1. What is the purpose of this document?
The University respects individuals’ privacy and is open and transparent about how it handles all personal information.
This document describes how we collect and use your personal data during the admissions process, in accordance with the relevant legislation.
This statement applies to prospective students, that is anyone applying to become a student of the University of Divinity either directly or through one of the Colleges. It is important that you read this Privacy and Collection Statement, together with any other privacy policy or statement we may provide on specific occasions when we are collecting or processing information about you, so that you are aware of how and why we are using the information. We may update this Privacy and Collection Statement at any time.
In addition, each College will have its own privacy framework.
2. Who is using your personal data
The University of Divinity is the “Australian Privacy Principles entity” or “data controller” for the information that we obtain from you or others as a result of your application for study. This means that we decide how to use it and are responsible for looking after it in accordance with relevant legislation.
Access to your data will be provided to the University’s staff, including those based in the University’s colleges, who need to view it as part of their work in carrying out the purposes set out in Section 5. We also share it with the third parties described in Section 7.
3. The types of data we hold about you
The information we hold about you may include the following:
- Personal details such as name, title, address, telephone number, email address, date of birth, sex and gender identity, ID photograph (included within received documents);
- Education information (including the school(s) and other colleges or universities you have attended, the courses you have completed, dates of study and examination results);
- Other personal and socio-economic background information collected during the admissions process, e.g. country of origin, languages spoken, citizenship and details of your parents’ education;
- Visa, passport and immigration information;
- Your feedback on the application process and university services collected through surveys such as (but not limited to) those sent to applicants and offer-holders;
- Attendance records at University, College or School organised events, and photographic and videographic data of such events captured for the purpose of live streaming and/or future publicity materials;
- Information about your use of our IT systems (such as website logging);
- Information about your use of our information and communications systems, including your communication preferences and website interaction (cookies and similar technologies); and
- Information about the overall attainment at the school where you took your qualifications (which is used to help us understand your attainment with that context).
We may also process the following “special categories” of more sensitive
personal data:
- Information about your race or ethnicity, religion and beliefs;
- Information about your health, including any disability and/or medical conditions;
- Information about criminal convictions and offences (if applicable to your course).
Special category data will not be used to assess your application and will only be used in accordance with section 7.
In addition, we may also process personal data that we receive or request from any third party in connection with recruiting activities to consider your application.
In submitting your application, where you provide the University with the personal data of others (e.g. the names and contact details of your parents/guardians) you are encouraged to inform them that:
- you are disclosing that information to the University;
- if your application is successful, the information will be retained; and
- they can access that information by contacting the University’s Office of the
Vice-Chancellor.
Your personal data is created, stored and transmitted securely in a variety of paper and electronic formats. This includes databases that are shared across the University. Access to your personal data is limited to University, College and Schools’ representatives who have a legitimate interest in it for the purpose of carrying out their duties.
4. How the University Obtained Your Data
The personal data processed by us will include the details you directly provide to us in your application forms, any supporting documents that we request as part of the admission process, and additional details provided by any referees and anything recorded following any interview process.
We may also collect additional information directly from you and from third parties, including referees, former schools, colleges and universities, and government departments and agencies.
5. How the University Uses Your Data
The personal data processed by us, or processed on our behalf, is needed for the purposes of identifying you, considering your application for admission to study at the University, verifying the information provided in your application, communicating the outcome of your application and, if you are successful, to commence the enrolment process on your behalf. If you choose not to provide the information requested, it may not be possible for the University to consider you for admission. We consider that the lawful basis for the processing of your personal data is that it is necessary for the pursuit of the legitimate interests of the University to consider your application for admission to study at the University.
We process your data for the purpose of assessing your application for study, and for purposes related to your application, such as assessing your eligibility for funding and your financial status. We set out below those circumstances where it is necessary for us to process your data. (These circumstances are not mutually exclusive; we may use the same information under more than one heading.)
5.1 Because we have a contractual obligation to consider your application
Information processed for this purpose includes the data listed in section 4 above.
We also need to process data under this heading where the University is working with a third party in order to offer you services, for example, those offered by the colleges or scholarship benefactors. See section 8 for a fuller list of examples of third party sharing.
5.2 Where we need to comply with a legal obligation
Information processed for this purpose includes, but is not limited to, information relating to the monitoring of equal opportunities. We are also required by law to provide data to various Australian Government departments through the Department of Education and Tertiary Collection of Student Information (TCSI).
5.3 Where it is necessary to meet our legitimate interests
We also need to process your data in order to meet our legitimate interests or the legitimate interests of others. Examples include, but are not limited to, the following:
- inviting you to take part in applicant surveys or enabling third parties to
conduct applicant surveys on our behalf; - asking you to provide additional information on your application;
- and notifying you of changes to course information.
5.4 Where we have your consent
There may be situations where we ask for your consent to process your data e.g. where we ask you to volunteer information for a survey (you will always be able to opt out of receiving such communications).
If you fail to provide personal information under 5.1 or 5.2 above
If you fail to provide certain information when requested under the circumstances described in 5.1 and 5.2 above, we may not be able to meet our contractual obligation to consider your application or to comply with our other legal obligations.
Change of purpose
We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose.
Please note that we may process your data without your knowledge or consent where this is required or permitted by law.
6. Special Category or Sensitive Data
Special category or Sensitive data require a higher level of protection. Listed below are examples of processing activities that we regularly undertake in respect of these types of data. In addition to the activities listed below, it may sometimes be necessary to process this sort of information for exceptional reasons, for example, because it is necessary to protect your vital interests or those of another person. We may also process your special category data to identify your eligibility for certain scholarships aimed to address underrepresentation.
6.1 Disability
We will process data you have volunteered about any disability in order to make any arrangements or adjustments required in relation to your application (e.g. to arrange access for interviews) and/or to monitor equal opportunities. We may share this data, for the same reasons, with the University’s colleges.
6.2 Racial or ethnic origin and religious belief
Data about your racial and ethnic origin or religious belief will only be processed where you have volunteered it and where we need to process it in order to meet our statutory obligations.
7. Data Sharing with Third Parties
We may share your personal data with a range of third parties, including the following:
- government departments such as the Australian Taxation Office, Department of Education, Science and Training, and the Department of Immigration and Citizenship;
- agencies and organisations involved in quality assurance and planning for higher education such as federal and state government and TEQSA;
- external organisations such as former employers, secondary schools, other tertiary education institutions, and tertiary admission centres, and the MyEquals verification service and English language testing verification service to verify your qualifications or experience for the integrity of the selection process;
- contracted service providers which the University uses to perform services on its behalf (such as recruitment and course administration, banks, mailing houses, logistics, IT service providers and caterers for University events);
- off-shore campuses and educational institutions for any overseas or cross institutional study undertaken by you;
- University of Divinity owned entities and subsidiary companies and affiliates of the University (‘University affiliates’);
- seminary and/or religious superior (for seminarians and members of religious orders);
- your parent/s guardians where deemed appropriate and under applicable laws; and
- in the event of an emergency, police, medical or hospital personnel, civil emergency services, your legal representative or nominated emergency contact person, or other person assessed as necessary to respond to the emergency.
Where personal data is disclosed to third parties, it will be done so only to the extent necessary to fulfil the purpose of such disclosure.
8. Transfer of Your Data Overseas
There may be occasions when we transfer your data outside Australia, for example, to obtain a reference or to verify information in your application. Such transfers will only take place if one of the following applies:
- the country receiving the data is considered by Australia to provide an adequate level of data protection, this includes countries in the European Economic Area;
- the organisation receiving the data is covered by an arrangement recognised by Australia as providing an adequate standard of data protection;
- the transfer has your consent;
- the transfer is necessary for the performance of a contract with you or to take steps requested by you prior to entering into that contract;
- or the transfer is governed by approved contractual clauses.
9. Retention Period
We will retain your data only for as long as we need it to meet our purposes, including any relating to legal, accounting, or reporting requirements.
If you enrol as a student, your data will be processed in accordance with our Student Privacy and Collection Statement which is available here.
10. Your Rights
In addition to your rights to access and correct your personal data and lodge a complaint relating to how we handle your personal data, if the GDPR applies, you may, under certain conditions, have the following rights available:
- to object to any processing of your personal data that we process on the lawful basis of legitimate interests, unless our reasons for the underlying processing outweighs your interests, rights and freedoms;
- to withdraw your consent where we have processed any of your personal data based on consent;
- to object to direct marketing (including any profiling) at any time;
- to ask us to delete personal data that we no longer have lawful grounds to process; and
- to object to the use of automated decision making.
11. Keeping Your Data Up-to-Date
It is important that the data we hold about you is accurate and current. You can access, amend and delete your data yourself until the point at which you submit your application to the University. Please keep us informed of any changes after you submit your application.
12. Changes to this Privacy and Collection Statement
We reserve the right to update this privacy and collection statement at any time, and will seek to inform you of any substantial changes. We may also notify you in other ways from time to time about the processing of your personal data.