1. General

1.1 Introduction

South Australian Tertiary Admissions Centre Limited ACN 613 691 526 (SATAC, we, us or our) collects, uses and discloses Personal Information for the purpose of carrying out its functions and activities.  

We collect Personal Information from individuals (you/your) who interact with us, including individuals (Applicants) who apply (or who have applied in the past) for enrolment with our participating universities and vocational and higher education providers (Institutions) and individuals who use our services and/or our website and online services (Online Services) such as mySATAC, Schools Web and Members Only Web. 

We recognise the importance to all individuals who interact with us of having their Personal Information protected and we are committed to collecting, using and disclosing Personal Information in accordance with this Privacy Policy and applicable law (including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs)).

In this Privacy Policy, the terms Personal Information and Sensitive Information have the meanings given to them in the Privacy Act. 

1.2 Obtaining a copy of this Privacy Policy

This Privacy Policy is available (including as a downloadable PDF file) free of charge on our website: www.satac.edu.au. Where we receive a request to provide a copy of this Privacy Policy in a different format, we will take reasonable steps to comply with such a request.

1.3 Updates to this Privacy Policy

We will review and update this Privacy Policy regularly and post updated versions on our website. We will take reasonable steps to notify you of such updates when they occur. 

2. Collection of Personal Information

2.1 SATAC functions and activities

Our core function is to process and assess applications made by Applicants for tertiary education courses on behalf of our participating Institutions.  We undertake a number of functions and activities necessary to fulfil this responsibility, including:
(a)     assessing the academic qualifications of Applicants and other information relating to admissions pathways according to rules and guidelines established by our participating Institutions; 
(b)     assessing the eligibility of Applicants for equity scholarships which may be offered by our participating Institutions;  
(c)     providing information to our participating Institutions regarding suitable Applicants for each course according to instructions from our participating Institutions; 
(d)     communicating offers to Applicants on behalf of our participating Institutions, based on instructions from our participating Institutions; and
(e)     dealing with enquiries from Applicants relating to application and assessment processes. 

2.2 Purpose for collection of Personal Information

(a)     We may collect your Personal Information to enable us to carry out the functions and activities in Item 2.1 (and other related activities) including to: 
(1)     provide you with access to our website and Online Services; 
(2)     identify you and create a profile containing your academic records and other information relating to admissions pathways (to enable us to process any applications that you may make with our participating Institutions);
(3)     understand your requirements;
(4)     assess and administer applications you make;
(5)     answer queries made by you and provide you with support;
(6)     manage, administer and improve our services and systems, including by participating in or undertaking research activities that relate to SATAC’s functions or activities, or to the development of public policy regarding tertiary admission, education and training;
(7)     inform our participating Institutions to which you have applied that you have authority to enrol;
(8)     communicate offers to you on behalf of our participating Institutions and inform you of other services or courses that may assist or interest you; 
(9)     provide information to your school regarding the courses you have applied for, offers that have been made to you and offers that have been accepted by you;
(10)   conduct appropriate checks and keep your information up to date; and 
(11)   comply with legislative and regulatory requirements. 
(b)     We only collect Personal Information if it is reasonably necessary for us to carry out the above functions and activities, or as required by law.  
(c)     We only collect Personal Information that is Sensitive Information as required or permitted by law, or with your consent where it is reasonably necessary for such information to be collected for us to carry out one or more of the above functions and activities. 

2.3 Types of Personal Information we collect

(a)     We may collect the following types of Personal Information about you when we are carrying out the functions and activities specified above:
(1)     your:  
(A)     contact details and identification information (name, address, telephone number, email address and date of birth); 
(B)     Unique Student Identifier and Student Identification Number; 
(C)    citizenship details;
(D)    gender;
(E)     SACE and NTCET (including other year 12 equivalents) and other examination results;
(F)     International Baccalaureate (IB) results;
(G)    Australian Tertiary Admission Rank (ATAR);
(H)    educational results;
(I)      course preferences; 
(2)     details of your proficiency in English;
(3)     information about you which is held by Centrelink or the Department of Veterans Affairs (where you have consented to us doing so as part of your application process); and 
(4)     any other information reasonably necessary for us to process your application and/or carry out our functions or activities and fulfil mandatory reporting requirements. 
(b)     In addition, we may collect certain types of Personal Information about you which is (or may be) Sensitive Information with your consent, when we are carrying out the functions and activities specified above. 
(c)     Some of the information in paragraphs (a) and (b) above is collected because it is required to be reported to the Federal Government by our participating Institutions under applicable law (and therefore collected as part of your application). 

2.4 How we collect Personal Information

(a)     We will obtain Personal Information directly from you except where it is impracticable or unreasonable to do so. We may collect your Personal Information: 
(1)     through your use of our website;
(2)     through your use of our Online Services;
(3)     through any application you make for enrolment with our participating Institutions;
(4)     through our other communications directly with you; 
(5)     where applicable, from any agent which you have appointed for the purpose of submitting an application with us;
(6)     from third parties, including: 
(A)     the SACE Board of SA, the NT Board of Studies, the International Baccalaureate Organisation, our participating Institutions, your school, other education providers, the Australian Council for Educational Research (ACER) and other Australian tertiary admissions bodies; 
(B)     government departments, agencies and statutory bodies; 
(C)    payment platforms and financial institutions which may be utilised by you to make payments to us in connection with their application; and
(D)    platforms such as Facebook or Google, where you use such platforms to login to our Online Services. 
(b)     When users access our website, the web server may log the following information:
(1)     the type of browser and operating system the user is using;
(2)     the address of the referring site (i.e. the site from which the user gained access to our website);
(3)     the date and time of the visit;
(4)     the pages the user accessed and documents downloaded;
(5)     search terms that the user enters when using our search engine; and
(6)     anonymous data through third party tracking and use of cookies.
(c)     This information is only used for statistical analysis and to maintain and improve our customer services and website.  No attempt is made to identify individuals, except in the event of an investigation where a law enforcement agency may exercise a warrant.
(d)     Our website contains links to other websites.  We are not responsible for the privacy practices or the content of such websites and users are advised to refer to the privacy statements of those external websites.

2.5 Logging into our Online Services using third party platforms

(a)     Where you opt to login to or create an account to use mySATAC using a platform such as Facebook, Google or other social platform identity providers, we will collect basic Personal Information about you from that platform, which may include your name, email address, gender, current city and encrypted access credentials. 
(b)     The types of information we collect through such platforms will depend on the permissions you set/ provide on these social platforms to share information with us. 
(c)     You may sever the link between mySATAC and the platform you have used to create or login to your account with mySATAC (such as Facebook, Google or other social platform) by applying the appropriate settings via the relevant platform.

2.6 Unsolicited Personal Information

(a)     From time to time, we may receive unsolicited Personal Information, for example, from schools, the SACE Board of SA, the NT Board of Studies (and its equivalents in other states) or other Australian tertiary admissions bodies.  When we receive such information, we will determine as soon as reasonably practicable whether we could have collected that Personal Information in a manner which complies with Items 2.2(b) and 2.2(c) above if we had solicited the information.  
(b)     If we determine that we could not have collected the Personal Information in a manner which complies with Items 2.2(b) and 2.2(c) above, or if we do not have any lawful purpose to retain such Personal Information that is aligned with our above functions and activities, we will, as soon as practicable (and provided it is lawful and reasonable to do so), destroy the information or ensure the information is deidentified.

2.7 Anonymity and use of pseudonyms

We will permit individuals to interact with us anonymously and/or to use a pseudonym when interacting with us regarding matters of a general nature, however we will require you to identify yourself when creating accounts to use our Online Services, or interacting with us regarding any current or previous application, or your Personal Information. 

3. Use and disclosure of Personal Information

3.1 How do we use or/and disclose Personal Information

(a)     Personal Information collected and held by us will be stored securely and will only be accessed and used by people employed or engaged by us as required in the fulfilment of the functions and activities described above and other purposes which are related to that purpose (or in the case of Sensitive Information directly related to that purpose). 
(b)  In carrying out the functions and activities described above, we may disclose your Personal Information: 
(1)     to your school; 
(2)     to our participating Institutions and to other tertiary admissions centres located within Australia; or 
(3)      to any relevant government department, agency or statutory body or officer (including the Office of the Student Identifiers Registrar) including as required by law. 
(c)     We may also disclose your Personal Information:
(1)      with your written consent; 
(2)     as detailed in Item 3.2 below; 
(3)     to service providers which provide us with cloud-based IT data storage services (solely for the purpose of storing, processing or backing up our data); 
(4)     as we believe is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of an enforcement body; or 
(5)     if a permitted general situation (as defined in the Privacy Act) exists, including: 
(A)     as we believe may be necessary to reduce or avoid a threat to an individual’s life or health and safety or a serious threat to public health and safety and it is unreasonable or impracticable to obtain your consent; 
(B)     as we consider to be appropriate, if we have reason to suspect that unlawful activity or misconduct of a serious nature relating to our functions or activities has been engaged in; 
(C)     as we believe is reasonably necessary to assist with the location of a person who has been reported missing; or
(D)     as we believe is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim or for the purpose of an alternative dispute resolution process. 
(d)     The Personal Information provided to us by you may also be used and disclosed for research and analysis.  Data provided to third parties for research and analysis purposes will be deidentified.  

3.2 Automated decision making

(a)     For some teaching courses, we use a third-party artificial intelligence (AI) platform to assess teaching capabilities statements submitted to us by Applicants. 
(b)     We disclose teaching capabilities statements (which may include Personal Information including your name and identity information to a third-party AI provider which uses AI to review and score such statements based on several set criteria provided by our participating Institutions.

3.3 Overseas disclosures

(a)     As we are an Australian-based company, Personal Information we hold will primarily be collected, stored and used in Australia and disclosed to recipients located in Australia.  From time to time, we may use data back-up, storage and processing services hosted outside of Australia, including services which may be hosted in the United States.
(b)     We will only disclose Personal Information to a third party located overseas (including a data back-up, storage and processing service provider hosted outside of Australia) if: 
(1)     we are reasonably satisfied that the recipient of the information is subject to a law that is substantially similar to the Privacy Act and you have mechanisms available to you to enforce your rights under that law; or 
(2)     we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs (other than APP1) in relation to Personal Information, including by entering into an enforceable contract with such recipient requiring them to comply with such APPs; or 
(3)     if a relevant permitted general situation exists of the kind mentioned in Item 3.1(c) above. 

4. Storage and protection of Personal Information

4.1 How do we protect your data?

(a)     We take reasonable steps to ensure that Personal Information is protected by all reasonable safeguards against loss, unauthorised access, unauthorised use, modification, disclosure or any other misuse.
(b)     We also maintain a Privacy Management Plan to document the types of Personal Information held by us and to create appropriate systems and organisational measures to ensure we manage the Personal Information we hold in accordance with this Privacy Policy, the Privacy Act and the APPs.

4.2 Access to and correction of Personal Information

(a)     You have a right to request access to and the correction of the Personal Information that we hold about you. 
(b)     The primary means of access to and/or correction of your Personal Information is by using our Online Services.  You may also direct requests for access to and/or correction of your Personal Information to our Privacy Officer (see contact details in Item 5 below). 
(c)     Our Privacy Officer will ensure that any requests for access to and/or correction of Personal Information which are not able to be easily resolved through use of our Online Services are dealt with in a reasonable period from receiving the request.
(d)     If a request for correction is accepted, or we are otherwise satisfied that Personal Information held by us is inaccurate, out of date, incomplete, irrelevant or misleading, having regard to the purpose for which it is held, we will take reasonable steps to correct/rectify the information. 
(e)     If we correct Personal Information that we have disclosed to another entity we will, at your request, notify that other entity of the correction/rectification, providing that it is lawful and practicable to do so.

4.3 Request for deletion of Personal Information

You have the right to request the deletion of your personal data in accordance with applicable data protection laws. You can request the deletion of your personal data by contacting: privacy@satac.edu.au. To protect your privacy and ensure the security of your information, we will ask you to verify your identity before processing your request.

A request to amend Personal Information may be refused by us if it is not reasonable in the circumstances to make those corrections, having regard to the purpose for holding the information. For example, requests to correct details on academic qualifications sourced and verified by issuing authorities will typically be refused. In some cases, we may be required by law or for legitimate business purposes to retain certain data. If this applies, we will inform you of the reason we cannot delete your data in full.

4.4 How long do we retain Personal Information?

(a)     We retain Personal Information to support future applications, and to assist with the continuing development of Institution admissions rules and for planning and research purposes.
(b)     SATAC will retain personal information relating to secondary studies and admissions information to enable future applications to our participating institutions. During the period in which we store your Personal Information, it will only be used or disclosed as permitted by Item 3 above.

5. Complaints

Any individual who believes that we have breached any of the Australian Privacy Principles or a registered APP code that binds us may lodge a written complaint to our Privacy Officer. Complaints should be addressed to:
Physical Address:       
Privacy Officer - SATAC
431 King William Street
Adelaide SA 5000

Email Address: privacy@satac.edu.au
SATAC’s Privacy Officer will respond to the complaint within a reasonable timeframe, and according to available resources.