Last Updated: 22 July 2019
This policy has been drafted having regard to New Horizons’s obligations under the Privacy Act 1988 (including the National Privacy Principles)
(the Privacy Act).
1.1 New Horizons will only collect personal information where the information is necessary for New Horizons to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 New Horizons collects personal information for the primary purpose of course registrations. New Horizons also collects and uses personal information for secondary purposes including:
- Print and digital marketing
- Testimonials and reviews
- Direct marketing
- Event registrations and attendance
- Monitoring and analyzing trends, usage, and activities in connection with the use of our site
1.3 New Horizons will notify individuals of the matters listed below at the time of collecting any personal information:
- The main reason that we are collecting personal information (this reason will be the primary purpose);
- Other related uses or disclosures that we may make of the personal information (secondary purposes);
- Our identity and how individuals can contact us, if this is not obvious;
- How individuals can access the personal information that New Horizons holds about them;
- That individuals should contact New Horizons (even if they are not a customer or an employee of a customer) if they wish to access or correct personal information collected by us or have any concerns in relation to personal information;
- The organisations or types of organisations to whom we usually disclose the personal information;
- Where applicable, any law that requires the personal information to be collected;
- The consequences (if any) for the individual if all or part of the personal information is not provided to New Horizons.
1.4 Where it is not practicable for New Horizons to notify individuals of all of the collection information before the collection of personal information, New Horizons will ensure that individuals are notified of the collection information as soon as possible after the collection. New Horizons will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.
1.5 New Horizons will not collect sensitive information from individuals except with express consent from the individual and only where it is necessary for New Horizons to collect such information for an activity or function.
1.6 New Horizons will not collect personal information secretly or in an underhanded way. For transparency, this is how New Horizons automates the processing of data:
- We automatically collect certain information to track visitor activity on our websites. We use this information to improve the content of our sites as well as to provide visitors with a more relevant overall experience with our organization and our site.
- This information may include information that identifies you as an individual or relates to an identifiable individual, including: name, title, company name, job function, expertise, postal address, telephone number, or email address.
- We may also collect other information that does not reveal your specific identity or does not directly relate to an identifiable individual such as browser and device information, information collected through cookies, pixel tags, and other technologies, and demographic information.
- We never share this information or information you provide us with third parties except to the extent necessary to provide our Service. See section 4. Disclosure.
- If you fill out a web form on our site, your information will be stored in our CRM system and some amount of your past browsing on our site may be available to us to determine your interests. We may use this information to more effectively engage with you and improve our site. However, if you use private browsing as described below, you may provide us your information without making your past browsing activity available to us. If you do not wish for us to have your personal information, please do not fill out any of the web forms on this site.
- If you provide your email address and consent, some information is collected about when/if the email was opened and what links were clicked. This information is used to assess the engagement and success of an email campaign. Clicking on a link in any of these emails may cause you to be personally identified on our site and may cause some part of your past browsing history on our site to be available to our personnel so we may more effectively engage with you and improve our site.
- If you do not wish for this tracking to occur, you can unsubscribe from our mailings or use private browsing mode to avoid tracking.
- If you do not want this site to place a cookie on your browser and track your activity, you may leave the site, or you may browse the site using privacy mode in your web browser. To learn how to use privacy mode, refer to the links below depending on the browser you use.
- InPrivate mode in Microsoft Edge
- Incognito mode in Google Chrome
- Private browsing mode in Mozilla FireFox
- Private browsing mode in Apple Safari
2.1 New Horizons will obtain an individual’s consent for use of non-sensitive personal information for secondary purposes at the time of collection, unless the use is a related secondary purpose which would be within the relevant individual’s reasonable expectations.
2.2 New Horizons uses personal information primarily for the purposes listed in 1.2 above.
2.3 If New Horizons relies on the direct marketing exception to direct market to individuals it will ensure that:
- Individuals are clearly notified of their right to 'opt out' from further direct marketing; and
- If the individual opts out of all direct marketing, the opt out will be respected by New Horizons and implemented free of charge.
2.4 New Horizons will not use sensitive information for direct marketing.
2.5 New Horizons may use personal information to avoid an imminent threat to a person’s life or to public safety. It may also use personal information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 New Horizons will not use personal information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.7 New Horizons will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.
3.1 New Horizons may disclose personal information to related or unrelated third parties only if consent has been obtained from the individual.
3.2 New Horizons may disclose personal information to unrelated third parties to enable outsourcing of functions where that disclosure or use is for a related secondary purpose and has been notified to individuals or where such disclosure is within the individual’s reasonable expectations.
3.3 New Horizons will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the use and disclosure requirements of the Privacy Act.
3.4 In the rare event that New Horizons is required to disclose personal information to law enforcement agencies, government agencies or external advisors, New Horizons will only do so in accordance with the Privacy Act or any other relevant Australian legislation.3.5 New Horizons may disclose personal information to avoid an imminent threat to a person’s life or to public safety.
3.6 If a disclosure is not for a primary purpose; is not for a related secondary purpose; or upfront consent has not been obtained, New Horizons will not disclose personal information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.7 New Horizons does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if the appropriate consent had been given by the individual involved.
4.1 New Horizons will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
5.1 New Horizons requires employees and contractors to perform their duties in a manner that is consistent with New Horizons’ legal responsibilities in relation to privacy.
5.2 New Horizons will take all reasonable steps to ensure that paper and electronic records containing personal information are stored in facilities that are only accessible by people within New Horizons who have a genuine “need to know” as well as “right to know”.
5.3 New Horizons will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6.1 New Horizons will allow its records containing personal information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 New Horizons will correct its records containing personal information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their personal information should do so by contacting New Horizons, as per the details on this document.
6.4 New Horizons will not normally charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 Contact with New Horizons via phone or web inquiry will be the first point of contact for inquiries about privacy issues.
7.2 Any formal privacy related complaints should be directed in writing to the New Horizons Privacy Officer, Level 6 31 Market Street, Sydney NSW 2000.
7.3 New Horizons will endeavour to manage any privacy related complaint efficiently and in a timely manner.
8.1 New Horizons will not make it mandatory for visitors to its web sites to provide personal information unless such personal information is required to answer an inquiry or provide a service. New Horizons may however request visitors to provide personal information voluntarily to New Horizons (for example, as part of a competition or questionnaire).
8.2 New Horizons will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
9.1 New Horizons generally does not send information overseas.
9.2 If personal information must be sent by New Horizons overseas for sound business reasons, New Horizons will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.
- Collection information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their personal information.
- Direct marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of New Horizons or a Related Body Corporate or those of an independent third party organisation.
- Disclosure generally means the release of information outside New Horizons, including under a contract to carry out an “outsourced function”.
- Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
- Primary purpose is the dominant or fundamental reason for information being collected in a particular transaction.
- Reasonable expectation means a reasonable individual’s expectation that their personal information might be used or disclosed for the particular purpose.
- Sensitive information means information or an opinion about an individual’s:
- Racial or ethnic origin; or
- Membership of a political association; or
- Religious beliefs or affiliations; or
- Philosophical beliefs; or
- Membership of a professional or trade association; or
- Membership of a trade union; or
- Sexual preferences or practices; or
- Criminal record; that is also personal information; or
- Health information about an individual; or
- Use means the handling of personal information within New Horizons.
We work closely with partners such as Microsoft and often provide links to their website. Please be aware of the Microsoft Privacy Statement.
Where New Horizons shares data with Microsoft, “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data includes, without limitation, a person’s address, phone number, fax number, email address, government-issued ID numbers, financial information, account numbers, and information associated or combined with Personal Data (such as a personal profile, unique identifier, biometric information, or IP address). If Supplier makes any Personal Data available to Microsoft, Supplier will ensure, to the best of its knowledge and ability, it has complied with all legal requirements and industry standards applicable to the collection, use, sharing, and disclosure of such Personal Data. These requirements include providing the appropriate notices and obtaining necessary consent to share Personal Data with Microsoft, and for Microsoft to receive and use Personal Data for the purposes of contacting individuals about products, services, events or offers. Supplier represents and warrants that the provision of Personal Data to Microsoft will not violate any agreement or obligation between Supplier and a third party and that it will comply with all applicable privacy laws, rules and regulations.
Contacting New Horizons
Address: Level 6, 31 Market Street, Sydney, NSW 2000
Telephone: (02) 8263 5900
Fax: (02) 9279 2240