Overview

Milner International College of English (Milner College) is subject to the Australian Privacy Act 1988 (Cth).

The Privacy Act regulates how private sector entities collect, use, disclose and otherwise handle personal information.

This Privacy Policy outlines how Milner College deals with the personal information we collect. People who deal with Milner College are entitled to expect that any information collected will be treated in accordance with our Australian privacy responsibilities and obligations.

What is personal information?

Personal information includes any information or opinion about an identified individual or an individual who is reasonably identifiable. For further information visit the Office of the Australian Information Commissioner website.

The types of personal information which Milner College collects may include an individual’s name, phone number, email address, address, nationality, date of birth, and educational history. Due to the nature of the services provided by Milner College, some of the information we collect may be sensitive information, including details about an individual’s religion, race or ethnic background. It is not common practice for Milner College to collect information about an individual’s medical history, political opinion, sexual preference or criminal record, unless such information is required in order to process a student’s application for admission, enrolment and education. Milner College will only collect sensitive information with an individual’s consent.

Personal information may be collected by Milner College in a number of circumstances, including when an individual:

• lodges an enquiry through Milner College’s online enquiry service;
• applies for admission to Milner College;
• registers or enrols for a class or course offered by Milner College;
• applies for employment with us.

We generally collect personal information directly from the individual concerned, although there may be occasions when information is collected from third parties, such as a family member who contacts us on the individual’s behalf, from our contractors who supply services to us, through our partner institutions or from a publicly maintained record. If an individual does not provide the information requested by us, we may not be able to provide them with our services.

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, including our identity and how to contact us, the purposes for which we collect personal information, our information disclosure practices, the individual’s right to obtain access to the information we hold about them and the consequences for the individual if the information is not provided. The individual must also provide the consents set out in this Privacy Policy in respect of how Milner College will deal with their personal information.

What other information do we collect?

When you look at the Milner College website, our computers record your visit and log the following anonymous information for statistical purposes:

• the Internet Protocol (IP) address from which we receive the request
• the date and time our server received the request
• the pages, documents and files you requested
• the address of the resource which provided the link followed, if any, to Milner College website
• the type of browser and, in some cases, the operating system used
• in some cases, data you send to our website from web forms (e.g. search terms).

Some sections of Milner College website use standard industry technologies, for example ‘cookies’, to make full use of the site. Milner College uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Milner College will only use and disclose personal information about you that is collected using cookies for other purposes where we have your consent to do so, or as otherwise required or authorised by law.

What do we do with the information?

Milner College collects personal information for the primary purpose of providing our services to individuals. We may also collect personal information for purposes related or ancillary to the primary purpose of collection, including:

• administering and managing the services we provide to prospective and current students, including admissions, enrolment, education, billing, maintaining our information technology systems, customer service and data storage;
• marketing the services of Milner College and its related entities to prospective, current and past students;
• hiring and managing employees and contractors;
• planning, monitoring, evaluating and improving our services, including conducting market research and surveys and assessing customer satisfaction; and
• otherwise communicating with you.

Milner College will only use and disclose personal information about you for the purposes stated above, where we have your consent to do so, or as otherwise required or authorised by law. For example, Milner College centres may need to share student information with partner institutions in the course of providing education classes on the institution’s campuses.

Milner College collects information from other organisations and bodies, including government bodies, in connection with providing services to them or on behalf of them. Information collected in that context may be treated differently from information collected in other contexts. Milner College will comply with any obligations imposed by the organisations and bodies that provided the information under the relevant agreements.

Milner College may from time to time provide information to third party marketing service providers, who represent to be securely handling the information, and that the information is de-identified while under their control.

By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis in order to provide you with marketing information we think would be of interest to you, including by mail, email, SMS and telephone.

Milner College may retain other companies and contractors to provide services for us, including entities located outside Australia, who will need to have access to your personal information to perform their obligations.

Only a limited number of staff has access to the anonymous information collected via the Milner College website. The information is collated for analysis. It is then evaluated and published in reports that show Milner College usage patterns and identify popular areas of the website. This helps us to improve and develop the website and its services.

For security reasons, Milner College uses software programs to monitor network traffic and identify unauthorised attempts to upload or change information, or otherwise cause damage.

What are my rights?

For security reasons, Milner College uses software programs to monitor network traffic and identify unauthorised attempts to upload or change information, or otherwise cause damage.

Under the GDPR your rights are as follows. You can read more about your rights in details here;

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object; and
• the right not to be subject to automated decision-making including profiling.

You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR.

Minors and privacy

When Milner College has knowledge that a person under age 18 is providing personal information to Milner College, we require the person to obtain parental permission and consent for you to provide Milner College with your personal information.

What won’t we do with the information?

Milner College will not disclose or externally publish personal information to third parties who are not related to Milner College with a view to allowing them to direct market their products or services without the relevant individual’s consent.

No attempt will be made to identify individual users of the Milner College website except in the unlikely event of an investigation or legal proceedings, or where otherwise permitted to do so under the Privacy Act.

For example, Milner College will gather more extensive information than stated above in the following circumstances:

• unauthorised attempts to access files other than those published on Milner College website
• unauthorised tampering or interference with files published on Milner College website
• unauthorised attempts by other websites to index the contents of Milner College website
• attempts to intercept messages of other Milner College website users
• communications which are defamatory, abusive, vilify individuals or groups or give rise to a suspicion that an offence is being committed
• attempts to otherwise compromise the security of the Milner College web server, breach the laws of the Commonwealth or a state of Australia, or interfere with the use of the Milner College website by other users.

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal date” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.

Our EMS provider is; MailChimp. We hold the following information about you within our EMS system;

• Email address
• P address
• Subscription time & date
• Name

Is data stored in a secure way?

Milner College has security measures in place to protect against loss, misuse and alteration of information under our control, as required by law and generally accepted industry standards. However, no system is 100% secure and to the extent permitted by law, we exclude any liability in contract, tort or otherwise for any security breach.

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

Do we publish personal information on our website?

Milner College will only publish personal information on our website if it has been collected for this purpose with your knowledge and consent.

When giving such consent you should be aware that information published on our website is accessible to millions of users from all over the world, that it will be indexed by search engines and that it may be copied and used by any web user. This means that once the information is published on our website, Milner College will have no control over its subsequent use and disclosure.

Names and email addresses of Milner College staff appearing on our website are provided with their knowledge and consent.

Under no circumstances will Milner College sell or receive payment for licensing or disclosing your personal information.

What about external links?

This site contains links to other sites. Milner College is not responsible for the privacy practices or the content of such websites.

Can I access and correct my personal information?

You have the right to access your personal information held by Milner College on request, subject to limited exceptions in the Privacy Act. We will deal with your request within a reasonable time. We may recover from you our reasonable cost of providing you with access.

Milner College will take reasonable steps to ensure your personal information is accurate, complete and up-to-date. Should you wish to access or amend this information, or complain about a breach of the Privacy Act, please contact Milner College’ Privacy Contact Officer as follows:

Milner International College of English

1^st Floor, 379 Hay Street

Perth WA 6000

Email: general@milner.wa.edu.au

We will make all reasonable attempts to respond to your complaints or requests.

If you are not satisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner at:

Website: www.oaic.gov.au

Phone: 1300 363 992

Further information about the application of privacy law to the private sector generally can be found by contacting the Office of the Australian Information Commissioner (details above).

If you no longer wish to receive any communications, or want to be removed from any Milner College database, please contact the service identified on the relevant feature page, or Milner College’s Privacy Contact Officer on the details set out above.