Harcourts Group (Australia) Pty Ltd ACN 074 304 073 and their related entities (collectively, Harcourts, us, we, our) are committed to protecting the privacy of your personal information.  This policy applies to our business and training facilities in Australia, any registered training organisation (RTO) we operate, the website www.realestatetrainingcentre.com, train.realestatetrainingcentre.com and any other website we operate from time to time.

Harcourts is required to comply with the Privacy Act 1988 (Cth) including the Australian Privacy Principles (APPs) in Australia.

This policy is intended to provide a general overview of how we handle your personal information. It should be read together with any terms and conditions governing your dealings with us or your use of our website, and any location specific legal notice.   By providing your personal information to us you consent to our collection, use and disclosure of your personal information in accordance with this policy and any other arrangements that apply between us.

Collection of your personal information

We only collect personal information where it is necessary for our functions or activities.  We operate a nationally recognised RTO offering training for careers in real estate, along with other training programs related or relevant to real estate, and other services we may offer from time to time (our services). 

The kinds of personal information we collect and hold about you, and our use of that information, is dependent on the services we provide to you.

General enquiries

When you enquire about our services, we will typically collect your name, e-mail address and any other contact details required for us to respond to that enquiry.

Students and potential students

In addition to the above information, when you enrol in a course or program with our RTO, we will generally require:

• your address, date of birth and emergency contact;
• your payment information, which may include credit card details for the purpose of processing payment of course fees;
• any other data that we are required to provide to the national regulator, the Australian Skills Quality Authority (ASQA) as part of our mandatory reporting requirements as an RTO, which generally includes (but is not limited to) details of your attendance, cultural background, physical and mental health, and demographic (despite that this information may be statistical only and doesn’t identify you); and
• copies of your identification documents such as a birth certificate, drivers license and/or passport in order to create a Unique Student Identifier (USI), unless you already have a USI.  

With your consent, we may also collect your photo or video for promotional purposes.

Job applicants

If you apply for employment with us, we may collect personal information as part of our recruitment activities, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before you commence employment, we may collect additional details such as your tax file number, superannuation details and other information necessary to conduct background checks to determine your suitability for certain positions.

How we collect personal information

Generally, we collect your personal information directly from you unless it is impracticable or unreasonable to do so. From time to time, we may collect personal information about you from third parties (for example, from publicly available sources, social media, from your referees if you apply for a position with us, or our suppliers and contractors who assist us to operate our business).

If you enrol in a course, we may also collect personal information about you from particular third parties where required for your enrolment, for example:

• from schools and other educational institutions where necessary to verify qualifications and course credits for enrolment and assessment purposes;
• from organisations where you may be completing a work placement or practical component of your course;
• from your employer if your course is being supported by them or incorporated into your employment; from professional or member associations or government departments via websites such as confirming your membership or registration or license check.

If you provide us with personal information about a third party, you represent, and we collect it on the basis that, you have that person’s consent for us to collect and handle their personal information in accordance with this policy.

When collecting your personal information, we will take reasonable steps to provide you with certain information as required under the APPs, including the purpose of collection, who we may disclose your personal information to, any law that requires or authorises us to collect the information and the main consequences if we do not collect all of the personal information we require.  If we collect your personal information from another source, we will take reasonable steps to ensure you are aware of the circumstances of that collection.

Purposes for which personal information is collected, held, used and disclosed

We will use and disclose your personal information for the purposes for which we collected it (as described above in relation to general enquiries, students and job applicants), and for other related purposes that you would reasonably expect (depending on the nature of our interaction with you). 

Generally, these purposes include:

• complying with reporting requirements of the national VET Regulator;
• responding to your enquiries;
• providing you (or arranging for our related parties or partners to provide you) with our services or information about our services;
• obtaining your feedback on your experience or training;
• conducting promotional and marketing activities;
• researching and developing our services;
• sending you updates on opportunities or events you may be interested in;
• any purpose you have consented to;
• any related secondary purpose we believe you would reasonably expect when we collected your personal information or because of our relationship with you;
• any purpose for which we are required or authorised by applicable law;
• to respond to and manage complaints, feedback, appeals and claims, defend our legal interests and investigate and protect against fraud, theft and other illegal activities; and
• for our general business operations (for example, processing payments or pursuing a debt, recruitment, maintenance of our RTO records, compliance with our legal and insurance obligations, training and statistical purposes).

We may use your image or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur, or where you have given us your consent.

By providing us with your personal information, you consent to us using your personal information for these purposes.

Generally, if we are unable to collect the personal information we require we may not be able to provide you with the products and services you seek.  If the information provided is incorrect or incomplete, this may also prevent, limit or otherwise affect our ability to provide our services to you.

Direct marketing

We may use or disclose your personal information for the purpose of informing you about our services, promotions and events, or other opportunities that may interest you.  If you do not want to receive direct marketing communications, you can opt-out at any time by using the unsubscribe facility in all emails we send to you, or by contacting our Privacy Officer via the details shown below.

If you opt out of receiving marketing material from us, we may still contact you in relation to any services you engaged us to provide to you.

We may occasionally engage other companies to provide marketing or advertising services on our behalf.  Those companies will be permitted to obtain only the personal information they need to deliver the service. If we provide those companies with any of your personal information, it is to provide you with a better or more relevant and personalised experience and to improve the quality of those services. 

Circumstances in which we may disclose your personal information

Disclosures for training purposes

If you are undertaking a course we may disclose information to a third party about you or your course for the purposes of assessing your progress, tracking your attendance, providing student support, issuing your results, and providing certificates of completion and/or Statement of Attainments (SoA) for nationally recognised training.  In addition, for Australian nationally recognised courses, this will include:

• disclosure to government agencies with responsibility for administering and regulating education and training providers in Australia such as ASQA and state training authorities;
• disclosure to government agencies or government-appointed providers with responsibility for reviewing and analysing student and other stakeholder feedback.

Other types of disclosures

We may also disclose personal information:

• within the Harcourts corporate group;
• to our suppliers, contractors or agents that we engage in order to provide our services, including for payment processing and debt recovery, data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance, development or hosting, archiving, marketing and market research;
• via our social media pages for promoting us and our services;
• if we merge with or are acquired by another entity, to that entity as a part of the merger or acquisition;
• to relevant government authorities for the purpose of investigating an incident, for example a workplace health and safety matter or security incident or a data breach;
• when conveying information to a responsible person (e.g. parent, guardian, spouse) if you are injured or cannot communicate;
• to a third party for other administrative and operational purposes, such as risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives).

Apart from the above instances, we may also use and disclose your personal information with your consent and as otherwise required or permitted by law.

Sensitive Information

We will only collect ‘sensitive information’ (as defined in the APPs) with your consent. 

If you are enrolled in a Harcourts training course, we may collect information about you which is considered sensitive information for example, information about whether you identify you as Aboriginal or Torres Strait Islander; information which may disclose your racial or ethnic origin (such as your proficiency in languages other than English); and information about your health or a disability where this is relevant to your training needs.

Storage and security of your personal information

We may hold your personal information in electronic formats or in hard copy.  We take reasonable steps to protect your personal information from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss.  This includes electronic and physical security measures and procedures, staff training and use of password protection software. 

We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected.  We may retain your personal information for as long as necessary to comply with any applicable law (for example, reporting requirements of the national VET Regulator), for legal, insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes.  Your personal information may also be retained in our IT system back-up records.

The transfer of data over the Internet is inherently insecure.  We cannot guarantee the security, during transmission, of any personal information provided to us via our websites.  Please bear this in mind when transmitting information by this means to us.

The Privacy Amendment (Notifiable Data Breaches) Act 2017 established the Notifiable Data Breaches Scheme (NDB scheme) in Australia (to be Part IIIC of the Privacy Act 1988 (Cth) on commencement).  The NDB scheme sets out obligations for notifying affected individuals, and the Australian Information Commissioner (Commissioner), about a data breach which is likely to result in serious harm.

Where serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations. You may contact our Privacy Officer via the contact details below should you require additional information.

Access and correction of your personal information

Under the APPs, you have the right to access information we hold about you.  You may lodge a request to access and correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading by contacting our Privacy Officer via the contact details shown below.

You may request that we provide you with access to the personal information we hold about you.  Generally, we will provide you with access, except in limited circumstances where the APPs permit us to deny access.  Any such requests must be made in writing and directed to our Privacy Officer via the details shown below.  We may need to verify you first.  Under the APPs, we are permitted to charge you a reasonable fee for providing access to your personal information.  Please note that no fee will be incurred for requesting access, and if your request for access is accepted, we will inform you of the fee (if any) that will be payable for providing access if you proceed with your request.

You may ask us to inform you of the source of any personal information about you that we have collected from a third party.  We will provide this at no cost, except in limited circumstances where the APPs or other laws permit us to withhold this information.

Making a complaint

You may lodge a complaint with us if you believe we have handled your personal information other than in accordance with the APPs.  To do so please contact our Privacy Officer via the contact details below.  We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response.  We will endeavour to respond as quickly as possible, which will typically be within 14 days of receiving your complaint.

Harcourts Real Estate Training Centre website

Our websites use cookies. We do not use the information stored in those cookies to collect information about you or your computer.  The cookies are used for statistical purposes and to assist with your use of the website. We may also collect click-stream data when you use the website, such as the date and time of your visit, the pages you accessed, your IP address, the type of browser and operating system you are using and the websites you come from and move to.  This information is collected for statistical purposes to assist us to find out how our website is used and navigated and to improve our website.

Harcourts websites may contain links to third party websites. Harcourts is not responsible for the privacy, security or handling of your personal information via those websites.  You should review the privacy policy and terms of use for those websites each time you visit them.

Overseas disclosure of your personal information

Generally, we will not disclose your personal information to overseas recipients, except upon your request or with your consent, or if we are authorised or required to do so by law. 

Generally, such disclosures will be to a related party of ours located overseas, or a service provider we use that is located overseas, where we have taken reasonable steps to ensure that recipient does not breach the APPs in relation to your personal information.

The reason for disclosure to an overseas recipient depends on the nature of the services those recipients provide to us (for example storing data via a cloud service, or where our customer relationship management system is hosted on servers located overseas).

We will take reasonable steps to ensure that the overseas recipient handles your personal information in accordance with the APPs.

Data Provision Requirements 2012

Under the Data Provision Requirements 2012, Harcourts Real Estate Training Centre is required to collect personal information about you and to disclose that personal information to the National Centre for Vocational Education Research Ltd (NCVER).

Your personal information (including the personal information contained on this enrolment form), may be used or disclosed by Harcourts Real Estate Training Centre for statistical, administrative, regulatory and research purposes. Harcourts Real Estate Training Centre may disclose your personal information for these purposes to:

• Commonwealth and State or Territory government departments and authorised agencies; and
• NCVER.

Personal information that has been disclosed to NCVER may be used or disclosed by NCVER for the following purposes:

• populating authenticated VET transcripts;
• facilitating statistics and research relating to education, including surveys and data linkage;
• pre-populating RTO student enrolment forms;
• understanding how the VET market operates, for policy, workforce planning and consumer information; and
• administering VET, including program administration, regulation, monitoring and evaluation.

You may receive a student survey which may be administered by a government department or NCVER employee, agent or third party contractor or other authorised agencies. Please note you may opt out of the survey at the time of being contacted.

NCVER will collect, hold, use and disclose your personal information in accordance with the Privacy Act 1988 (Cth), the National VET Data Policy and all NCVER policies and protocols (including those published on NCVER’s website at www.ncver.edu.au).

For more information about NCVER’s Privacy Policy go to https://www.ncver.edu.au/privacy.

Changes to our Privacy Policy

We may amend, modify or replace this policy at any time.  You should review our policy each time you visit our website or provide us with personal information.

Contact us

If you would like further information about the way we manage your personal information, or if you have a privacy-related complaint, please contact our Privacy Officer by telephone on +61 7 3839 3226, by mail at 31 Amy Johnson Place, Eagle Farm, QLD 4009, Australia or by email at privacy@harcourts.net.

Office of the Australian Information Commissioner

More information about your rights and our obligations in connection with your personal information are available from the Office of the Australian Information Commissioner at www.oaic.gov.au.