Privacy Policy

Deakin University (“University”) engages education technology provider Keypath Education Australia Pty Ltd (“Keypath”) to support the University with marketing, student recruitment and student support of select online courses (the Services).

Where Keypath collects, accesses, uses or discloses personal information in the course of providing the Services, the terms of the Privacy Policies below will apply.

Table of Contents

 

Deakin University Privacy Policy

The way we handle personal information or requests for personal information is outlined below.

Deakin staffstudents and alumni should also refer to the Privacy Statements, which contain information and specific detail regarding how we collect and manage your personal information.

Use and disclosure of personal information

Deakin is committed to responsible collection and management of personal and health information (referred to in this statement as personal information) consistent with the Privacy and Data Protection Act 2014 (Vic), the Health Records Act 2001 (Vic) and our Privacy Policy. All areas of Deakin treat personal information and health information in accordance with our Privacy Policy.

Deakin website users

When you visit our site, Deakin may collect your personal information as well as data about your interaction with our website.

Automated collection of data

We use functional, analytical and tracking cookies (or similar technologies) which are saved to your web browser to personalise your visit to our website. For this purpose, the cookie collects your IP address, browser type, browser language, date and time of your request, and the identity of your browser.

We collect data using cookies to help us better understand how people use our website and to give website visitors a better experience. You may choose not to accept cookies by opting-out of DoubleClick or opting-out of Google Analytics.

More information about how we use functional, analytical and tracking cookies (or similar technologies) and how you may manage them can be found on Manage cookies on the Deakin website.

Collection from you

Deakin collects your personal information when you supply it to access restricted areas of our websites, request information, complete online surveys and forms, or when offering feedback about Deakin's website. We collect this personal information to fulfil your service request and facilitate your participation in surveys.

If you choose not to accept cookies or supply your personal information, we may not be able to personalise your experience, provide you with access to restricted websites, or fulfill your request and it may limit your ability to participate in surveys and other feedback activities.

Applicants for employment at Deakin

When you apply for a role at Deakin, we collect your personal information to administer your application and assess your suitability for the relevant position.

If your application is successful, the personal information Deakin has collected will form part of your employment record and will be used to administer your employment at Deakin.

If your application is not successful, Deakin may keep your submission and related documents on file for a reasonable period and may use your information to communicate with you about other employment opportunities that may be of interest. If you do not wish your details to be retained, please email DeakinRecruit@deakin.edu.au and request that they be removed.

Full details of how Deakin manages your application are available when you apply via Deakin’s online recruitment process.

The personal information Deakin collects

We will collect personal information relevant to the position you apply for. This may include your name and contact details, employment history, educational history, professional associations, racial/ethnic background, health, and any requirements for accommodation during the interview process.

How Deakin collects your personal information

Collection from you

Most personal information will be collected from you directly when you enter your details into Deakin’s recruitment system/s.

Collection from recruitment service providers

Deakin engages recruitment service providers to assist it in recruitment (Recruiters). The Recruiters have entered into agreements with Deakin in which they are obligated to protect the privacy of your personal information.

Deakin will collect personal information relevant to your application from these Recruiters.

Who Deakin may disclose your personal information to

Assessment and verification

Deakin may disclose your personal information to external selection panel members and to your referees.

Deakin may also disclose your name and relevant details to:

  • verify your identity and the personal information provided by you or collected about you (e.g. education, professional affiliations);
  • its legal advisors, professional advisors or consultants;
  • conduct criminal records checks, working with children and other fit and proper person checks, if relevant to the position for which you are applying.

Referees

Deakin will provide your name, contact details and details of the position you have applied for to your named referees. Deakin encourages you to notify your referees that it holds the referee’s contact details and that they may seek access to the information held about them by contacting Deakin’s Privacy Officer at privacy@deakin.edu.au.

Disclosure outside of Australia

If Deakin must communicate with a person or entity (a recipient) located outside of Australia to verify your personal information or to contact your referees, you should be aware that the privacy laws applying in the recipient’s jurisdiction may not be comparable to those in place in Australia. By providing the relevant information to Deakin you are consenting to it disclosing your personal information to a recipient outside of Australia to the extent relevant to your application.

Other than as notified above, Deakin will not disclose your personal information to any other person or entity without your prior consent, unless it is authorised or required by law to do so.

Research and collaboration from other institutions

This statement explains how Deakin manages your personal information when you collaborate with Deakin researchers.

Deakin collects your name, position, employer, contact details and research profile. It will also collect your salary level where required to cost an application for research funding. This information is obtained either directly from you or from collaborating institutions. Deakin collects this information for the primary purpose of preparing and submitting applications for research funding and for the secondary purpose of communicating with you about any application for funding and for documenting your collaboration with Deakin researchers.

Your personal information will be shared with other collaborators on the research project and with the external funding body. Your personal information will form part of Deakin’s research records and will be stored in its research information management system and records management system. It will be securely destroyed or deleted in accordance with Deakin’s record retention protocols.

Visitors to our campuses

When you are on our campuses, your personal information is collected in the ways outlined below. Deakin will use this information to enable access to University premises and facilities on campus, to confirm access rights and identity, to enhance the safety of staff, students and visitors to the University's campuses, to protect University property, and for planning, quality assurance and analytics purposes.

Surveillance cameras

Images of you from cameras installed to enhance safety, security and protection of individuals and property. These cameras are also used to monitor and analyse use and demand for our facilities and to enable investigations of incidents on campus.

Location tracking

Personal device technology allows location-based data to be collected if you enable location based services. Depending on the settings on your personal device, its name may constitute personal information. Deakin uses location based data to monitor and analyse traffic patterns, space usage and allocation, and generally to improve the digital and campus experience. For Deakin staff and students, Deakin digital tools may use location-based services to promote special offers and events and may provide emergency and safety warnings relevant to on-campus locations.

Wi-fi

When you turn on wi-fi on your personal device, Deakin collects your unique device identifier as well as where and when you connect to the wireless network. Deakin uses this information to assist users having connectivity issues, for planning, quality assurance and analytics purposes. Deakin does not disclose this information to third parties, other than its contracted service providers, except where required or authorised by law.

Building access and security system

Access to University premises and facilities may be restricted, and only specific individuals granted access (usually via a staff or student card). The technology underlying the access card system generates records of access enabling an individual’s identity to be validated against other University IT systems.

Information for individuals located in the EU

This information should be read in conjunction with the student or staff privacy statement, as applicable.

Authority

Deakin University manages personal information under the authority of the Deakin University Act 2009 (Vic). It also processes your personal information where relevant to its legitimate interests and its legal and regulatory obligations.

Data Protection Officer

The University Privacy Officer, Shirley Rooney, is Deakin’s Data Protection Officer for purposes of the General Data Protection Regulation 2016 (GDPR).

Data subject rights

You may have the following data subject rights:

  • Access: you may receive a copy of the personal information held by Deakin about you.
  • Correction: you may request correction of the personal information Deakin holds about you.
  • Objection to Processing: you may object to processing if you demonstrate that Deakin's processing of your personal information impacts on your fundamental rights and freedoms as contemplated by the GDPR. Your objection to processing may be denied if Deakin is able to demonstrate compelling legitimate grounds to process personal information which override those rights and freedoms.
  • Suspension of Processing: you may request that Deakin suspend the processing of your personal information if:
    • you want Deakin to establish the data's accuracy before processing it
    • Deakin's use of the data is unlawful but you do not want it erased from Deakin's records
    • you need Deakin to hold the data to enable you to establish, exercise or defend legal claims
    • you have objected to Deakin's use of your data but Deakin is in the process of verifying if it has overriding legitimate grounds to use it.
  • Transfer to you or to a third party: if we hold your personal information in an electronic format (e.g. a database), we will provide it to you, or a third party in a structured commonly used, machine-readable format.
  • Withdrawing consent: if Deakin processes your personal information based solely on your consent, you may withdraw that consent, however Deakin may not be able to continue to provide you with certain goods or services. If your withdrawal of consent relates to marketing material, please follow the unsubscribe processes below.

You may exercise your data subject rights by emailing Deakin's Data Protection Officer and providing written details of your request.

Deakin Alumni, Friends and Supporters

Deakin University collects and uses personal information about its alumni, donors, and wider community of friends and supporters. Deakin may collect personal information directly from you or from publicly available sources.

Your personal information is used for the primary purpose of staying connected with you, providing you with services, keeping you informed about activities and opportunities that may be of interest to you, contacting you for marketing and fundraising initiatives and/or accepting and managing your philanthropic support. Deakin may also use your personal information to assist with planning and quality assurance, to invite you to participate in surveys and research, to comply with legislative reporting requirements, and as permitted or required by law.

For these purposes, Deakin may share your personal information with other units of the University and with service providers who are subject to contractual privacy obligations.

Graduation programs, which include the name and award of each Deakin graduate at that graduation ceremony, are a public record of the University.

Deakin also provides an online qualification verification service that confirms if individuals have received a Deakin award. Further information is available at https://apps.deakin.edu.au/gradsearch.

DeakinCo.

DeakinCo. is a division of Deakin University, providing learning and development solutions tailored for business. DeakinCo. additionally offers credential services to validate and accredit skills developed independently of traditional educational institutions.

DeakinCo. collects your personal information when you or your employer request its services. DeakinCo. uses your personal information for the primary purpose of delivering its assessment and credentialing services and when delivering its employment-based courses. It also uses your personal information to stay connected with you and to keep you informed about activities and opportunities both through DeakinCo. and more generally through Deakin University, that may be relevant to your credential and interests. You may also receive marketing and sales information relevant to your employment. Your personal information may be used for planning and quality assurance, for research and otherwise as permitted by law.

DeakinCo. may share your personal information with other units of the University if your credential is part of a pathway into Deakin, but otherwise does not provide your personal information to any third party without your consent unless required by law.

Communications from DeakinCo. will contain an unsubscribe function with which you can ask to receive no further communications.

Prospective Students

Deakin University collects and uses personal information about its prospective students. Your information may be collected by any means, including hard copy, electronic or verbal means. Deakin will, where practicable, collect your information directly from you.

Your personal information is used for the primary purpose of staying connected with you, providing you with services, promote future events, news and course information. Deakin may also use your personal information to assist with planning and quality assurance, to invite you to participate in surveys and research, to comply with legislative reporting requirements, and as permitted or required by law.

For these purposes, Deakin may share your personal information with other areas of the University but otherwise does not provide your personal information to any third party without your consent unless required by law.

In the case of individuals located in China, by submitting an enquiry you consent to Deakin using your personal information to respond to your enquiry and we will not otherwise contact you without your consent.

Individuals applying for admission to Deakin

When you apply to Deakin, we collect information from you directly and also from relevant third parties, including referees, secondary schools, tertiary admission and testing centres and other education providers.

This information is used primarily to assess your eligibility for admission into Deakin and selection for specific courses. If your application is successful, your information will be used to offer you a place in a course and to administer your acceptance or refusal of that place.

You should also expect Deakin to use your information to:

  • provide you with information related to your application for admission (e.g. about fees, scholarships, equity and access entry programs, course requirements, housing and accommodation)
  • offer you advice and access to student services prior to your enrolment
  • determine your eligibility for scholarships, bursaries or similar awards
  • provide information on additional opportunities for studying at Deakin
  • help us with marketing and fundraising initiatives
  • conduct planning and quality assessment activities
  • invite you to participate in surveys or research.

As part of the selection process, Deakin will disclose your personal information to the extent necessary to verify your qualifications or experience. On admission, the personal information collected in the application process will form part of your student record and will be managed in accordance with Deakin's Privacy Policy.

Use of contracted service providers

Deakin engages consultants and contractors to provide it with services. Contracted service providers are bound by contract to:

  • use personal information provided by Deakin only for the performance of the contracted service
  • to have in place administrative and technical measures to keep the personal information secure
  • to protect personal information from unauthorised access, use, disclosure, modification or deletion.

Deakin discloses personal information to its consultants and contractors only to the extent required by them to provide the contracted service.

Your use of services provided by a third party may also be governed by that third party’s terms of service and privacy policy. Deakin encourages you to review these before using those services. See, for example, Deakin’s YouTube Channel for more information about YouTube’s Terms of ServiceGoogle’s Privacy Policy and Google’s Security Settings. 

By accessing and viewing content on our channels via API, users acknowledge and agree to be bound by these terms of services, privacy policy and security settings. It's important to note that the information collected by third party service providers, such as usage data and personal information, is governed by their policies and depends on how users utilise their services and manage privacy controls.

Access to information by third parties

Deakin does not provide personal information about its staff and students to third parties, other than its contracted service providers, unless we're satisfied that:

  • the disclosure is authorised under relevant privacy legislation
  • the associated staff member or student has given their consent
  • it is required by law to disclose information.

If privacy legislation authorises Deakin to disclose information, we will assess the request on a case-by-case basis and will use our discretion to determine whether to disclose information. Deakin is not legally obligated to disclose personal information when authorised to do so.

Guidance on frequently encountered requests for disclosure of personal information is below.

Parents of students

Deakin frequently receives requests from parents to confirm that their child is attending classes or making good academic progress. We are unable to provide personal information about students to their parents unless the student has given their explicit consent. This is regardless of whether the student in question is under 18 or if the parent is paying their fees and/or expenses.

A student can give their consent by emailing the Division of Student Administration, using their Deakin email account, ensuring that the information below is included.

  • Student ID number
  • Given name/Surname
  • Date of birth

I give permission to Deakin University to disclose information pertaining to my student record to:

  • Given name/Surname
  • Third-party individual's date of birth
  • Relationship to student
  • Duration of consent (please specify 'ongoing' or end date in 'DDMMYY' format)

This includes information relating to (remove options that are not applicable):

  • All information relating to my student record
  • Academic details; enrolment and results
  • Financial details; tuition fees
  • Collection of Academic transcript/ Letters
Search warrants, subpoenas and informal requests for information

Deakin releases information when legally required to do so. Search warrants, subpoenas and court orders should be served on:

General Counsel
Office of General Counsel
Deakin University
Geelong Waterfront Campus
1 Gheringhap Street
Geelong VIC 3220

Informal request for information must also be addressed to the Office of General Counsel or privacy@deakin.edu.au and must:

  • be in writing, contain the agency’s name, address and contact details
  • if sent by email, from an email address clearly linked to the organisation or agency
  • set out the basis upon which authorisation for release of the information is claimed
  • specify what information is required and why it is needed.
Employers and recruitment agencies

Prospective employers and recruitment agencies often seek to verify that a student has received an award (a degree, graduate certificate or graduate diploma) from Deakin.

To facilitate this, Deakin maintains GradSearch, an online qualification verification tool. To search for a graduate, two search items from the following list must be provided: surname / date of birth / student ID. Please note that GradSearch does not provide a full transcript of results.

Unsubscribe requests

To unsubscribe from Deakin publications or mailing lists, please contact the following.

Freedom of information

Requests for access to, and correction of personal information are managed under the Freedom of Information Act 1982 (Vic). To make a FOI request, please visit Freedom of Information.

Complaints

If you believe that Deakin has engaged in an act which constitutes an interference with your privacy, you can make a complaint to the University. Complaints must be made within six months of the time that the complainant first became aware of the alleged breach.

A complaint should contain full details of how the individual believes their privacy has been breached, including a thorough description, with names and dates if known. Details of the complaint will be disclosed to the relevant operational unit of the University and/or persons named in the complaint, so that it can be investigated and handled fairly. Details may also be disclosed to others that Deakin believes has information relevant to the complaint. Complaints from individuals who are neither staff nor students of Deakin are investigated and managed pursuant to Deakin's Privacy Policy.

Complaints should be directed as follows:

Email
privacy@deakin.edu.au

Mail
Office of General Counsel
Deakin University
Geelong Waterfront Campus
1 Gheringhap Street
Geelong VIC 3220

Contact details and further information

Enquiries about the management of personal information at Deakin should be directed to:

Email
privacy@deakin.edu.au

Mail
Office of General Counsel
Deakin University
1 Gheringhap Street
Geelong VIC 3220

Links
Deakin University Privacy Policy
Privacy and Data Protection Act 2014 (Vic)
Health Records Act 2001 (Vic)
Office of the Victorian Information Commissioner
Office of the Victorian Health Complaints Commissioner

Keypath Education Australia Pty Ltd Privacy Policy (“Privacy Policy”)

Last updated: June 28 2023

Deakin University (“University”) partners with Keypath Education Australia Pty Ltd (who we refer to, together with our related bodies corporate[1], as “Keypath”, “Keypath Group”, “us”, “we”, or “our”, depending on the context) to support the University with the supply of select online courses. We provide Services such as course recruitment and marketing, as well as student support for the duration of a student’s enrolment (“Services”). The performance of these Services requires the collection and use of Personal Information (as defined under ‘What we mean by “Personal Information”’ below) and the sharing of that information by and between Keypath and the University. Keypath and the University respect your privacy and take seriously the privacy and security of Personal Information.

This Privacy Policy explains:

  • what Personal Information we collect, how we collect that Personal Information, and how we use that Personal Information;
  • when and with whom we may share the Personal Information we collect; and
  • your choices and rights regarding your Personal Information.

This Privacy Policy applies to the Personal Information we collect, including through any sites (such as websites, apps or social network sites) that link to this Privacy Policy (referred to collectively as “Site”), as well as through any other contact you have with Keypath including through, or on behalf of the University, in connection with the Keypath-supported online educational courses they offer (referred to generally as a “Course” or the “Courses”). 

In addition, the University’s Privacy Policy will also be applicable to any dealings with your Personal Information by the University.

We will always deal with your Personal Information in accordance with all relevant laws, including the Privacy Act 1988 (Cth).

If you do not agree with the terms of this Privacy Policy and would prefer that we do not collect, use, or share your Personal Information as we describe, then you should not submit any Personal Information to us, including through a Site, or otherwise provide us with any of your Personal Information.

Unless otherwise required by law, and where practicable, you can choose to remain anonymous or to use a pseudonym when communicating with us. Please note that if we are unable to collect Personal Information from or about you, it may be difficult or impossible for you to access Services through a Site, for us to be able to respond to your requests or enquiries, or for us to engage in other dealings with you. For example, you may not be able to enrol in or complete a Course. However, it is your choice whether you want to interact with us and the University, enrol in Courses, and/or participate in online learning through the University and your interactions with us and the Site.

COLLECTION AND USE OF PERSONAL INFORMATION

A. What We Mean By “Personal Information”.

“Personal Information” is information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Different states, countries, and laws define Personal Information (or similar terms, such as “personally identifiable information” and “personal data”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the internet protocol (IP) address of your computer or mobile device, if that IP address can be linked to you from specific information we handle, or other information (such as other Personal Information accessible to us, or geo-location information) that can be used to ultimately identify you.

B. The Kinds of Personal Information That We Collect and Hold, and How We Collect It.

The kinds of Personal Information we collect and hold about you depends on the nature of your dealings with us and the circumstances of collection. For example:

  • we may collect your name, telephone number, email address and other information you choose to provide to us, if you decide to contact us through a “Contact Us”, “Request More Information”, or similar links on a Site, or if you otherwise request information about the University or about the Courses, units and other services we and they offer, including via subsequent telephone, electronic voice, or text communications with our representatives;
  • if you apply for enrolment in a Course, or if you sign up to receive newsletters or other materials, we may collect your name, email address, and any other information you include with your submission, or that we or the University require to make a determination on your suitability for enrolment in the Course; and
  • if you participate in a Course, we will obtain Personal Information from you so that we and the University are able to provide you with the services that you have signed up to receive, as well as to seek your feedback as to your experience in regard to the Course and the services received.

If you deal with us in some other capacity, we may collect your name and contact details and any other information you choose to provide to us. Other categories and examples of the types of Personal Information we collect are set out under “The Purposes For Which We Collect, Hold, Use and Disclose Personal Information” below.

We may collect sensitive information (such as health information) in limited circumstances (as described in more detail below under "The Purposes For Which We Collect, Hold, Use and Disclose Personal Information”), and we will only collect sensitive information about you as required to deliver the Services (unless we are otherwise required or authorised by or under law to do so).

If you are or have been our employee, the handling of your Personal Information may be exempt from the Australian Privacy Principles if it is directly related to your employment relationship with us.

In addition, a Site may automatically collect certain information from you when you visit it, such as your IP address or other unique identifier of your computer or other device, and information about the browsing history and website, app or social media interactions associated with that device. This device and online activity information may be considered Personal Information where it could be used to ultimately identify you (for example, where information held is able to be linked with other accessible information that could ultimately identify you). However, we will not use this type of automatically collected information to identify or to contact you, unless and until you voluntarily provide other Personal Information to us in the manner outlined above (such as via a “Request More Information” form). More information about how we use this information on an anonymous, de-identified and/or aggregate basis is described below under “How We Collect and Use Non-Personal Information”.

C. The Purposes For Which We Collect, Hold, Use and Disclose Personal Information.

We routinely collect Personal Information for the purpose of providing our Services, in order for the University to provide its services to you in relation to a Course, and for our other business functions and activities, including:

1. Personal Information We Collect Directly

The Personal Information you may be asked to provide to us, and the purpose for which we collect, hold, use and disclose that Personal Information, may include the categories described below.

In addition to the purposes specified in the table below, we also collect Personal Information so that we can operate our business and provide Services to you, and others, as described further below under "Personal Information We Obtain From Third Parties" and "Certain Generally Applicable Uses of Personal Information."

We present this information based on the categories of Personal Information collected, but please note that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Contact Information,” “Communication, Activity and Marketing Information,” and “Educational History Information” categories described below.

Category of Personal Information

Our Purpose For Collecting, Using And Disclosing Your Personal Information

Contact Information

Examples:

  • Full name
  • Email address
  • Phone number
  • Address/Location
  • Contact preferences
  • The reason for your contact (i.e., the details of your inquiry or request- if the request contains information that can be used to identify you)

We collect this information as necessary for us to provide Services, and for the University to provide information you have requested or enter into or perform a contract with you.

For example, we may need this information to:

  • Verify your identity.
  • To help us identify you.
  • To communicate with you, and to provide you with information and Services you have requested.
  • To provide relevant information to you, or upon your request, to assist you with enrolment in a Course, and to support and facilitate flexible online learning.
  • Subject to your right to opt out, to market to you by email or other electronic means.

Communication, Activity and Marketing Information

Examples:

  • Contact Information
  • Email communications
  • Text (SMS) communications
  • Phone conversations/recordings
  • Appointment requests, dates and status
  • Adviser notes
  • Public posts made by you
  • Testimonials and opinions
  • Images

We collect this information as necessary for us to provide the Services to you, or for the University to enter into and/or perform a contract with you, as well as to communicate with you. For example, we may need to provide you with information about Courses you have enroled in.

Where required by law, we will obtain your consent to collect this information (such as to use your image in photos and videos).

We use and disclose the Personal Information to:

  • Utilise this information to prepare materials for the purposes of marketing the Course and the University.
  • Allow you to participate in interactive areas of a Site, such as participating in discussion forums or providing comments to others’ posts.
  • Ensure the quality of our Services and interactions with you.
  • Provide you with information and Services you have requested.
  • Assist you with enrolment in Courses and to support and facilitate flexible online learning.
  • Subject to your right to opt out, to market to you by email or other electronic means.

Personal/Demographic Information

Examples:

  • Contact Information
  • Educational History Information
  • Employment History Information
  • Age/age range
  • Currency
  • Languages
  • Nationality
  • Gender
  • Religious affiliation
  • Racial/Ethnic background

We collect this information as necessary for us to provide the Services and for the University to communicate or enter into or perform a contract with you. For example, we may need this information to verify your identity and application information, as well as your eligibility for the Course.

In relation to sensitive information (such as your racial or ethnic origin), we will only collect this information as required to deliver the Services (unless we are otherwise required or authorised by or under law to do so). 

We use and disclose the Personal Information to:

  • Ensure the quality and suitability of our Services and interactions with you.
  • Respond to and/or address your requests and inquiries, and/or to provide requested information to you.
  • Assist you with the enrolment in Courses and to support and facilitate flexible online learning.

Educational History Information

Examples:

  • Contact Information
  • Education level
  • Degrees held, prior Universities attended, transfer credits
  • Reasons for study
  • English proficiency test information
  • Prior assessment information
  • Transcripts

Employment History Information

Examples:

  • Contact information
  • Previous and current employer(s), job title, and employment status

We collect this information as necessary for us to perform the Services, or for the University to communicate or enter into or perform a contract with you. For example, we may need this information to verify your identity and application information, your eligibility for the Course and any credits for prior study, and the University will require Personal Information of this nature to process your application and enrolment.

We use and disclose the Personal Information to:

  • provide you with information about the University, Course(s), you may be interested in or that may be of interest based on your indicated preferences.
  • respond to your inquiries regarding the University, and its Course(s), including your suitability for the Course.
  • support you with your application and enrolment in Courses and to support and facilitate flexible online learning.

Course Financial Support Status and Related Information

Examples:

  • HECS status and eligibility for Commonwealth Supported Places (CSP);
  • FEE-HELP status; or
  • any other scholarship or other financial-support or financial standing status, that we and/or the University need to be aware of in order to appropriately review any application or enrolment, and to administer the Course and related Services on an ongoing basis.

We collect this information as necessary for the University to enter into or perform a contract with you and for us to provide the Services. For example, this information can be required to verify your identity and application information, your suitability for the Course, and to process your application and enrolment.

We use and disclose the Personal Information to:

  • provide you with information about the University Course(s) you may be interested in or that may be of interest based on your indicated preferences.
  • respond to your inquiries regarding the University and its Course(s).
  • support you with the application and enrolment in Courses and to support and facilitate flexible online learning.

University Course Information

Examples:

  • Contact Information
  • Application Information
  • Application status
  • Reasons for study
  • Risk factors for completing the Course(s) such as academic, financial, personal, or technical issues.
  • Preferred Course(s)
  • Course eligibility and prerequisite information
  • Planned enrolment dates and details
  • Course(s) admission and acceptance status
  • The number of Course(s) you enrol in
  • Course registration details, dates, status, and outcome
  • Official student enrolment details, dates, status and outcome(s)
  • Evaluation, assessment, course and classroom participation and activity details
  • Degree path plans

We collect this information as necessary for us to perform the Services and for the University to enter into and perform a contract with you. For example, your information may be required to verify your identity and application information, to process your application for entry into the Course, and to facilitate your enrolment and ongoing participation in the Course.

In relation to sensitive information (such as health information), we will only collect this information where necessary to perform the Services, unless we are otherwise required or authorised by or under law to do so.

On behalf of the University, to provide you with information and Services you have requested from the University.

We use and disclose the Personal Information to:

  • Support you with the enrolment in Courses and to support and facilitate flexible online learning.
  • Respond to and/or address your requests and inquiries, and/or to provide requested information to you, including information that has been requested by a third party.

Application Information

Examples:

  • Contact Information
  • Personal/Demographic Information
  • Educational History Information
  • Employment History Information
  • Financial Aid-Related Information
  • Other identifiers (e.g., government-issued ID numbers)
  • Special needs information related to a disability
  • Letters of recommendation
  • Criminal history/convictions

We collect this information as necessary for the University to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information, to assess your suitability for a particular Course, and to process your application and enrolment.

In relation to sensitive information (such as certain demographic information), we will only collect this information about you where required to perform the Services, unless we are otherwise required or authorised by or under law to do so.

We use and disclose the Personal Information to:

  • Support you with the application process and enrolment in Courses and to support and facilitate flexible online learning.
2. Personal Information We Obtain From Third Parties

As noted above, we collect some Personal Information from third parties, including Personal Information that has been provided to us from the University, in order that we can perform our Services in relation to the Course.

3. Certain Generally Applicable Uses of Personal Information

The Personal Information we collect directly from you and from third parties may be used for additional purposes related to the operation of our business and our provision of Services, including:

  • our and the University’s internal record-keeping;
  • to enable us or the University to contact you by e-mail, text or phone for any of the above stated reasons;
  • where necessary as part of any restructuring of the Keypath Group;
  • for compliance with legal, regulatory, and other good governance obligations;
  • to convert Personal Information into pseudonymous and/or de-identified data, and to use it (normally on an aggregated statistical basis) for research and analysis;
  • to gain insight that enables us and the University to measure the effectiveness of our Services; and
  • to learn about potential and current students, their interests, needs, and resources applicable to the Courses so that we can improve the Courses and provide you and others with better and targeted service offerings by tailoring our marketing messages to your and their specific interests, needs, and abilities. This may include by undertaking remarketing or other targeted marketing activity or building a ‘lookalike audience’ on social media platforms to better direct our marketing messaging.

When we use your Personal Information for our business purposes, those business purposes include working with the University to make Courses available, responding to your, other students’ and potential students’ queries or complaints, marketing the University’s products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.

D. How Long We Keep Personal Information.

We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law or by contract. For example, we will keep Personal Information for at least as long as you continue to be enroled in any Course, and, if any Site allows you to create an account, we will keep the Personal Information associated with your account for as long as you maintain it. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.

All applicant, enrolment, and student details will be kept for at least as long as we continue to provide Services to the University, unless we agree otherwise with the University. Once we cease to have a relationship with the University, our practice is to de-identify (or otherwise destroy) all Personal Information we have collected in the course of that relationship.

It is important to note that some Personal Information that we collect may be made public. For example, with your consent, we may use your image and testimonials in promotional materials for the University. In these circumstances, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In addition, we or the University may make available services that enable you to post information on a Site in public forums and on message boards. In these cases, once posted, the information will be able to be seen and republished by others for as long as that web page remains active. Even if web pages, apps or platforms are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area of a Site.

How We Collect and Use Non-Personal Information.
A. What Is Non-Personal Information?

Non-Personal Information refers to information that is not and cannot be used to identify a specific individual, or is Personal Information that has been de-identified so that it is no longer about an identifiable individual, or an individual who is reasonably identifiable. This may include information about the statistical characteristics of the visitors to a Site or persons who enrol in Courses. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used to specifically identify you. This section describes how we collect and use non-Personal Information.

B. The Non-Personal Information We Collect and Why.

When you visit a Site or interact with us electronically (such as through email), we may automatically collect standard internet and website log information, and details of patterns about how you behave. This information includes your internet service provider name, your operating system, your browser type and browser language, the IP address of your computer or other device (unless such IP address can be used to identify you), your access times, whether you opened email correspondence from us, any links that you visit from those emails, the website that referred you to a Site, the specific web pages you visit and the date and time of those visits, and links clicked as you visit a Site.

We use this information to evaluate our Services, a Site (including to find out which parts of a Site are popular or may need improvement), to inform and evaluate marketing efforts, and to enhance your and others’ experiences with us, the University and a Site. 

C. Cookies and Other Tracking Technologies.

A Site, such as the Course website, utilizes “cookies”, which are anonymous identifiers and other tracking technologies such as web beacons, and which enable us to distinguish you from other users and provide you with information that is customized for you, including to show you promotions on other third-party platforms. For more information, see the “Cookies Policy” section of this Privacy Policy. 

D. Analytics Services.

A Site, such as the Course website, may use analytics tools and Services to collect information about your use of the Site, such as how often you visit the Site, what pages you visit, and what other sites you used prior to visiting the Site. We use the information we collect from these analytics Services to maintain and improve the Site and our and the University’s Services, to provide a better user experience, and to inform and evaluate our marketing efforts. The analytics Services we use include Google Analytics, Facebook Ads, and others. 

E. Sharing Non-Personal Information.

We may use or disclose non-personal, aggregate, anonymous information to third parties (such as the third party service providers we engage in order to improve the Site and our and the University’s Services), and to market research firms.

COOKIES POLICY

A. What Are Cookies?

Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing when you visit a website. Some cookies are deleted once you close your browser or application (session cookies), while other cookies are retained even after you exit so that you can be recognized when you return (persistent cookies). Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

B. How We Use Cookies.

We use both session and persistent cookies on a Site. The cookies we use are generally divided into the following categories:

  • Mandatory cookies: These are cookies that are required for the effective navigation of all areas of the Site.
  • Functional cookies: These are cookies that remember choices that you make when you visit the Site such as language options. They help to make your visit more personal and assist your navigation of a Site.
  • Analytics/Marketing cookies: These are cookies that automatically collect information about your use of a Site, such as the pages you visit, and the links you followed. These help us recognize previous visitors to the Site, understand how many people are using the Site, and how they navigate through it. As mentioned above, we use analytics Services to analyze user behavior, so these third parties will place these types of cookies on the Site, please see ‘Third Party Cookies’ below for further information.
C. Your Choices About Cookies.

Web browsers may automatically accept cookies, but you can usually change your settings to prevent that, such as by having your device warn you each time a cookie is being sent or choosing to turn off all cookies. On a Site, you will be able to disable all cookies other than mandatory cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. There are also online resources that may help you learn more how to opt out of targeted behavioral advertising from many major third-party network advertisers.

If you do disable cookies from your browser you may not be able to access certain sections of a Site that use mandatory cookies, and this may make your experiences on the Site less efficient.

D. Third Party Cookies

We may allow third parties to use analytics/marketing cookies on a Site in order for those third parties to provide their Services to us. These Services may include the provision of website analytics (for example, from Google Analytics) and marketing and promotional Services (such as those provided by Google Ads and Facebook). These third parties may use the information gathered by those cookies to assist us with personalizing content, providing a better user experience and for targeted advertising.

E. Do Not Track Requests.

Currently, certain browsers, including Firefox, Google Chrome, Safari and Microsoft Edge, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. However, we do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

HOW WE MAY SHARE INFORMATION

A. Sharing Information with the University.

We collect, use, and process your Personal Information on behalf of the University, and accordingly, it will be shared with the University for all purposes consistent with this Privacy Policy, including to process applications and enrolment materials and to fulfill our contractual relationship with the University. In addition, we may also collect and share your Personal Information with the University so that we can collaborate with them for the purpose of undertaking research, and to develop, deploy, and deliver additional Courses and online programs, and to facilitate flexible online learning.

Please note that we have no control over how the University uses Personal Information and other information we share with them. You are reminded that the University has its own Privacy Policy, and their collection and use of your Personal Information is subject to the terms of that policy.

B. Sharing Information with Others.

We may share information with other third parties in the following circumstances:

  • We share your information, including Personal Information with the University in order to administer your enrolment in the Course and to otherwise provide the Services to the University and you.
  • We may share your information, including Personal Information, so that we or others may provide you with periodic communications in connection with the University’s Courses, or may contact you regarding products, services, or events of the University. If you do not wish for us to share your information in this manner, please let us know by contacting us at cst@keypathedu.com.
  • We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide Services to you. For example, such third parties may handle our data management and/or email distribution. Unless we tell you differently, those third parties do not have any right to use your Personal Information beyond what is necessary to assist us.
  • We may share information, including Personal Information, with our corporate affiliates in the Keypath Group for the potential expansion and promotion of product and service offerings for the University, and other uses consistent with the purposes described in this Privacy Policy.
  • We may share your Personal Information with your employer, if your employer is paying for your enrolment in a Course and/or unit.
  • We will share Personal Information with third parties for other purposes if we have your express “opt-in” consent to do so.
  • We may disclose non-personal, aggregate, anonymous data for our legitimate business purposes.
  • We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.
  • We may disclose Personal Information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us or the University, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.
  • We may share information, including Personal Information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may also disclose your Personal Information to third parties for other purposes where we are required or authorised by or under law to do so (including where you have provided your consent). We will never sell your Personal Information.

C. Sharing Information to Recipients Outside Australia.

Other companies in the Keypath Group and some of our service providers are located outside of Australia. As a result, Personal Information collected and held by us may be disclosed to recipients in other countries, including recipients located in the United States, the United Kingdom, Malaysia, Singapore, Israel, Japan and Canada.

SOCIAL NETWORK PLATFORMS, SHARING FEATURES AND THIRD-PARTY WEBSITES

We, or a Site may offer social network and similar sharing features, such as Facebook, Twitter, Instagram, and YouTube buttons, which let you share information related to a Site, the University, and/or the Course(s) you enrol in, through your preferred social network site. In addition, a Site may include links to other third party websites.

Further, if you provide your Personal Information to us via a social network (for example, by completing a “Contact Us”, “Request More Information”, or similar form in-app), your Personal Information will be collected by us (via our account on the relevant social network), and by the social network. 

The social network sites, and the third parties’ use of any data that may be collected by those sites, are not governed by this Privacy Policy. You should always review the privacy policies of any site you visit before submitting your Personal Information.

If you permit a connection between a Site and your social network page(s) or another third-party site, or you otherwise provide us with Personal Information via a social network platform, we (and the social network itself) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network or other third-party site, the information you share may be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks and other third-party sites once it is provided to them, you should review the privacy policies of those social networks and other third party sites.

How We Hold Your Personal Information and Our Security Measures.

We use a variety of industry-standard security measures to maintain the safety of your Personal Information, including measures designed to secure your Personal Information from accidental loss and from unauthorised access, use, alteration and disclosure. We store the Personal Information you provide on secure (password- and firewall-protected) servers.

Unfortunately, no electronic data transmission over the internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect Personal Information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us.

If any portion of a Site allows you to create an account, it will be your responsibility to keep your account and password confidential. We will never ask for your password (except, if applicable, when you create your account and log into the Site).

YOUR RIGHTS REGARDING YOUR INFORMATION

A. General Rights to Access, Correct and Remove Personal Information.

If you have any questions regarding this Privacy Policy or our use of your Personal Information, you can contact us by email at cst@keypathedu.com. In addition, you can also contact us at any time at cst@keypathedu.com to request access to the Personal Information that we hold about you, or to otherwise request that we make any corrections to your Personal Information. If, where applicable, you have an account on a Site, you can access and edit your account information online, by signing into your account on a Site and selecting the information you want to edit.

As noted above, we have standard retention practices with respect to the Personal Information we collect. If you would like to request any earlier removal of your Personal Information, please contact us at cst@keypathedu.com. Please note that we may not be able to completely remove Personal Information from the Site or our systems in certain circumstances. This will be true if the data is not in a searchable format, if it is retained in backup systems or cached or archived pages, if we need it to prevent fraud or future abuse, or if we are required by law to keep it.

B. Your Rights Regarding Direct Marketing.

As noted above in this Privacy Policy, we may use your Personal Information to provide you with marketing and promotional information about our and the University’s products and Services. These promotions may be made by mail, email, telephone, instant messaging application, or text (SMS) message, or other methods that may become relevant or available. All promotional materials that are sent by electronic means will include a simple method for you to stop receiving further communications. For example, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will subsequently be able to change your mind at any time.

Your consent will be deemed if you do not opt out when we offer you the opportunity to do so, and will remain current until you advise us otherwise. You can manage your consent preferences with respect to direct marketing activities by contacting us at cst@keypathedu.com. Please note that despite your email preferences, we may need to contact you regarding your enrolment with the University, as required by law, or regarding legal matters. However, we will not send you targeted marketing communications if you have opted out of receiving them.

A NOTE ABOUT CHILDREN

The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 15. If you are a parent or a legal guardian who believes that your minor child has provided us with any Personal Information, please contact us at cst@keypathedu.com.

CONTACT US

Please contact us (at cst@keypathedu.com) if you have any questions, or if you otherwise have any concerns or complaints about the manner in which we have handled your Personal Information. We will inquire into your complaint and respond to you in writing within 30 days. If we don’t respond to your complaint within 30 days, or if you are otherwise not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. Any modifications will be effective when the changes are posted to a Site. You can review the most current version of this Privacy Policy at any time by accessing the section of a Site labeled “Privacy Policy”, and you can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. You are expected to check this Privacy Policy from time to time to take notice of any changes. 

[1] As defined in section 50, Corporations Act 2001 (Cth).