our Learner Satisfaction Surveys which are issued both in hard copy and electronic format. These survey results are returned to the main office and entered into our survey analysis software “Satisfaction Data”. Survey forms once entered into Satisfaction Data are either destroyed if hard copy or permanently deleted if in electronic form.
Enquiry information from prospective learners including personal contact information is collected directly from individuals who make data requests either by telephone or email in person or via our website.
COTY personal information is collected from individuals on employment commencement.
Personal information collected by COTY that may be regarded as ‘sensitive’ under the Privacy Act includes:
‘Disability’ and ‘long-term impairment status’ (health); and ‘indigenous status’, ‘language spoken at home’, ‘proficiency in spoken English’, ‘country of birth’ (implies ethnic/racial origin). This information is specified in the AVETMISS data elements and is collected for the national VET data collections, national VET surveys, and may be collected for VET-related research.
Health information including history, current status, medications etc
‘Dietary requirements’ (health-related) are collected for event catering purposes only.
Biographical information, which may contain information on ‘affiliations’ and ‘membership of a professional or trade association’ are obtained from keynote speakers for event marketing purposes.
‘Memberships of professional associations’ and ‘health and work injury information’ is collected from COTY employees for HR management purposes.
COTY respects an individual’s right not to receive marketing material and provides an option within communications and on its website for individuals to unsubscribe from receiving marketing material. COTY conducts its marketing communications and dissemination of service information in accordance with Australian Privacy Principle 7 (Direct marketing), the Spam Act 2003 (in respect of electronic communications), and the Do Not Call Register Act 2006. It is not, however, COTY practice to ‘cold call’ for the purpose of marketing its products and services.
COTY web servers automatically log information such as server address, date and time of visit and web pages accessed. No personal information is recorded. These logs are used for website management and improvement.
If COTY should receive unsolicited personal information, it will be treated and managed according to the Australian Privacy Principles.
COTY aims to notify individuals of the collection of their personal information before, or at the time of collection, or as quickly as possible thereafter. Notifications are usually in writing, but may be verbal for telephone help-desk services, or research conducted by telephone interview.
Marketing – notification is provided on our website course application page. Individuals are also notified at the time of collecting personal information for events. A privacy notice is provided in all COTY marketing communications.
Quality Indicator surveys – notification is provided in the letter of invitation to participate in the surveys and also at the time of collecting the information (online or by telephone).
COTY staff – Notification is provided on employment commencement.
COTY does not disclose personal information other than for the purpose for which it was collected, or an individual has consented to a secondary purpose, or an individual would reasonably expect this (such as receiving communications about upcoming events), or if required by law.
COTY may share personal information with the Commonwealth government in accordance with Commonwealth contractual obligations. In these circumstances COTY will take reasonable steps to inform and seek consent from the individuals concerned and take all reasonable steps to ensure that the recipient handles the personal information according to the APPs.
COTY does not sell its mailing lists to third-parties for marketing purposes.
COTY does not disclose personal information to overseas recipients. While people around the world can access material published on our website, no statistical or research publications contain identifiable personal information.
COTY endeavours to ensure the personal information it collects and uses or discloses is accurate, up to date, complete and relevant. COTY routinely updates the information held in its customer relationship management system. This includes confirming with learners who are returning for a new enrolment if their personal contact details have changed.
Access to and correction of personal information
Individuals may, subject to the exceptions prescribed by the Australian Privacy Principles, request access to and correction of their personal information where this is collected directly from individuals by COTY.
COTY does not charge for giving access to or for correcting personal information. Requests for access to or correction of personal information should be made in accordance with the learner access to records policy.
Personal information is held in electronic and paper format:
Information collected from learner enrolment applications and survey responses, is held in databases.
Names and contact details of stakeholders are held in RTO Data and email contact lists.
Names and contact details collected during the delivery of services may be held either in electronic form in COTY document management system or in paper documents which are locked in cupboards and filing cabinets.
Personal staff information is held in VetTrac and HR management, pay roll database.
Backup copies of all electronic files held in COTY systems are kept in the event of system failure/loss. All backup copies of system files are secured.
COTY retains personal information for 30 years. When personal information is no longer necessary for COTY business functions, and it is lawful to do so, COTY destroy the information.
COTY takes active steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
COTY systems and internal network are protected from unauthorised access using appropriate technologies. Most system data transferred over the internet is protected by Secure Socket Level protocol (SSL). The inherent risks associated with data transmission over the internet are, however, commonly acknowledged. Individuals, who do not wish to provide their personal information via the online website forms have the option of mailing this information to COTY.
Access to VetTrac is protected through user log-on and password, and assignment of user access rights.
Third-party providers used by COTY for the delivery of services are all located within Australia and are required to be compliant with the Australian Privacy Principles and offer appropriate safeguards to protect personal information.
COTY premises and data storage systems are fully secured. COTY practices clean-desk policy and locking workstations when working with personal information. Paper documents containing names and addresses are required to be locked away and shredded when destroyed. All hardware is properly ‘sanitised’ before disposal.