Records Management and Archiving Policy

The College is committed to maintaining the safety and security of all its records and ensuring that private and confidential records are viewed only by the personnel authorised to access them on a need-to-know basis. The current records of the College may be categorised as follows:

• Student Records
• Finance and Operational Records

1 Access to Student Records

Student records may be accessed by the following College personnel:

1. a) The person whose responsibilities include collection, collation and processing of the record (“the Record Keeper”);
2. b) the Director of Academic Administration and Quality Assurance;
3. c) other officers authorised by the College to collect, collate, record and maintain records of personal and academic history of students;
4. d) Student Support Officer and Dean of Students.

1.1 Nature and purpose of student records

Student records may be in hard copy form, or electronic form, but frequently in both forms. The student records currently maintained by the College are described in the following table:

(At present, all student records are kept indefinitely. Records referenced with * are completed anonymously and individual students cannot be identified. Records referenced with ^ are directly accessible to students currently enrolled in the relevant course of study.)

1.2 Students rights

Students have the right to request a statement describing the information held in their personal files. On receipt of such a request, the College has the obligation to supply in a timely manner, a statement which describes:-

• the nature of the information held;
• the main purposes for which the information is used; and
• how individuals may go about getting access to personal information which relates to themselves.

Students (including past students) who wish to access their personal records are required to notify the College and arrange an appointment to view their records. In extenuating circumstances a student may delegate this authority in writing on the approval and verification of the Dean of Students. Students will be provided with access to their records, in particular hard copy records and printed versions of softcopy records but the following limitations would apply:-

• students who access their records would be supervised, that is, the Record Keeper would be present while the record is being viewed.
• students may request, and be supplied with, photocopies of any documents in the student’s personal record;
• students would not be permitted to remove any documents from the record; however,
• students may request that incorrect or out of date information in their personal records be removed or updated. The Record Keeper shall be responsible for taking this action.
• students who are in dispute with the Record Keeper over any matter regarding their records, shall have the right to take action according to the College’s Complaints & Grievance Procedures (non-academic).

2 Financial and Operational Records

The current finance and operational records maintained by the College may be categorised as:

• Staff personal details and remuneration;
• Donors and donations;
• Income and expenditure;
• Finance and Audits;
• Minutes of Meetings-Board, Sub-Committees, Staff;
• Commercial Relationships – Agreements, Memorandums of Understanding, Partnerships

2.1 Access to financial and operational records

The financial and operational records of the College may be accessed by the following College Personnel on a need-to-know basis:

1. a) The Principal;
   b) Chief Operations Officer;
   c) Finance Officer/CFO, and delegate;

   e) Director of Academic Administration and Quality Assurance or Delegate; and
   f) Governing Board members, including sub-committee members.

2.2 Nature and purpose of financial and operational records

The financial and operational records may be in hard copy form, or electronic form, but frequently in both forms. The financial and operational records currently maintained by the College are described in the following table:

(# Records referenced with # are kept indefinitely.)

3. Archival Policy

As the College is a small educational institution, all student records shall be kept permanently. This arrangement exceeds the minimum retention period (30 years) required by accreditation and registration agencies with respect to students’ educational records. Financial Records shall generally be kept for seven (7) years. This arrangement exceeds the minimum retention period (5 years) required by Audit and Government Regulatory Agencies and the Australian Taxation Office.

Other budget, cash flow and Partnership agreement records shall be maintained for a period of ten (10) years.

Destruction of records after the required retention period shall be supervised by the Director of Academic Administration and Quality Assurance with respect to student records, and by the Chief Operations Officer with respect to all financial and operational records. Records identified for destruction shall be secured in locked “confidential wheelie bins” and collected by a corporate records destruction company which guarantees their confidential destruction.

4. Our disclosure practices

We disclose personal information about our students to:

• education providers to administer cross-institution enrolments (where you are a cross-institution student or student enrolled with the College and another provider under an approved arrangement)
• education providers to verify academic information or transcripts
• scholarship providers and student sponsors where there is a written agreement between the student and the provider or sponsor.

The College discloses whether a graduate has completed an award to any member of the general public via requests for verification of qualifications.
The College is required by law to provide personal information about our students to:

• the Commonwealth Department of Education (routinely, statistical information about student enrolment, educational background, etc)
• the Australian Taxation Office (in relation to HECS-HELP, FEE-HELP and other loan schemes where students may defer fee payments through the taxation system)
• the Commonwealth Government on student request for Commonwealth support or financial assistance, and particularly if you request financial assistance by submitting an electronic or paper Commonwealth Assistance Form. You will be asked to consent to personal, identifying data, including your Tax File Number, being provided to the Australian Government for the allocation of a unique identifier and the management of your Commonwealth assistance notice
• Centrelink (which requires the College to provide information to monitor domestic student entitlements to Centrelink benefits)
• other governments and private loan schemes where students are granted approved loans
• the Victorian Institute of Teaching for students graduating in relevant education awards.

We also make class lists available to other students enrolled in the same unit.

Disclosure without consent or prior notification
In very limited circumstances, privacy principles permit disclosure without consent or prior notification, for example, if we are asked for the information in connection with a police investigation; if we receive a writ, subpoena or similar document legally requiring us to disclose the information; or if disclosing the information will prevent or lessen a serious and imminent threat to a person’s life or health. These circumstances are extremely rare.