VCAA Privacy Policy
VCAA Privacy Policy
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Released: 1 September 2002, Revised 2007
As a Victorian public sector organisation, the Victorian Curriculum and Assessment Authority (VCAA) will comply with legislation governing the collection, storage, use and disclosure of personal and health information.
Section A - Role and Structure of the VCAA
A1 Context of Policy
In Victoria the Information Privacy Act 2000 and the Health Records Act 2001 have established a regime for the responsible collection and handling of personal and health information respectively. The VCAA is required to comply with both Acts.
The Privacy Act does not replace the VCAA's obligation to comply with existing legislation such as the Freedom of Information Act 1982 governing access to records in the public sector and with other laws requiring mandatory reporting or release of personal information.
A2 The Role of VCAA
The VCAA is a statutory authority established under the Victorian Curriculum and Assessment Authority Act 2000. The VCAA has responsibilities relating to both curriculum and assessment across year levels Prep to 12 for all Victorian school students.
The VCAA's major functions include the following activities:
- development and evaluation of the curriculum and assessment for the Victorian Certificate of Education (VCE) and of the Curriculum and Standards Framework (CSF),
- delivery and conduct of VCE assessments and of the Achievement Improvement Monitor (AIM) for years 3, 5 and 7 students,
- monitoring patterns of participation by school students and the quality of student outcomes,
- preparing and maintaining records of student assessment,
- conducting research on matters related to curriculum, assessment and reporting.
This policy ensures that privacy issues are handled in a consistent manner across the organisation and that there is compliance with the Information Privacy and Health Privacy Principles.
A3 VCAA Structure
The VCAA collects personal and health information from the Victorian public in the performance of its functions. The role of each Branch of the VCAA is outlined below:
A3.1 Assessment Branch
The Assessment Branch is responsible for the assessment and reporting of students' educational achievements. The Branch comprises the VCE Assessment Unit, incorporating Assessment Operations, and the Student Records and Results Unit.
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VCE Assessment Unit
The Unit co-ordinates the development and assessment of all VCE assessment across two sites at East Melbourne and Camberwell. The Unit prepares and assesses all VCE written examinations, including VCE VET examinations, performance examinations in the Arts and LOTE, school assessed tasks in a number of studies and the General Achievement Test (GAT). It provides the data that is used to prepare certificates for VCE students and conducts audits of school coursework. In addition the Unit provides the operational requirements of the AIM tests, including contracts, appointments, marking and the provision of data
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Student Records and Results Unit
The Student Records and Results Unit has responsibility for the record-keeping of enrolments and results of VCE and VCAL students, the delivery of Statements of Marks and VCE certificates to students' home addresses and, working with other agencies, organises student results services. The Unit processes applications for second-language status, special provision and the formation of school partnerships, as well as playing a key role in the moderation of school results.
A3.2 Curriculum Branch
The Curriculum Branch is responsible for the development and evaluation of curriculum for Victorian students from P- 12. This includes the CSF in the compulsory years (P-10) and the VCE in the post-compulsory years. The Branch also develops resource materials and provides professional development to support teachers in their implementation of the curriculum and assessment of student work. Key learning area managers work across P-12 with small project teams focusing respectively on P-10, VCE and VCE VET.
A3.3 Educational Measurement and Research Branch
The Educational Measurement and Research Branch is responsible for the
provision of research and measurement expertise in all aspects of the VCAA's
work, and for the development of its research and measurement capacity. The
Branch brings together the work of the P-10 Assessment Unit, the Educational
Measurement Unit and the Research
and Evaluation Unit
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P-10 Assessment Unit
Through its delivery of the AIM, the Unit coordinates the assessment of student achievement in English and Mathematics in Years 3, 5 and 7 across two sites at East Melbourne and Camberwell. The Unit prepares and assesses the AIM written tests, school assessed tasks and online delivery. It prepares AIM performance data and reports student achievement to schools, parents and sector authorities.
A3.4 Operations Branch
The Branch has operational responsibility for the delivery of key products and services of the VCAA. It incorporates the work of the following units:
- Finance and Administration
- Information Technology
- Executive Services
- Information Services
- Production
- Website
- VCE Season of Excellence.
The main work of the Branch includes the provision of administrative support and governance advice, the preparation and monitoring of budgets, administration of human resource functions, maintenance of the VCAA's two locations, provision of IT services, communication and promotion of the VCAA's key activities to the public and educational community.
Section B of this Policy outlines how the VCAA manages the collection and use of personal and health information as an organisation in general and, in more detail, in relation to the specific roles of each of the VCAA Branches.
Section B - Addressing Privacy Protection
B1 Privacy Protection
B1.1 Definitions
'Personal information' - recorded information or opinion, whether true or not, about a readily identifiable individual.
'Health information' - information or opinion about the physical mental or psychological health of an individual. It includes information about a disability or the well being of an identifiable person.
'Sensitive information' - an individual's racial or ethnic origin, religious belief, sexual preference, membership of groups or criminal record.
'Unique identifier' - a number assigned to uniquely identify an individual for the purpose of the operations of the organisation.
B1.2 Principles
The VCAA will support the Information Privacy and Health Privacy Principles in the following ways:
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Collection
Only personal and health information that is necessary for performance of VCAA functions and activities will be collected. Health and sensitive information will only be collected with the consent of the person. At or before the time of collection, individuals will be informed about the reason for collection, what use the VCAA will make of the information and how to seek access to it. Use and Disclosure Personal and health information will only be used and disclosed for the purposes for which it was collected, or for a secondary purpose which the individual would reasonably expect would occur.
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Data Quality
The VCAA will ensure that personal and health information is accurate, complete, up to date and relevant to the purpose for which it is collected.
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Data Security
Reasonable steps will be taken to ensure that personal and health information is not misused, lost, accessed or modified without authority. Information will be maintained in accordance with the Public Records Act 1973.
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Openness
The VCAA Privacy Policy clearly expresses the organisation's policy on the management of personal and health information. This policy is available to the public on request. Privacy notices are provided to individuals whenever personal or health information is collected.
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Access and Correction
Individuals have the right to seek access to the personal and health information that is held by the VCAA and its correction if inaccurate. Access to documentation will be mostly handled under the Victorian Freedom of Information Act 1982. Requests for access to personal and health information held by the VCAA need to be made in writing to the following address or email:
Manager, Corporate Governance
VCAA
41 St Andrews Place
East Melbourne VIC 3002
privacy.vcaa@edumail.vic.gov.au
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Unique Identifiers
A unique identifier, the student ID, has been adopted by the VCAA to identify all students who have previously been enrolled, or are currently enrolled, in the VCE, the VCE VET or the VCAL, as well as students who have undertaken the GAT. Use of the ID enables the VCAA to carry out its functions effectively under the VCAA Act. The ID is not provided to any other organisation nor is it disclosed to schools.
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Anonymity
If practicable and lawful, individuals will have the option of not identifying themselves when entering into transactions with the VCAA.
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Transborder Data Flow
Transfer of personal and health information outside Victoria will only occur when the receiving organisation is subject to privacy standards similar to those in Victoria.
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Sensitive Information
The collection of sensitive personal information, such as an individual's indigenous status, country of birth and language/s spoken, is restricted to the following: a) the collection of information directly from schools to support student applications for English as a Second Language (ESL) status and for Second Language status in a number of LOTE studies, and b) the compiling of statistical reports under the national standards for Statistics on Cultural and Linguistic Diversity. No individuals are identified in such reports.
B2 Addressing Privacy within VCAA Branches
B2.1 Assessment Branch
* VCE Assessment Unit
The VCE Assessment Unit uses application forms to directly collect personal
and health information from current and potential employees who set and mark
VCE examination papers. The information is used to appoint examination panels
and is used by the Panel Chairperson of each study for the purpose of
selecting panel members. The Unit also
collects this information from
casual staff applying for employment within the VCAA.
The Unit protects the information by placing it on a password-protected database and hard copies are securely archived for five years.
* Assessment Operations Unit
The Unit collects individual examination and General Achievement Test (GAT) booklets containing student responses for marking and for calculating VCE results.
Statistical data is also collected from the marking record sheets of exam assessors so that the Chief Assessor for each VCE study can monitor assessor performance.
Access to both types of information is restricted to authorised VCAA staff. It is securely archived for a period of seven years.
VCE Examination and GAT booklets are normally pulped in April of the following year.
* Student Records and Results Unit
The Student Records and Results Unit uses VCE, VCAL and GAT student enrolment
data and school-assessed coursework results collected by schools and provided
to the VCAA through the VASS interface. The Unit also uses individual student
examination results as calculated by the Assessment Operations Unit. This
information enables the
unit to calculate study scores and generate final
results for VCE students.
Student personal information and final VCE, VCAL and GAT results are disclosed to the Victorian Tertiary Admissions Centre (VTAC) for calculation of ENTERs and processing of applications for tertiary selection. VTAC also includes the information provided by the VCAA into its CourseLink database - a password protected interactive, web-based program enabling VCE students to access their own individually tailored career and course options.
The names and schools of VCE students who achieve study scores of 40 and above in any VCE study are disclosed to the newspapers for publication only with the permission of the students involved. Similarly, student consent is sought before personal information is disclosed to the Commonwealth Department of Education, Science and Training for the selection of the annual Australian Students Prize and to the Victorian Department of Education for the selection of the annual VCE Premier's Awards.
The Unit also collects personal and health information to support claims for special provision for students and sensitive information in support of student applications for ESL and Second Language LOTE status.
All information is stored indefinitely on a password-protected database and access is restricted to authorised VCAA staff. Authorised restricted access is also provided to staff at the Victorian Qualifications Authority (VQA) for the performance of functions under its own Act.
Hard copies of the data are securely archived for five years. Some components are also stored indefinitely on microfiche.
B2.2 Curriculum Branch
* Senior Secondary Curriculum Unit
The Unit collects personal information directly from individuals who have
expressed an interest in being VCE study specialists, in attending briefings
and workshops, in being on VCE review panels or in participating in
consultation on VCE studies. Opportunities are provided to express this
interest through the VCE Bulletin, memoranda to schools
and on workshop
registration forms. The information is updated on the VCAA register each time
an expression of interest is received. Access to the electronic data is
restricted to authorised VCAA staff and hard copies are securely archived for
seven years.
* P-10 Curriculum Unit
The P-10 Curriculum Unit collects personal information directly from individuals for the purpose of maintaining a database of teacher reference groups. Access to the data is restricted to authorised VCAA staff and hard copies are securely archived for seven years.
* VCE VET Unit
The VCE VET Unit collects information directly from individuals for the
purpose of providing a referral service comprising contractors, sessional
staff, consultants and teachers involved in developing and teaching VCE VET
programs. The information is disclosed to people involved in these networks
mainly through publications produced by
the Unit. It is stored
electronically and deleted when the services of the individual are no longer
required or approval is withdrawn.
B2.3 Educational Measurement & Research Branch
* Research and Evaluation Unit
The Research and Evaluation Unit sometimes uses surveys to collect personal information directly from individuals for the purpose of assisting in curriculum or program reviews. In order to conduct its duties in research and evaluation, the Unit uses statistical data and personal information redirected from the Student Records and Results Unit. The data is stored securely and permanently. Paper records are maintained for a period of six months after the completion of the academic year and then archived for five years.
* P-10 Assessment Unit
The P-10 Assessment Unit collects individual test booklets containing personal and sensitive information of all students in Years 3, 5 and 7 who undertake the Achievement Improvement Monitor (AIM) testing. Individual student data is also collected from students who participate in the AIM Online assessment program in Year 7.
The AIM test booklets and the AIM Online test responses are used to generate student performance data. Individual student results are disclosed to parents and schools.
For the purpose of developing national benchmark statistics, data from the AIM testing is disclosed to the Commonwealth Department of Education, Science and Training. Data from the AIM testing is also disclosed on a confidential basis to schools and their authorities, (ie. the Victorian Department of Education, the Catholic Education Commission of Victoria) for the fulfilment of operational responsibilities including measuring and improving student and school performance and for strategic planning.
Access to information is restricted to authorised VCAA staff. Electronic data is securely stored by the VCAA in order to track student progress through years 3, 5 and 7 and then archived for seven years.
The AIM test booklets are normally pulped in April of the year following the test.
The P-10 Curriculum Unit also collects personal information directly from individuals for the purpose of maintaining a database of teacher reference groups. Access to the data is restricted to authorised VCAA staff and hard copies are securely archived for seven years.
B2.4 Operations Branch
* Finance and Administration Unit
The Finance and Administration Unit collects personal and sensitive information directly from potential and current employees of the VCAA for selection, employment and performance management purposes. The information is collected on hard copy application forms and, for casual staff, may include a health declaration.
The personal information of VCAA employees working on a part time or fulltime basis is also disclosed to the Victorian Department of Education (DoE) which acts as the employing body. DoE maintains all VCAA personnel records on its Human Resources Management System (HRMS). The Unit also discloses personal information to Centrelink when requested by that body, and to the Government Superannuation Office for the maintenance of superannuation records for VCAA staff.
Information on current and former staff is stored electronically and only authorised Unit staff and the Manager, Corporate Governance, have access to it. Hard copies are securely stored and archived for seven years.
* Information Technology Group
The Group neither collects nor holds personal or health information as defined under the legislation.
* Executive Services
Executive Services access personal and sensitive information on VCE students from the password-protected database and from relevant schools and use it in the VCAA procedures for dealing with discipline issues, student appeals and teacher error claims in relation to the delivery of the VCE assessment program. The Unit may also collect personal information to respond to Freedom of Information requests. Information which is generated from these processes is stored securely at the VCAA, both electronically and in hard copy.
Personal information about Executive Services staff, the Chief Executive Officer and Assistant General Managers and Authority members is collected for employment and administrative reasons. It is stored electronically and in hard copy and access is restricted to authorised Unit staff.
In preparation for publications such as the VCAA Strategic Plan and Annual Report, photos are used of students and/or teachers with the individual's written consent.
VCAA publications may also include images obtained from the DoE photo library, for which consent for use has already been given.
* Information Services
Personal information about Information Services Unit staff is collected for employment reasons. It is stored electronically and in hard copy and access is restricted to authorised Unit staff. Information about a Unit member is shredded on leaving the organisation.
* Production and Website
The Production Unit collects information directly from individuals for the purpose of maintaining hard copy records of consultants, agency staff and freelancers. This is kept on an ongoing basis. It also collects information from subscribers to the VCE Bulletin publication. This data is stored and updated electronically for an indefinite period and is relayed to external mail houses for mailing purposes. All mail houses are requested to destroy distribution data after a period of six months.
Use of photographs and recordings such as video, audio or other electronic personal representation is covered by agreement between the VCAA and the individual concerned. The authorisation allows the VCAA to use or reproduce any such recordings for any reasonable purpose including placement on the VCAA website. Individuals can withdraw authorisation by informing the Manager, Corporate Governance.
E-commerce transactions which are performed through the VCAA website's online Application for Replacement of Results involve the supplying of the applicant's personal information to the National Australia Bank. The National Australia Bank's Privacy Statement may be viewed at its website (www.national.com.au). VCAA staff do not have access to this data and only identify individuals in order to process their applications.
Personal information collected on the website for the purpose of consultation or survey will be kept secure. Respondents will be advised via a privacy notice of what use will be made of their information and whether it will be accessed by anyone other than authorised VCAA staff.
* VCE Season of Excellence
VCAA staff use application forms to collect personal information directly from
students who express interest in participating in the VCE Season of Excellence
program each year. Information is disclosed to the Chief Assessors of the
relevant VCE studies for the selection of work for Season exhibitions and
performances. Information is stored
electronically and in hard copy and
only accessed by relevant VCAA staff.
As part of the presentation and promotion of the Season of Excellence, images of Season participants may be used in publications such as venue programs, the website, the VCE Bulletin and the Annual Report. Permission is sought from Season participants to cover publication of all images.
For students whose work is accepted for the Season, the information is kept securely for five to seven years. For those whose work is not accepted, the information is shredded within four months of their application and any work submitted in support of the application is disposed of in security bins.
Section C - Complaints Handling Procedures
C1 Complaints Handling Procedures
Contacting the VCAA
The VCAA will make every attempt to settle queries or complaints about privacy
through direct communication with the party involved. First contact should be
made through the VCAA Information Services on (03) 9651 4328 or email
privacy.vcaa@edumail.vic.gov.au
If, through informal discussion, a complaint cannot be resolved to the satisfaction of the complainant, a written complaint should be lodged with the VCAA.
Lodging a complaint in writing
Written complaints must be lodged with the
Manager, Corporate Governance,
VCAA,
41 St Andrews Place,
East
Melbourne 3002.
Details to be provided in the complaint should include:
- name and address of person lodging the complaint
- privacy concern/s
- if applicable, how concern/s could be remedied.
Confirmation from VCAA
Within 14 days of receipt of a complaint, the Manager, Corporate Governance, will:
- confirm receipt of the complaint in writing,
- inform the complainant that an investigation will be conducted and a response provided as soon as practicable, but in no more than 45 days from the day the complaint is received at the VCAA,
- commence an investigation into the complaint.
Investigation and response
As a result of the investigation of a complaint the Manager, Corporate Governance, may:
- respond to the complainant that no further action will be taken on the matter; or o make a formal apology to the complainant; and/or
- take such remedial action as thought appropriate by the VCAA; and/or
- provide undertakings that the conduct will not occur again; and/or
- implement administrative procedures within the VCAA to ensure that the conduct will not occur again.
In all cases of a written complaint being lodged against the VCAA or one of its staff, the Manager, Corporate Governance, will inform the complainant of his/her right to lodge a complaint with the Office of the Victorian Privacy Commissioner if the dispute is not remedied.
C2 For More Information
- Email the VCAA at privacy.vcaa@edumail.vic.gov.au
- Office of the Information Privacy Commissioner: www.privacy.vic.gov.au
- Office of the Health Services Commissioner: www.health.vic.gov.au/hsc
