We, ISP Eduworld Pty Ltd. (ABN: 67641732729) having registered office address at 55 Junction Street, Nowra NSW, 2541 (we, us and when relating to us, our) provide educational related services, products, offerings and support by partnering with various educational institutions around the globe.
We are committed to protecting privacy rights and personal data of our contacts, students, partners, suppliers, and employees (you and when relating to you, your) and complying with the Privacy Act 1988 (Cth), UK Data Protection Act 2018, and E.U. General Data Protection Regulation 2016/679 (Privacy Laws).
We take ‘personal data’ to mean any such information about you, including but not limited to your name, address, email address, telephone, personal identification number (such as passport number, driving licenses, social security number), birthdate, place of birth, parents name, photographs of your face, health data, economic data, location data, device ID, IP addresses and cookies. Further, ‘sensitive personal data’ means and refers to a specific subset of personal data that includes but not limited to, for e.g., your race, origin, ethnicity, sexual orientation, gender, health data, economic data, disabilities.
In this policy we describe how we manage your personal data.
1. Our privacy principles
- Purpose Limitation: We only collect personal data about you for the specific, explicit, and legitimate purposes listed in this policy. We do not process your personal data for any other purposes.
- Data Minimisation: We only collect personal data that is adequate, relevant, and limited to what we need for the purpose for which we collect your data.
- Lawfulness, Fairness, and Transparency: We process your personal data lawfully, fairly and in a transparent manner.
- Integrity and Confidentiality: We take technical and organisational measures to ensure that personal data is adequately protected.
- Accountability: We demonstrably comply with our obligations for protecting personal data.
- Storage Limitation: We only keep your personal data for as long as it is necessary for the purpose for which we collected it.
- Accuracies: We take every reasonable step to ensure that the personal data we collect is accurate and kept up-to-date and give you every opportunity to rectify or erase any inaccuracies.
2. What personal data we collect
The kinds of personal data that we collect depends on the relationship we have with you:
- contact details such as name, role or position, address, email address, mobile number, landline number and fax number, ;
- data relating to your circumstances and affairs relevant to the matter/s in which we are instructed;
- data about your interests and requirements and the services, products, offerings or supports that you may wish to avail from us;
- data regarding our communications with you and your attendance at seminars and promotional events held by us;
- if you are a student, data about your nationality, insurance status, residency status, employment status, civil status, educational background, work experience, student loan status, photo identification such as passport, driving licenses, social security number, academic certificates, diplomas, personal statements, references, resume, and another information as required on a case to case basis. We also collect and process sensitive personal data such as nationality, ethnic origin, health data, disability and marital status of yours for the purpose of assisting you with any eligibility checks for academics or financing.
- if you are an employee or prospective employee, data about your qualifications, skills and work experience, certifications, skills, reference information, salary expectations, work permit/visa requirements and any other relevant information, national identity card, passport, settlement status, proof of address in order to verify your legal right to work in the country; and
- if you are a supplier or prospective supplier or business partner, data about your business skills, services, products, prices, and business interests, payment information, conflict checks and credit references; and
- if you are general public visiting our website, we may collect name, phone number, email address, postal address for any queries that you post through ‘Contact Us’ option on our website.
- When providing names and contact information of third-party references in connection with availing our services or applying for a position with us, you represent that you have obtained permission from your references to provide us with their personal data.
3. How we collect personal data
We will collect your personal data directly from you whenever you interact with us. We do not collect your data from third-party sources, however, we may have collected data about you from a third party such as a client, an agent or a third party information provider.
3.1 We collect personal data by various means including when:
- you contact us with a question or inquiry about the Global Freshman Certificate or any other services, products, offering or support;
- you make an application to study at the Global Freshman Certificate or the DANSUS preparation module at Arden University or with any such partner from time to time;
- you make an inquiry about or become a Closed Loop Recruitment Member University;
- you subscribe to our newsletter or updates service;
- you attend a seminar or event where we are hosting or presenting;
- you visit our website.
3.2 If you do not provide us with accurate personal data we may not be able to answer your inquiry or achieve the purpose for which the data has been sought.
4. Our role
- For the purposes of processing your personal data, we act as both a Data Controller and a Data Processor, depending on the nature and purpose of each processing operation that we carry out using your personal data.
- For the purposes of our marketing and recruitment operations, we acts as a “Data Controller”. We also act in this capacity in connection with third-party vendors we may engage in conducting our business, as well as members of the general public who contact us through any channel with questions about our company, services or for any other purpose. This means that in all these cases, we decide whether and how to process your personal data, depending on the nature of our relationship with you and the purpose(s) for which your data is necessary in this context.
- For the purposes of providing our education consulting and placement services to you, we acts as a “Data Processor”, meaning that we process your personal data in accordance with your instructions as our client, and as determined by educational and financial institutions’ application processes in their capacity as “Data Controllers”.
5. Purposes for which we collect, hold, use and disclose personal data
5.1 The purposes for which we collect, hold and use your personal data varies depending on the type of relationship that you have with us, such as if you are a student, client, website user, recruitment candidate, business partner, supplier or vendor. We only collect and use your personal data when there is a fair and lawful basis for each processing operation, such as when we need to collect and use your data to enter into a contract with you, when we have your valid consent, or a legitimate interest of ours. Where we rely on legitimate interest to process your personal data, we will specifically detail the nature of the interest we are pursuing.
5.2 We collect, hold, and use personal data in order to:
- respond to your enquiries;
- provide our services;
- employ competent and diligent personnel;
- monitor or improve the use of and satisfaction with our international education related services; and
- let you know about developments and services that may be of interest to you.
5.3 We disclose personal data:
- in order to carry out your requests for services from us; and
- subject to our confidentiality obligations, when using support services which assist us to deliver our services.
5.4 Individual Consent: We also process personal data about our clients for the purposes of providing them with our expert, education consulting and placement services. We may also use their contact information to distribute promotional material about our company and its products and services. In these cases, we process personal data relying on individuals’ permission to collect and further process their data. Please note that once you have provided us with consent to process your personal data for any of these purposes, you have the right and opportunity to withdraw your consent at any time by contacting us.
5.5 Contractual Relationship: We process personal data about our business partners, third-party vendors and suppliers, recruitment candidates, and members of the general public for the purposes of entering into a contractual arrangement with them, or providing information requested by them with a view to entering into a contract with them. In all these cases, we rely on the necessity of processing your data for the purpose of entering into a contractual relationship with you.
5.6 Balancing test: In most of the cases where we rely on our legitimate interests to process your personal data, we balance the necessity of each processing operation against your interests, rights, and freedoms. In doing so, we consider the following factors:
- The nature of our relationship with you;
- Whether your data is particularly sensitive or private;
- Whether you would expect us to use your data in this way;
- Whether you are likely to object to our processing or find it intrusive;
- The possible impact of our processing on you;
- Whether the data processed involves children;
- Whether you belong to a category of vulnerable individuals;
- Whether we can adopt safeguards to minimize the impact of our processing on you; and
- Any opportunity we may have to offer you a chance to opt-out of this processing.
5.7 If you do not provide us with your personal data we may not be able to provide you with our services, communicate with you or respond to your enquiries.
6. The parties to whom your personal data is disclosed
6.1 Subject to our confidentiality obligations and in exceptional cases, we may share some relevant personal data with:
- parties whether within Australia or outside related to an enquiry, request or application you have with us, including service providers as reasonably required by us;
- our e-mail marketing provider for the purposes of providing you our newsletter and updates; and
- third party service providers who assist us with archival, auditing, accounting, legal, business consulting, website or technology services.
6.2 We also will disclose your data if required by law to do so or in circumstances permitted by the Privacy Laws – for example, where we have reasonable grounds to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been is being or may be engaged in, in response to a subpoena, discovery request or a court order.
7. Disclosure of data outside the jurisdiction of collection
7.1 Some of the third parties described above including our service providers and related bodies corporate may be located in other countries, including but not limited to the United Kingdom, United States or in European Union.
7.2 Opting out of marketing communications: We may, from time to time, send you newsletters, invitations and updates about our services, products and offerings. You can opt out of receiving further such communications by notifying us using our contact details below by clicking the “unsubscribe” option at the bottom of any marketing e-mail received from us.
8.1 We take reasonable physical, technical and administrative safeguards to protect your personal data from misuse, interference, loss, and unauthorised access, modification and disclosure. For example, we maintain our files in secure offices and limit access to personal data to individuals with a need to know. We do not unnecessarily hold on to, and securely dispose of your personal data records after the purpose of collecting them has been fulfilled.
8.2 We will delete or block your personal data after the applicable retention periods under the Privacy Laws, unless you authorise us to keep it, or when it is necessary to enforce our agreements or resolve disputes. These storage terms apply unless agreed otherwise in a contract with us or in applicable legislation.
9. Access/Correction/Updating personal data
9.1 You may access or request correction of the personal data that we hold about you by contacting us. As per the applicable Privacy Laws, we are committed to facilitate the exercise of your following privacy rights:
- Right to Information about whether, what, and how we process personal data about you;
- Right to Access a copy of the personal data that we hold about you;
- Data Portability gives you the right to request us to provide a copy of your data to a third-party, instead of yourself, such as when you would like to change service providers;
- Restriction of Processing, which allows you to request us to stop specific processing operations, or all processing operations using your personal data altogether;
- Permanent erasure, meaning that you can request us to permanently erase your personal data from our records;
- Right to Object and Withdraw Consent to Processing at Any Time, means that you can object to specific processing operations and withdraw any consent that you have previously provided us with to process your personal data, in which case all processing operations based on consent must stop. For example, we only send you marketing communications with your consent. You have the right to unsubscribe from our marketing campaigns at any time by using the ‘Unsubscribe’ facility that we provide with each communication.
- Right to Complain to Data Protection Authorities, should you feel concerned about our data protection practices and/or unsatisfied with our response to you.
9.2 Unless we are subject to confidentiality obligation or some other restriction on giving access to the data and we are permitted to refuse you access under the Privacy Law, we will endeavour to make your data available to you within 30 days. Examples of circumstances where we may refuse to give you access to your personal data include where:
- giving access would be unlawful;
- we reasonably believe that giving you access would pose a serious threat to the life, health or safety of any individual or to public health or public safety;
- giving access would have an unreasonable impact on the privacy of others;
- the data could reveal the intentions of a party in negotiations;
- giving access could prejudice the taking of appropriate action in relation to unlawful activity;
- giving access could reveal evaluative data in a commercially sensitive decision making process.
9.3 If you request to correct your personal data, we will correct, or, if we consider more appropriate, note your request for amendment of the data on your record.
9.4 We will not charge you to make a request to access your record but we may charge you to actually provide access depending on the costs associated with obtaining and providing the material.
9.5 These actions can usually be taken by contacting a customer relations representative using the contact information on the “Contact Us” section below.
10. Notification of changes
11. Complaints / Contact us
Attention: Privacy Officer
We will endeavour to respond to any complaint within 30 days. If you are not satisfied with our response to your complaint you may seek a review by contacting: