Privacy Policy

This Privacy Policy applies specifically to the Education Services Australia's service, Literacy Hub. Any reference to Education Services Australia in this Privacy Policy is also a reference to Literacy Hub. The general Privacy Policy for ESA is available here.

Education Services Australia Limited (ABN 18 0073 424 21) on behalf of its service, Literacy Hub (ESA, we, us or our) is committed to protecting the privacy of Personal Information. This Privacy Policy explains how ESA collects and uses your Personal Information for the Literacy Hub and the rights and options you have in this respect. In doing so ESA complies with its obligations to protect the privacy of Personal Information under the Australian Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

ESA delivers a number of products and services in relation to education systems and sectors (related entities). This Privacy Policy applies to the use of your Personal Information by the Literacy Hub. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. A reference in this Privacy Policy to ESA, we, us or our is also a reference to the Literacy Hub.

In this Privacy Policy, ‘you’ or ‘your’ refers to the individual reading this Privacy Policy or those people whose personal information ESA collects, uses and discloses in accordance with this Privacy Policy.

1. What is personal information?

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

2. What personal information does ESA collect?

a) When a school teacher registers to use the Phonics Check on the Website, ESA collects the school teacher’s:

first and last names;
email address; and
school name (including the Australian Curriculum, Assessment and Reporting Authority (ACARA) school identifier), sector, state, address and postcode/suburb).

b) When a school teacher registers a school student to use the Phonic Check on the Website, ESA collects the school student’s:

first name;
last name (optional);
student ID (optional); and
Phonics Check evaluation.

c) When a school administrator registers their school to use the Phonics Check on the Website, ESA collects their:

first and last names;
email address; and
school name (including the ACARA school identifier), sector, state, address and postcode/suburb).

d) When a school teacher or system administrator accesses the Phonics Check via Single Sign On (Single Sign On enables relevant users to gain access to the Phonics Check without having to register), when first connecting to the Phonics Check, a user record will automatically be created for the user. The user record will include the user’s name and email address (provided by the relevant school/jurisdiction (Identity Provider)).

e) When you choose to register on the Website to receive a newsletter via email ESA collects your:

first name,
email address; and
whether they are a educational professional or parent or carer.

Usage statistics or patterns obtained from tracking the level and range of interest in the Website are collected in order to improve the Website.

3. How does ESA collect your personal information?

ESA may collect your personal information when:

you register on the Website to use the Phonics Check (only available to Australian school teachers) and/or receive newsletters;
a teacher registers you (a school student) on the Website;
you (a school teacher) use Single Sign On;
you browse, make an enquiry or otherwise interact with ESA, for example, via the Website or by telephoning or emailing the ESA help desk;
when you provide feedback to us;
when you visit a premises from which we operate;
when you otherwise contact us by telephone, email, social media, post or in person; or
when we are otherwise required or authorised by law to do so.

Sometimes ESA collects your personal information from a third party for example, ESA may collect your Student ID from ACARA or an individual school in order to enable a smooth integration of the Phonics Check observations data into existing school systems or from a relevant jurisdiction in order to enable Single Sign On.

4. Third party Personal Information provided to us

If you provide Personal Information to us about someone else, you must ensure that you are entitled to disclose that Personal Information to us and that, without us taking any further steps, we may collect, use and disclose that Personal Information as described in this Privacy Policy. In particular, you must ensure that the individual concerned is aware of and acknowledges this Privacy Policy and our collection statement.

5. Remaining anonymous or using a pseudonym: are you required to provide personal information?

Where it is not impractical or unlawful, you may interact with ESA without identifying yourself or using a pseudonym. As a general principle, you provide ESA with your personal information voluntarily and there are no detrimental effects for you if you choose not to consent or to provide personal information.

School students are registered to use the Phonics Check on the Website by their school teacher or a relevant school administrator. The school student registration process allows for the option to use a pseudonym for a school student and/or to only provide a first name without the addition of a last name or Student ID.

However, in order to register and use the Phonics Check, if you are a school teacher or school administrator, you are unable to remain anonymous or to use a pseudonym. ESA requires you to provide the information specified in section 2 above in order to associate school administrators and school teachers to schools and to the extent relevant, to enable Single Sign On.

6. Information collected via our Website

Personal Information may be collected by us and by our third party service providers who assist us in operating our website at literacyhub.edu.au (the Website).

We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this section 6.

Click Stream Data

When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.

Cookies
Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

Cookies may also be used for other purposes on our Website.

Google Analytics
We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

7. Handling of personal information

7.1 Use of your personal information

We use the Personal Information we collect about you for Literacy Hub’s functions and activities, in order to operate Literacy Hub efficiently and to market our products and services. We may collect, hold and use your Personal Information:

to facilitate and support the function and activities of our internal business units and related entities;
to provide services or things you have requested, for example being able to use the Phonics Check on the Website by creating user accounts, for school teachers to run reports and to send newsletters to registered recipients;
to identify and communicate with you about your account (including about any updates to the Phonics Check);
to communicate with you through the channel you have approved to keep you up to date on our latest products and services such as through newsletters as well as updates to Phonics Check;
to provide you with information about customer surveys, marketing campaigns, market analysis, contests or other promotional activities or events;
for compliance with ESA’s legal obligations (such as record keeping obligations);
for insurance purposes;
for monitoring and assessing compliance with ESA’s policies and standards;
to comply with ESA’s legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
to comply with court orders and exercises and/or defend ESA’s legal rights; and
for any purpose related and/or ancillary to any of the above or any other purpose for which your personal information was provided to ESA.

ESA will only communicate with you (not school students) via email during the process of registration for the Phonics Check.

We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

in accordance with this Privacy Policy or any agreement you enter into with us, or
required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

7.2 Disclosure of your personal information

We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in section 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties.

We may also disclose your Personal Information to:

your nominated representatives;
ESA's related entities, internal divisions, business units or departments;
other organisations who assist us in providing products and services to you;
professional service providers and advisors who perform functions on our behalf, such as lawyers;
representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development); and
Government, regulatory authorities and other organisations as required or authorised by law.

We may also disclose your Personal Information to our Website host in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

Otherwise, ESA will only use or disclose your personal information as described in this Privacy Policy, when you direct ESA or give ESA permission or when ESA is required by applicable law or regulations to do so.

7.3 Interstate and Overseas disclosures

Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

(a) our offices or related entities are overseas

(b) we outsource certain activities overseas

(d) our computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

In particular, your Personal Information may be disclosed to third parties located in the UK, EU and EEA and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

7.4 Other uses and disclosures

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.

7.5 Marketing

You consent to us using your Personal Information for sending you information, including promotional material and surveys about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of email messages.

If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

(a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or

(b) contacting us using the contact details specified in section 11.

8. Accessing, correcting and deleting Personal Information

ESA endeavours to ensure that the Personal Information that it holds is accurate, up-to-date, complete and relevant. If you want to know what, if any, Personal Information ESA hold about you, or wish to correct any Personal Information ESA may hold about you, you may access this information by contacting ESA using the contact information in section 11.

ESA may allow access to, make your requested changes to or delete your personal information unless otherwise required or permitted by law. ESA will notify you of the basis for any denial of access to your personal information.

When personal information is no longer required, ESA takes reasonable steps to de-identify, securely destroy or delete such personal information.

9. Security of your personal information

ESA takes reasonable steps to protect the personal information that it holds against misuse, interference, loss, unauthorised access, modification or disclosure by utilising up-to-date electronic and physical security controls that comply with relevant industry standards and guidelines.

If you do not wish to use the internet to transmit personal information you can mail or telephone ESA using the contact information in section 11.

You should also note that if you link to a non-Literacy Hub web page, a different privacy and security statement is likely to apply.

10. How we deal with complaints about Privacy

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in section 11 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

We will notify you of the outcome of our investigation.

11. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

If you have any questions, comments, concerns or complaints about our privacy practices, you can contact us by:

Telephone: +61 3 9207 9600;
Post: Post Office Box 177, Carlton South, Victoria, Australia 3053; or
Email: privacy@esa.edu.au

12. Changes to this Privacy Policy

ESA may make changes to this Privacy Policy from time to time to take account of new laws and technology or changes to ESA’s operation and practices. ESA recommends that you regularly check this Privacy Policy. Any changes will take effect as soon as they are posted on this website. You may obtain a paper copy of this Privacy Policy by contacting ESA via the contact details provided above.