Privacy Policy Website This following document sets forth the Privacy Policy for the SchoolBench and Parashift websites. Parashift is bound by the Privacy Act 1988 (Cth), which sets out a number of principles concerning the privacy of individuals. Collection of your personal information There are many aspects of the site which can be viewed without providing personal information, however, for access some content, you can be required to submit personally identifiable information. This may include but not limited to a unique username and password, or provide sensitive information in the recovery of your lost password. Sharing of your personal information We may occasionally hire other companies to provide services on our behalf, including but not limited to handling customer support enquiries, processing transactions or customer freight shipping. Those companies will be permitted to obtain only the personal information they need to deliver the service. Parashift takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. Use of your personal information For each visitor to reach the site, we expressively collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at this Site. We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are. You can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. We will use the data provided by Google Analytics Demographics and Interest Reporting to develop the site and content around our users' interests. Our websites uses WordPress CMS and cookies are used to store basic data on your interactions. If these are disabled then various functionality on the site may be broken. Some Cookies in use on this Site are supplied by Third Party providers, typically these relate to the sharing buttons across the site allow visitors to share content onto social networks. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. These sites are likely to be collecting information about what you are doing all around the internet, including on this website. Changes to this Privacy Policy Parashift reserves the right to make amendments to this Privacy Policy at any time. If you have objections to the Privacy Policy, you should not access or use the Site. Accessing Your Personal Information You have a right to access your personal information, subject to exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. Parashift reserves the right to charge a fee for searching for, and providing access to, your information on a per request basis. Contacting us Parashift welcomes your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact us by any of the following means during business hours Monday to Friday. Company Privacy Policy Parashift Pty Ltd ACN 163 535 886 (referred to in this Policy as Parashift, we, us, our) is committed to a culture that protects privacy. We will endeavour to protect the personal information we collect, store, disclose and use. This policy outlines the way in which we manage personal information and how you can contact us if you require any further information. In this Policy, 'personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. This Policy is made with regard to the requirements of the Privacy Act 1988 (Cth) (Privacy Act) and accompanying Australian Privacy Principles (APPs). Parashift will manage personal information in a manner that is consistent with these principles as well as community expectations. 1. How we collect personal information Parashift provides software products and services to organisations (including schools) to enable them to upload, collate, manage and distribute visual and documentary content effectively within their organisation (or school community). Those organisations themselves are responsible for operating the software product, and Parashift provide them with technical support services. This means that those organisations are separately responsible for collecting and handling personal information within their organisations via the software provided by Parashift - and Parashift does not generally have access to, collect or hold records of, such information. Notwithstanding the above, from time to time Parashift may collect and hold personal information about current and prospective users of our products and services, employees, contractors, suppliers and other people with whom we come into contact. In general, we will only collect personal information directly from the individual, for example: if they provide to us their information by telephone, post, e-mail or facsimile, or in person; if they contact us via email or submit their information through our website; and/or if they interact with us on any of our social media pages (e.g. Facebook). In limited circumstances, we may collect personal information about individuals from third parties, for example: if their employer or spouse/partner provides us with this information for the purposes of creating or administering a user account; or if an organisation provides us with this information in the context of requesting our technical support services. If you provide us with personal information about a third party, you warrant that that third party consents to us collecting and using their personal information in accordance with this Policy. 2. The types of personal information we collect As noted above, Parashift typically provides software products to organisations without collecting any personal information about individuals within those organisations. However, in limited circumstances, there may be some incidental collection of personal information where Parashift is providing technical support services to the organisation. The types of personal information that Parashift collects about individuals will depend on their relationship and dealings with us. Such personal information may include: identity information (e.g. name, image or date of birth); contact information (e.g. address, email or telephone number); information about their dealings with us (e.g. records of any telephone, email or online interactions with us); and for job applicants or staff, your employment history, educational qualifications, reference checks, payroll information and medical information (where relevant). 3. How we use personal information In general, we will only use and disclose your personal information for the following purposes: to provide our products and services to you; to respond to enquiries and provide you with any information that you have requested; to obtain feedback on our products and services; to provide potential and current clients with news, updates and information about our products and services; to conduct general administrative, business and management functions; to provide the information to third parties (such as our agents, contractors and suppliers) for the above purposes; and provide that information to third parties as required by law. Our use of your personal information may extend beyond these uses, but will be restricted to related purposes that you would reasonably expect, and for other purposes required or authorised by law. Overseas disclosures As at the date of this Policy, we are not likely to disclose personal information to any overseas recipients. If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of applicable privacy laws. Direct Marketing By providing us with your personal information you consent to us communicating directly with you to promote or offer a product or service (Direct Marketing). We use Direct Marketing to provide you with information about products or services that we believe you may be interested in. If you receive Direct Marketing material from us but do not wish to continue receiving it, please contact us by any of the methods set out below, asking to be removed from all future Direct Marketing programs. Once we have received your request, we will remove you from our Direct Marketing programs as soon as reasonably practicable. How we store personal information We take reasonable steps to securely store your personal information to ensure it is protected from loss, misuse or unauthorised access, disclosure, interference or modification. We store your personal information using various methods including, digitally on site and with third party storage providers. All hard copy material is secured using industry accepted methods. All digital material is secured using secure company IT systems. Any digital transfer of personal information is secured using a range of secure methods including but not limited to encryption. We will generally keep personal information as long as we need it for our business purposes or as long as we are required by law to retain it, after which time we will destroy it. Cookies Our website (www.parashift.com.au) may use cookies. A cookie is a piece of information that our web server may send to your computer when you visit the website. The cookie is stored on your machine, but does not identify you or give us any information about your computer. A cookie helps us to recognise when you re-visit the website, and to optimise your experience. You may configure your web browser to refuse or disable cookies. Our website may contain links to other websites. We are not responsible for the privacy practices, use or protection of your personal information on those other websites. We cannot warrant the privacy or security of personal information during transmission to our website. Questions, queries or complaints If you have a question or complaint about our management of your personal information, you can raise it with us by: Emailing contact@parashift.com.au Calling us on 1300 769 809; or Sending a letter to: Level 2, 12 Pirie Street, Adelaide SA 5000. We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious. Amendment This Policy is current as at 2 July 2020. We may amend this Policy from time to time, to ensure that we maintain the highest standards. The date of this Policy will inform you as to whether there have been updates since your last visit. SchoolBench Privacy Policy SchoolBench is software designed to make it easier to process, store and analyse images of students, and distribute them to parents, whilst managing media consent issues. As part of this, SchoolBench provides schools with access to facial recognition technology. However, as schools adopt new technologies to solve day-to-day challenges and make administrative practices more efficient, it is important to ensure that they are adhering to privacy laws and best industry practice, when using this technology. In Australia, the Privacy Act 1988 Cth regulates the handling of personal information by private organisations with an annual turnover exceeding $3 million. Many non-Government schools in Australia fall within its ambit. Importantly: facial recognition technology involves facial biometric matching using an electronic copy of an individual's biometric information; the Privacy Act requires higher levels of protection for biometric information (as a form of sensitive information) than other, more generic types of personal information; and in particular, biometric information can only be collected from an individual with their consent. SchoolBench supports schools to comply with the Privacy Act in a number of ways: 1. The school controls the student's information First, all personal information (including biometric data) is stored on school systems, with both security and access controlled by the school. This means that, no personal information about students (including biometric data) is disclosed to, or collected by, Parashift (the provider of SchoolBench). Parashift only receives system diagnostic information to provide maintenance and support for the software, which does not disclose personal information (including biometric data) collected and store by the school on its IT architecture and systems. That means all personal information (including biometric data) that is collected by a school remains with its internal control at all times. Further, all actions occurring within or via the SchoolBench software is under the users' explicit direction and control (e.g. sharing images to an external album for collaboration, facilitating payments in the SchoolBench Portal). 2. The biometric information captured on SchoolBench is not usable outside of the software As noted above, the SchoolBench software utilises facial recognition technology for the purpose of identifying students by reference to biometric 'markers' of 128 points on their face. The information is stored as a set of numbers and then compared to faces in images for recognition. The biometric information is a series of numbers and not human readable. Therefore, if that information were to be accessed by anyone outside of the licensed SchoolBench user (ie; the school), it would be of minimum to no value. However, further security is also applied as all information within SchoolBench is encrypted at rest using 256-bit encryption. The purpose of facial recognition for SchoolBench is limited to the following: 1. Cataloguing identified students for future searches within the school environment/community; 2. Applying a privacy/media consent to the image of the identified student/s. Importantly, there is no harvesting of any personal information (whether biometric or otherwise) for either commercial or non-commercial use by SchoolBench. Other than the school, no other party has ready access to that information. Parashift's ability to access SchoolBench in the school environment is strictly controlled by the school, and is generally limited to 'administrator' rights to troubleshoot any issues that school's may face when utilising the software package. 3. Change Management and best practice Change Management refers to strategies to achieve the adoption of changes to a system by those affected by the change (in this case, students, parents and school staff). Change management is most successful when those affected receive an explanation of the purpose or benefit of the change as well as the ramifications of not doing it. A school naturally collects personal information (including various kinds of sensitive information) about its students, parents, and others who are part of the school's community. Therefore, the collection of biometric information is not radically different from what the school has likely already been doing. When implementing SchoolBench, the school should notify the community in an upfront and transparent way about what information will be collected, and how it will be used, disclosed and stored by the school going forward. On the one hand, this is done so as to remove the 'surprise' factor which can often lead to more fear, uncertainty and doubt, and it also allows students, parents and others to retain control over how their personal information is used. However, it is also a necessary step to ensure legal compliance with the Privacy Act * so that informed consent can be obtained from students and parents, to the collection of biometric information. When communicating with parents and students about the introduction of SchoolBench, we recommend: 1. noting that facial recognition technology is already widely spread across various industries and areas of life; 2. noting that the school will handle biometric information in compliance with the Privacy Act, along with all other kinds of sensitive information already managed by the school; 3. explaining the purpose for which it is using SchoolBench; that is, it will streamline the process of storing and analysing images in the school environment, so they can be shared with parents and so that media consents can be enforced; 4. communicating what protections exist within the SchoolBench software (as already described above) to facilitate privacy and security of that information; and 5. clearly communicating what options are available if the parent - or student - does not consent to the use of SchoolBench technology to images of them or their child. If you have any further queries about SchoolBench and privacy compliance, please contact Parashift and we will assist you to the extent that is possible. As there are no clear Commonwealth Government resources specifically on facial recognition technology, we recommend the following: Consent to the handling of personal information - Home (oaic.gov.au)
