Purpose of Policy

NeuroMite and its association with Schuhfried Australia are committed to protecting the privacy of personal information obtained through its operations as a psychology and education service provider.

This privacy statement describes the policy of Schuhfried Australia for NeuroMite Programs.  We are bound by the legal requirements of the National Privacy Principles from the Privacy Act (1988) and Privacy Amendment Act – Private Sector (2000).  NeuroMite programs also conform to all Australian Psychological Society guidelines.

The Australian Privacy Principles apply to personal information, that is, information or an opinion (whether true or not) relating to an identified individual or which can be used to identify that individual.  Please note that information about companies is not personal information.

Type of information Collected

NeuroMite collects personal information that is reasonably necessary for, or directly related to, its functions or activities (e.g., assessment and diagnostic services, candidate booking and scheduling programs, training programs, data analysis, and program evaluation).  Personal information refers to documents, test results, training results and/or reports collected during the provision of educational and psychology services, which record personal information that would not otherwise be publicly accessible.

The specific types of personal information we may collect and hold include:

  • Name, title contact details, and business/mailing address
  • Test and training data about human abilities, personality and character traits
  • Additional personal information about family members
  • Qualifications, memberships and other accreditations
  • Academic and report card results, National Assessment Program for Literacy and Numeracy (NAPLAN) data and reports, school performance summary results, or other educational results or performance records

NeuroMite collects certain information that is specifically provided by third parties, such as an IP address, browsing patterns on the site, click streams, and the status of cookies placed on a computer. NeuroMite does not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which NeuroMite has been engaged or may be engaged, or its other functions and activities.

Collection of Personal Information

NeuroMite only collects personal information that has been directly provided to us by our candidates/clients or prospective candidates/clients, associates of candidates/ clients, educational institutions and schools, our suppliers or potential suppliers, our employees or potential employees, or is otherwise available in the public domain where this information will assist us with the provision of services to our current and prospective candidates/clients.  Information may have been provided verbally or in writing (including by email or through web forms).

Information is gathered as part of the pre-program planning, program delivery (e.g., assessment, diagnosis, training and intervention), or in course of general provision of educational and psychology services.  NeuroMite may from time to time collect personal information concerning an associate of a candidate/client or a prospective candidate/client (e.g., school principal, teacher, counselor, psychologist, spouse, sibling, or a child) where it is considered unreasonable or impracticable to seek this same information directly from the associate.

At times, our website uses cookies to identify site users and their interests and to track usage of the site.  Cookies are small pieces of text stored on a computer that help us to know which browser the operator is using, where they have been on the site and any web sites to which they may link in order to use some of our features.  By acceptance of our cookie, the user will be permitted access to certain pages of the site without having to log in each time they visit.  A user who does not accept the cookie from the site may not be able to access certain areas of the site.

We also may log IP addresses, or the location of computers on the internet to help diagnose problems with our server and to administer the site. If the user prefers not to accept a cookie, they can set their web browser to warn them before accepting any cookies.  Alternatively they can refuse all cookies by turning them off in their web browser.

Use of Personal Information

NeuroMite programs subscribe to the following privacy principles when collecting and using personal information:

  • We collect information that is necessary for the conduct of its work in the provision of educational and psychology services
  • We will take all reasonable precautions to securely store and prevent unauthorised access to client information
  • If information cannot be de-identified (i.e., personal name removed from data), we will obtain informed consent from candidates/clients before reusing their information for alternative applications, and before disclosure to third parties

NeuroMite may use and disclose personal information about an individual for the “primary purpose” of collection (i.e., the dominant or fundamental purpose for which that information is collected).  As well as providing services to clients, that “primary purpose” includes facilitating our internal business processes, communicating with clients, prospective candidates/clients and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations and dealing with enquiries and complaints.

In certain circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where a client would reasonably expect us to and the purpose is related to the purpose of collection).

Disclosure of Personal Information

Personal information is not disclosed to a third party unless the disclosure is necessary to support the delivery of the client services for which NeuroMite has been, or is expected to be, engaged, or is required by law.  Examples where personal information may be disclosed to a third party include:

  • Disclosures to our related departments (program designers, researchers, marketers), overseas offices, or partnered companies
  • Educational institutions, school teachers, principals, or heads of departments so that they are better able to support the learning, effort, or behaviour of students
  • Where NeuroMite is required by law to provide personal information so that we comply with court orders, subpoenas or other legislation that requires us to provide personal information
  • In certain circumstances, NeuroMite may also disclose personal information to third party service providers (such as IT service providers) who assist us to administer our business.

Reuse of client information for alternative applications (i.e., beyond its original application) and/or disclosure of client information to a third party is only allowable under any of the following circumstances:

  • The client has consented to disclosure of information to third parties, within the usual course of receiving educational and psychology services
  • The client whose information it is has signed an informed consent for alternative uses and disclosure where personal identifiers remain associated with data (e.g, tests results or training data)
  • For research or marketing purposes, any personal or organisational identifiers are deleted from the information, and it is used in aggregate form or in case studies
  • Conditions under the National Privacy Principles (1998) are applicable. For example, disclosure is likely to prevent harm to a person, or the information is about an unlawful activity

Should it be necessary for NeuroMite to forward personal information to third parties outside the firm, we will make every effort to ensure that the confidentiality of the information is protected, either through de-identification (i.e., removal of personal name and contact details), aggregate data summaries (not individual data), and/or restrictive use agreements of personal data.

Storage of Personal Information

NeuroMite will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, including through appropriate physical and electronic security strategies. Only authorised NeuroMite personnel are provided access to personal information, and these employees are required to treat this information as confidential. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will destroy or de-identify these records.

Our policy is that all electronic records are only stored within Australia whenever this is commercially feasible. However, on occasion, a limited number of specialist software applications may involve the storage of personal data at an overseas location where a suitable alternative is not available.

NeuroMite will only store data with an external provider if a technical assessment of a service provider’s security protocols are considered to meet or exceed the level of security that NeuroMite could apply if the electronic data were to be stored in NeuroMite’s own in-house systems and where we are satisfied that NeuroMite is able to meet its commitments under Australian Privacy Legislation.

Accuracy of Personal Information

NeuroMite will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date. If a person believes that the information we hold is inaccurate or out of date, they may contact our Privacy Officer and we will update the relevant information accordingly.

Access to Personal Information

Under the Australian Privacy Principles, a person has the right to request access to any personal information that we may hold about them and to advise us if the information should be corrected. The Australian Privacy Principles set out the circumstances when we can refuse those requests. If we do refuse a request, we will provide the person with a written notice that sets out the reasons (unless it would be unreasonable to provide them).

Subject to our right to refuse access, NeuroMite will provide the person with a report that lists any personal information that we may hold. Our policy is to provide written acknowledgement of our receipt of any request for access to personal information or a request for correction of personal information within 7 days of the request being received. We will then provide a written response within 30 days of our receipt of the request.

If you wish to make an enquiry about your personal information at NeuroMite, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please email our nominated Privacy Officer at privacy@neuromite.com.au or telephone (07) 3511 0588.

If a party has lodged a complaint with NeuroMite and is not satisfied with our response, they may contact the Commonwealth Information Commissioner.