1. Purpose and nature

Holocaust Eduation Australia (HEA) is an educational program for students in Years 9-10 that is accessed by teachers for the purposes of teaching students to learn about the Holocaust and to think critically about the Holcaust’s relevance today, moving beyond just learning the facts.

HEA recognises the importance of your privacy. This Privacy Policy explains how HEA intends to collect, store, use, disclose, protect and otherwise handle your personal information when you are using or engaging with the HEA program, having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy applies to HEA and also its related entities, such as its subsidiaries, and their employees and volunteers. These related entities comply with the same obligations that HEA has to protect your personal information under this Privacy Policy.

2. What is personal information?

Personal information is information or an opinion about you, whether true or not and whether recorded in a material form or not, from which you can be reasonably identified.

3. Why does HEA collect personal information?

HEA will collect personal information for the primary purpose of enabling you to create an account to access the HEA program and to use the materials and modules provided through the HEA program. HEA may also use your personal information for related purposes in connection with providing, administering, improving and personalising the HEA program.

If HEA does not collect your personal information, it may not be able to provide you with access to the HEA program and associated modules and materials.

4. What personal information does HEA collect?

The types of personal information collected by HEA in connection with the HEA program include:

1. names;
2. contact details (including email address, telephone number(s) and other contact details);
3. the capacity in which you will use the website (including whether you are a teacher, school support staff, school counsellor, principal etc);
4. the school or educational organisation you are registering on behalf of;
5. the state/territory in which the school is located; and
6. other information you provide to us.

5. How does HEA collect your personal information?

HEA will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide HEA with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 14).

5.1 Collecting information from you

If it is reasonable and practical to do so, HEA will collect personal information directly from you. For example, HEA will collect your personal information in order to create a teacher account in order to access the HEA program.

Depending on how you choose to interact with HEA in relation to the HEA program, HEA may also collect your personal information from you if you contact, or are contacted by, HEA or its service providers by telephone, by email, through the HEA website, social media and other digital services, or when you complete a form or document and provide it to HEA.

5.2 Collecting information from third parties

HEA may also collect information about you from other people (eg a third party administrator) or independent sources. However, HEA will only do so where it is not reasonable and practicable to collect the information from you directly. Where HEA has collected your information from a third party, such personal information will be held, used and disclosed by HEA in accordance with this Privacy Policy.

5.3 Collecting information from visits to HEA website

When you visit the HEA website, HEA will collect information about how you use and visit the website. For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded and the type of device, browser and operating system you used.

We use and disclose this information in anonymous, aggregated form only for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

5.4 Cookies web beacons and other similar technologies

HEA may also collect information based on how you use its website, including through 'cookies', web beacons and other similar technologies.

Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable the HEA’s systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services. No attempt is made by HEA to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of the HEA's website may not function fully for users that disable cookies.

6.Anonymity/pseudonymity

Where practicable, you may be able to interact with HEA anonymously or by using a pseudonym. Circumstances where it is not practicable, however, include where personal information is required to create an account to access the HEA program or to access the HEA modules and materials, or where you have opted in to be contacted by HEA in relation to the HEA program.

7. How does HEA hold your personal information?

The security of your personal information is important to HEA. Accordingly, HEA takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure and will store all of your personal information securely. This includes using Firebase Storage, a secure Cloud Storage platform to store all personal information. HEA will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.

7.1 Security breach procedures

The HEA’s data security practices have been adopted with a view to protecting the data held by HEA. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, HEA cannot guarantee any transmission will be completely secure.

8. How does HEA use your personal information?

HEA may hold, use or disclose your personal information so that it can provide you with access to the HEA modules and materials through the HEA website and provide any products and services that you request.

CAH may also hold, use or disclose your personal information to:

1. contact you regarding the HEA program, if you have opted in to be contacted by HEA;
2. consider any concern or complaint that you raise against HEA or to manage any legal action between you and HEA;
3. prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; or
4. comply with any relevant laws, regulations, codes of practice and court orders.

8.1 Direct Marketing

HEA may also use your personal information to send you marketing communications about the HEA program, if you have opted in to receive such materials. At any time, you may opt out of receiving direct marketing communications from HEA. To do so, you may click on the opt out link within an email, or by contacting the person in clause 12.

9. How is personal information disclosed to others?

HEA does not sell, rent or trade personal information to, or with third parties including any third parties who are overseas.

The HEA website may contain certain links to other websites. HEA does not share your personal information with those websites and it is not responsible for the privacy practices applying in respect of those websites.

10. How is the quality of personal information maintained?

HEA takes all reasonable steps to ensure that the personal information it collects is accurate, up-to-date and complete. For example, HEA promptly adds updated information to the relevant existing records and, where appropriate, will remind individuals to update their personal information if they are contacted by HEA in accordance with this Privacy Policy.

11. How you may access or correct your personal information

You may contact HEA to request access to the personal information it holds about you at any time. You may also ask HEA to correct information about you that you may believe is inaccurate, incomplete or out of date.

Please contact HEA using the contact details set out in clause 13. HEA will need to verify your identity before giving you access to, or correcting, your personal information. HEA will respond to the request within a reasonable period after the request is made.

In certain circumstances, HEA may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, HEA will write to you to explain the reasons why this is the case.

12. How you may complain if you have concerns about how HEA has managed your personal information

If you have a complaint related to how HEA has managed your personal information, please contact HEA using the contact details set out in clause 13. HEA may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.

HEA will provide you with an estimated response timeframe in relation to your complaint. In any event, HEA will endeavour to respond to your complaint within 30 days. If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.

13. How to contact us

If you have any questions about this Privacy Policy or HEA's management of your personal information, please contact HEA on:

Attention: Jeremy Kalbstein

Email: contact@holocausteducation.org.au

14. Changes to HEA privacy policy and information handling practices

This Privacy Policy is subject to change at any time, so we encourage you to review this Privacy Policy at regular intervals. If HEA changes this Privacy Policy an updated version will be posted on the HEA website to notify you of this change. By continuing to use the HEA program after that time you will be deemed to have accepted any changes to this Privacy Policy.