This is the privacy policy of TheFootnotes Pty Ltd T/A The Careers Department ("we," "us," or "our"). We respect and protect the privacy of all users, including students, educators, parents, and institutional partners. This policy explains how we collect, use, store, and disclose personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
By using our platform, app.thecareersdepartment.com, placing an order with us, or providing personal information, you consent to the terms of this Privacy Policy.
What Personal Information Do We Hold
AUSTRALIAN PRIVACY PRINCIPLE 1 – OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
We adopt the principle of data minimisation and only collect information reasonably necessary for our operations and provision of services.
Depending on how an individual uses our platform and services, the types of personal information we may collect and hold include:
- Identity and contact information – such as name, email address, gender, and parent or guardian email address (where applicable).
- School and education information – such as school name, state and location, year level, subjects studied or selected, and other information relating to a user's education or learning.
- Career interests, preferences and aspirations – such as industries, occupations, courses, institutions, pathways and other career or study preferences selected, saved or identified by a user.
- Career profiling and assessment information – including responses to career profiling tools, personality or preference-based questions, and recommendations, results or insights generated from those tools.
- Platform activity and learning information – such as modules, lessons, quizzes, skills training or virtual work experience activities completed; content viewed or saved, activity progress; badges and certificates earned; and other interactions with the platform.
- Student-created content and portfolio information – information entered, created or uploaded by a user through features such as an ePortfolio, résumé/CV builder or other student work, including employment history, work experience, education, qualifications, skills, achievements, interests, references and other information the user chooses to include.
- Files, images, video and other media – photographs, images, videos, documents and other files that a user chooses to upload or include in their work, résumé/CV, ePortfolio or other areas of the platform.
- Teacher and school staff information – such as name, email school, role, account permissions and other professional contact or account information.
- Technical and usage information – such as login activity, dates and times of access, and information about how users interact with the platform.
- Communications and support information – information provided when users, parents, teachers or schools contact us, request support, provide feedback or otherwise communicate with us.
We do not collect sensitive information unless explicitly required and authorised by law or consent.
AUSTRALIAN PRIVACY PRINCIPLE 2 – ANONIMITY AND PSEUDONYMITY
Where lawful and practicable, you may interact with us using a pseudonym. You have the option of not identifying yourself or of using a pseudonym when you create an account with us. However, if you do not identify yourself or you use a pseudonym, then we may be unable to communicate with you via email and deliver certain functionalities of the platform (e.g. self-serve password resets or certifications using your name) will not be possible. You accept that if you deal with us anonymously or using a pseudonym, that we may not be able to respond to an enquiry for you or provide certain other functions or services.
AUSTRALIAN PRIVACY PRINCIPLE 3 – COLLECTION OF SOLICITED PERSONAL INFORMATION
We will only collect Personal Information if it is reasonably necessary for one or more of our functions or activities. The Personal Information we collect about you will be limited to the information that we need to undertake necessary business operations and/or to provide you with our service and/or associated products. We will not collect or require you to provide any sensitive information as that term is defined in the Privacy Act 1988 Cth.
AUSTRALIAN PRIVACY PRINCIPLE 4 – DEALING WITH UNSOLICITED PERSONAL INFORMATION
We request that you do not provide us with any Personal Information which we do not request from you. If you do provide us with Personal Information we have not requested, we will, within a reasonable time, determine whether that information is reasonably necessary for one or more of our functions or activities.
If we determine that we could not have collected the unsolicited information for the purposes of providing goods and services to you, then we will destroy the information as soon as possible or ensure that the information is de-identified.
If the unsolicited information you provide to us is information we could have collected for the purpose of our functions or activities, then we will deal with the information as outlined in the remainder of this privacy policy.
AUSTRALIAN PRIVACY PRINCIPLE 5 – NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION
If we collect Personal Information about you and you have not provided that information to us, then we will take reasonable steps to ensure that you are notified that we hold that Personal Information.
AUSTRALIAN PRIVACY PRINCIPLE 9 – ADOPTION, USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS
We do not collect or adopt Government-related identifiers of individuals.
How We Collect Personal Information
AUSTRALIAN PRIVACY PRINCIPLE 1 – OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
We collect personal information through:
- User account creation
- Participation in modules, surveys, or enquiries
- Our website or mobile interface
- Face-to-face workshops and in-school events
- Institutional uploads (e.g. student lists provided by schools)
AUSTRALIAN PRIVACY PRINCIPLE 10 – QUALITY OF PERSONAL INFORMATION
We only collect Personal Information which is provided to us by you. You should ensure that all information you provide is accurate, up-to-date and complete.
You must advise us if the information becomes inaccurate, up-to-date or incomplete.
How We Use Personal Information
AUSTRALIAN PRIVACY PRINCIPLE 1 – OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
We collect and use personal information to:
- Provide tailored digital learning experiences
- Enable account login and content access
- Deliver targeted career and education suggestions
- Facilitate communications between students, parents, and schools
- Respond to enquiries and provide support
- Improve our content, services, and platform performance
- Comply with legal obligations
We only collect personal information that is reasonably necessary to provide our Services and fulfil our legal and contractual obligations.
If you choose not to provide personal information that we reasonably request, we may be unable to create or manage your account, provide access to some or all features of the Services, respond to enquiries, deliver support, or otherwise provide the Services requested.
AUSTRALIAN PRIVACY PRINCIPLE 6 – USE OR DISCLOSURE OF PERSONAL INFORMATION
We only use or disclose personal information for the purpose for which it was collected, unless:
(i) the individual has provided consent; or
(ii) the individual would reasonably expect us to use or disclose the information for a secondary purpose that is related to the original purpose.
Sub Processors
AUSTRALIAN PRIVACY PRINCIPLE 1 – OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
We may engage third-party service providers to support delivery. We only use services which meet a high standard in relation to cybersecurity and privacy. These include:
|
Sub-Processor |
Service Type |
Purpose of Processing |
Categories of Personal Data |
Location of Processing |
Security Measures |
|
Amazon Web Services, Inc. |
Cloud Service Provider |
Cloud hosting provider |
Customer Personal Data, created by customer and stored by The Careers Department |
Australia |
|
|
HubSpot |
Software Vendor |
Customer communication. Customer support at a school level. Used for relationship management with school’s lead admin. |
Customer personal details for school account staff (e.g. name, email) |
Australia |
|
|
Intercom |
Software Vendor |
User communications. Customer support |
User personal details (e.g. name, email, school) and account activity (e.g. module completion, industry interests) |
Australia |
|
|
Google Analytics |
Software Vendor |
Web analytics, measurement, and visitor behaviour tracking |
IP address, device information (such as browser type). |
Global |
|
|
Atlassian |
Software Vendor |
Jira and Bitbucket for Software development and project management |
Source code, technical documentation, development tasks, issue/ticket information, user account details (e.g. staff name and email). No routine storage of production or customer data. |
Australia |
|
|
Microsoft Office 365 |
Software Vendor |
Office tools and workplace productivity |
Stores contact details and communications of stakeholders engaging with TCD. |
Global |
|
|
Stripe |
Third-Party Payment Processor |
Payment processing |
Customer billing and payment information (when online payment used), including name, email address, billing details and payment details. Payment card details are processed directly by Stripe and are not stored by TCD. |
Global / US |
|
|
Xero |
Third-Party Payment Processor |
Accounting and invoicing |
Accounts contact details (e.g. name, email, school) |
Australia/NZ |
All sub-processors are subject to contractual safeguards and regular review.
Data Storage And Security
AUSTRALIAN PRIVACY PRINCIPLE 1 – OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
AUSTRALIAN PRIVACY PRINCIPLE 11 – SECURITY OF PERSONAL INFORMATION
Your data is securely stored on AWS infrastructure in Australian data centres.
Protections include:
- Encryption
- Role-based access control
- Logging and monitoring
- Regular backups
We retain personal data only as long as required to fulfil our purposes and legal obligations. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
While we take reasonable steps to try and keep your personal information secure, unfortunately over the Internet there is not a 100% secure way of transferring data and information. We do not warrant the security of information you to us online. We will not be responsible for any liability, loss or damage arising from unauthorised access to your information.
Marketing And Communications
AUSTRALIAN PRIVACY PRINCIPLE 7 – DIRECT MARKETING
When signing up, you consent to receiving communications from us. We may use your Personal Information for direct marketing purposes.
You can easily request that we stop direct marketing to you by requesting the cessation of direct marketing material by emailing hello@thecareersdepartment.com or by simply clicking the relevant “unsubscribe” link in any email we send to you for direct marketing purposes. We will comply with such request within a reasonable time.
Your Rights And Access
AUSTRALIAN PRIVACY PRINCIPLE 12 – ACCESS TO PERSONAL INFORMATION
If you're a student/individual, parent/carer, or school staff member using The Careers Department, you can ask us at any time to access the personal information we hold about you.
In very limited situations, we may not be able to give you access — for example, if doing so would:
- Put someone else’s privacy or safety at risk, or
- Be unlawful or breach a legal obligation;
If we can’t give you access, we’ll let you know why and explain what you can do next.
To request access to your information, please email us at hello@thecareersdepartment.com. We aim to respond within 30 days.
AUSTRALIAN PRIVACY PRINCIPLE 13 – CORRECTION OF PERSONAL INFORMATION
You can access personal information that we hold about you and we will correct that information upon your advice that it is inaccurate, incomplete, misleading or not-up-date. You may also request deletion of your account/data (subject to legal retention requirements). You can contact hello@thecareersdepartment.com for these above purposes. We aim to respond within 30 days.
Cookies, Analytics And Third Party Links
AUSTRALIAN PRIVACY PRINCIPLE 8 – CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATIONWhen you use our website we may use “cookies” which is a small text file that our site may place on your computer as a tool to remember your preferences. You can refuse to use “cookies” by selecting the appropriate settings on your browser, however if you do this you may not have the full functionality of our website.
Our site uses Google Analytics to help us understand how the people use and access its information, providing important insights that help us to customise and improve our services for you. Google Analytics collects data including the details of the links clicked, search terms, navigation details, browser type and other use details as listed above. While these identifiers provide information about user behaviour, Google prohibits customers from sending Personally Identifiable Information to Google Analytics. You can opt out of Google Analytics if you disable or refuse the cookie, disable Java script, or use the opt-out service provided by Google.
This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of other sites and we encourage you to be aware of this when you leave our site. This privacy policy applies solely to information collected by us.
The Careers Department platform and resources may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, applications and/or resources of the The Careers Department Platform, we encourage you to read the privacy policy of every website you visit.
Privacy Policy Changes
We may amend this Privacy Policy from time to time to reflect changes to our services, practices, technology, legal or regulatory obligations, or the way we collect, use, hold, disclose or protect personal information.
Where we make a material change to this Privacy Policy that may affect the privacy, security or handling of personal information or customer or user data, we will provide impacted customers with at least 30 days’ prior notice before the change takes effect. Notice may be provided by email, through the platform, or by another appropriate method of communication. This notice period is intended to provide customers with a reasonable opportunity to review the proposed changes, understand their potential impact and raise any questions or concerns with us before the changes take effect.
Minor, administrative or clarifying changes that do not materially affect customer or user rights, obligations, privacy, security or data handling may take effect when the updated Privacy Policy is published.
Where a change is required urgently to comply with legal or regulatory requirements, address a security risk or vulnerability, or protect our users, customers or services, a shorter notice period may apply. In these circumstances, we will notify impacted customers as soon as reasonably practicable.
We encourage users and customers to review this Privacy Policy periodically to remain informed about how we collect, hold, use, disclose and protect personal information.
By continuing to access or use our services after any changes to this Privacy Policy take effect, you acknowledge the updated Privacy Policy and the practices described in it. If you do not agree with the updated Privacy Policy, you must not continue to access or use our services.
If you have any questions, concerns or complaints regarding this Privacy Policy or the way we handle personal information, please contact us at hello@thecareersdepartment.com.
We will acknowledge privacy complaints, investigate the matter and aim to provide a response within 30 days.