1. Introduction

Apollo Villages Early Learning (“Apollo Villages”, “we”, “us” or “our”) owns and operates early learning and childcare centres in Queensland, including Apollo Villages Burpengary and Apollo Villages Redcliffe, together with the website apollovillages.com.au.

We are committed to protecting the privacy of the children, families, employees and other individuals we work with. This Privacy Policy explains how we collect, hold, use and disclose personal information, and how you can access and correct your information or make a privacy complaint.

We manage personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), the Australian Privacy Principles (“APPs”), the Information Privacy Act 2009 (Qld), where applicable, the Education and Care Services National Law and National Regulations, and the Family Assistance Law governing the Child Care Subsidy (“CCS”).

2. What Personal Information We Collect

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. We only collect personal information that is reasonably necessary for, or directly related to, our functions and activities as an approved education and care service provider.

2.1 Information about parents, guardians and family members

• Name, residential and postal address, email address and telephone numbers
• Date of birth, Customer Reference Number (CRN) and other details required by Services Australia for Child Care Subsidy purposes
• Occupation, employer details and emergency contact details
• Banking, billing and payment information, including direct debit details
• Details of authorised nominees who may collect your child or be contacted in an emergency
• Court orders, parenting orders or parenting plans relevant to your child’s care and custody arrangements
• Communications you have with us, including enquiries, waitlist registrations, feedback and complaints

2.2 Information about children

• Name, date of birth, gender, residential address and CRN
• Health information, including medical conditions, allergies, dietary requirements, immunisation status, medication details, and details of your child’s doctor and Medicare number
• Developmental, behavioural and educational information, including observations, learning documentation, photographs and videos collected as part of our educational program
• Information about cultural background, language spoken at home and whether the child identifies as Aboriginal or Torres Strait Islander (where you choose to provide it)
• Incident, injury, trauma and illness records as required under the Education and Care Services National Regulations

2.3 Sensitive information

Some of the information we collect (such as health information, immunisation records, cultural background and religious beliefs) is “sensitive information” under the Privacy Act. We will only collect sensitive information with your consent, or where the collection is required or authorised by law (for example, under the Education and Care Services National Regulations or public health legislation). If you do not wish to provide certain sensitive information, please speak with our centre director, who can explain why the information is sought and any consequences of not providing it, which may include limits on the services we can safely provide.

2.4 Job applicants, employees and contractors

If you apply to work with us, we may collect your contact details, resume, qualifications, employment history, referee reports, Working with Children Check (Blue Card) details, teacher registration details, criminal history information and right-to-work documentation. Employee records of current and former employees are generally exempt from the Privacy Act but are handled confidentially.

3. How We Collect Personal Information

Where reasonable and practicable, we collect personal information directly from you. We may collect information:

• Through waitlist registrations, enrolment forms and enrolment agreements
• In person at our centres, by telephone, email or post
• Through our website, including enquiry forms, waitlist forms and tour bookings
• Through childcare management software and family communication apps used by our centres
• Through CCTV and security systems operating at our centres (where installed), and visitor sign-in records
• From third parties where permitted by law, such as Services Australia, government departments, health professionals, other education and care services, or your authorised nominees

If we receive personal information we did not solicit, we will determine whether we could have lawfully collected it. If not, we will destroy or de-identify the information as soon as practicable, where it is lawful and reasonable to do so.

4. Why We Collect, Hold and Use Personal Information

We collect, hold and use personal information to:

• Process waitlist applications, enrolments and orientation
• Provide education and care to your child, including developing and documenting their learning program under the Early Years Learning Framework
• Keep children safe, including managing medical conditions, allergies, dietary needs, medication administration, emergencies, and custody or court order arrangements
• Administer the Child Care Subsidy and meet our obligations under Family Assistance Law, including submitting attendance and enrolment information to the Australian Government
• Manage fees, billing, direct debits and debt recovery
• Communicate with you about your child’s day, learning and development, centre events and operational matters
• Comply with our legal obligations under the Education and Care Services National Law and Regulations, child protection laws, public health requirements and workplace laws
• Recruit, train and manage our employees, contractors and volunteers
• Improve our services, handle feedback and complaints, and conduct quality assurance
• With your consent, send you newsletters, updates and marketing about our services (you may opt out at any time)

5. Photographs and Images of Children

Photographs and videos of children are taken as part of documenting children’s learning and are shared with families through learning portfolios and our family communication app. We will seek your consent through the enrolment process before using images of your child, and separate consent before using any image of your child in external marketing, on our website or on social media. You may withdraw your consent at any time by contacting your centre director.

6. Who We Disclose Personal Information To

We only disclose personal information for the purpose for which it was collected, a related secondary purpose you would reasonably expect, with your consent, or where required or authorised by law. We may disclose personal information to:

• Australian Government agencies, including the Department of Education and Services Australia, for Child Care Subsidy administration and compliance
• Regulatory authorities, including the Queensland Department of Education (Early Childhood Regulatory Authority) and the Australian Children’s Education and Care Quality Authority (ACECQA)
• Child protection and law enforcement agencies, where we are required to report under child protection laws or otherwise required or authorised by law
• Health professionals and emergency services, where necessary to protect the health, safety or welfare of your child
• Service providers, who assist us in operating our business, such as childcare management software providers, family communication apps, IT and cloud hosting providers, payment processors, debt collection agencies, insurers, and professional advisers (such as lawyers, accountants and auditors)
• Schools and other education and care services, with your consent, to support your child’s transition

Our service providers are only permitted to use personal information to perform services on our behalf and are required to keep it secure and confidential.

6.1 Overseas disclosure

Some of our service providers (for example, cloud-based software platforms) may store or process data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with the Australian Privacy Principles. [Insert details of relevant countries once service providers are confirmed.]

7. How We Hold and Protect Personal Information

We hold personal information in paper records at our centres and in electronic form, including in secure childcare management systems and cloud-based platforms. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure, including:

• Secure storage of paper records and restricted access to administration areas
• Password protection, access controls and user authentication for electronic systems
• Staff training on privacy and confidentiality obligations
• Engaging reputable service providers with appropriate security practices

We retain records for the periods required by law. Under the Education and Care Services National Regulations and Family Assistance Law, certain records about children (including incident records) must be kept for specified periods, in some cases until the child is 25 years of age. When personal information is no longer required and we are not legally obliged to retain it, we take reasonable steps to destroy or de-identify it securely.

7.1 Data breaches

We comply with the Notifiable Data Breaches scheme under the Privacy Act. If a data breach occurs that is likely to result in serious harm to individuals, we will notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

8. Our Website, Cookies and Online Communications

When you visit apollovillages.com.au, we and our analytics providers may collect information such as your IP address, browser type, device information, pages visited and the date and time of your visit. This information is used to operate, secure and improve our website.

Our website uses cookies and similar technologies to improve your browsing experience and analyse site traffic. You can configure your browser to refuse cookies, although some parts of the website may not function fully as a result. Our website may contain links to third-party websites; we are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

If you subscribe to our waitlist, newsletter or updates, we will use your contact details to send you the information you have requested. Every marketing communication will include an option to unsubscribe, or you may opt out at any time by contacting us.

9. Anonymity and Pseudonymity

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym, for example when making a general enquiry about our centres. However, we cannot enrol a child or provide education and care services without identifying information, as this is required by law.

10. Accessing and Correcting Your Personal Information

You may request access to the personal information we hold about you or your child by contacting your centre director or using the contact details below. We will respond within a reasonable period and provide access in the manner you request where reasonable and practicable. In limited circumstances permitted by the Privacy Act, we may refuse access (for example, where access would unreasonably impact the privacy of others or is restricted by a court order); if so, we will give you written reasons.

We take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. Please let us know promptly if your details change, particularly emergency contacts, health information and custody arrangements. If you believe information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to correct it and we will take reasonable steps to do so.

11. Privacy Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us using the details below. We take privacy complaints seriously and will acknowledge your complaint promptly, investigate it, and respond to you, generally within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

12. Changes to This Policy

We review this Privacy Policy regularly and may update it from time to time to reflect changes in our practices, technology or the law. The current version will always be available on our website at apollovillages.com.au and at our centres on request. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions about this Privacy Policy or how we handle personal information, please contact:

Privacy Officer

Apollo Villages Early Learning