Privacy Policy

1. About this policy

Happy Steps Early Learning Centre (“Happy Steps”, “we”, “us” or “our”) respects the privacy of children, families, employees, applicants, visitors and other people who interact with our service.

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information. We aim to manage personal information consistently with the Privacy Act 1988 (Cth), the Australian Privacy Principles where applicable, the Education and Care Services National Law and Regulations, Child Care Subsidy requirements and other applicable Australian laws.

Because we provide education and care to children, some of the information we handle is sensitive. We take the privacy, dignity, safety and wellbeing of children and families seriously.

2. Personal information we may collect

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

• Names, addresses, telephone numbers and email addresses.
• Dates of birth and identity information.
• Parent, guardian, authorised nominee and emergency-contact details.
• Information about a child’s enrolment, attendance, routines and care requirements.
• Child Care Subsidy, Customer Reference Number and enrolment information where required.
• Payment, billing and account information.
• Health, medical, allergy, dietary, disability, immunisation and medication information.
• Information about developmental, behavioural, cultural, linguistic, religious or additional support needs.
• Court orders, parenting arrangements, authorised collection details and custody information where relevant.
• Incident, injury, illness, medication and emergency records.
• Learning observations, assessments, portfolios and educational records.
• Photographs, videos, audio recordings and digital learning documentation where authorised.
• Communications, enquiries, feedback, complaints and survey responses.
• Employment, contractor, volunteer and student-placement information.
• Website usage, enquiry-form and advertising information, including IP address, browser type, device information, referring page, cookies and advertising identifiers.
• Any other information reasonably necessary to provide education and care, respond to an enquiry or comply with our legal obligations.

Some of this information may be sensitive information under Australian privacy law. We collect sensitive information where it is reasonably necessary for our functions, where consent has been provided or where collection is authorised or required by law.

3. How we collect information

We generally collect personal information directly from parents, guardians, authorised representatives, employees, applicants and other individuals.

Information may be collected through:

• Enrolment and attendance records.
• Centre tours, telephone calls, emails and face-to-face conversations.
• Our website and online enquiry forms.
• The $1 per day enquiry form.
• The Parents Pack form.
• Google Ads lead forms and other advertising platforms.
• Our childcare management and communication platform, OWNA.
• Child Care Subsidy and government administration systems.
• Medical practitioners, allied health professionals or support agencies with appropriate authority.
• Schools, previous education and care services or authorised professionals.
• Emergency contacts and authorised nominees.
• Employment applications, reference checks and staff records.
• Photographs, videos, observations and documentation created as part of our education and care program.
• Other sources where authorised by the individual or permitted by law.

Where practical, we collect personal information directly from the person concerned or from a child’s parent, guardian or authorised representative.

If requested information is not provided, we may be unable to process an enquiry, assess eligibility for an offer, enrol a child, provide appropriate education and care, meet a child’s health and safety needs or comply with our legal obligations.

4. Why we collect and use personal information

We may collect, hold and use personal information to:

• Respond to childcare enquiries and arrange centre tours.
• Assess current availability and enrolment requirements.
• Contact families about the $1 per day gap-fee promotion and assess potential eligibility.
• Deliver requested resources, including the Parents Pack.
• Enrol children and provide education and care.
• Support children’s learning, development, health, safety and wellbeing.
• Communicate with parents, guardians and authorised representatives.
• Manage attendance, fees, payments and Child Care Subsidy obligations.
• Maintain records required under education, care, employment, taxation and other laws.
• Manage medical conditions, allergies, incidents, injuries, medication and emergencies.
• Develop and document children’s educational programs and learning.
• Manage permissions for photographs, videos, excursions and activities.
• Recruit, employ and manage staff, contractors, volunteers and students.
• Improve our centre, website, services, communications and advertising.
• Prevent fraud, investigate incidents, manage complaints and protect legal rights.
• Comply with legal, regulatory, funding, reporting and safeguarding obligations.
• Carry out administrative, insurance, auditing and business-management functions.

We will not use personal information for an unrelated purpose unless consent has been provided or the use is otherwise authorised or required by law.

5. Children’s information, photographs and videos

We recognise that children’s information requires particular care.

Information about a child is collected and used only where reasonably necessary to provide education and care, support the child’s safety and development, communicate with authorised family members or comply with our obligations.

Photographs, videos and learning documentation may be used for educational records and shared with authorised families through approved systems, including OWNA, in accordance with centre procedures and family permissions.

We will only use identifiable images of children for public marketing, social media or promotional purposes where the required permission has been obtained. Where appropriate, children’s faces may be blurred or images may be selected so children are not identifiable.

Parents and guardians should not download, copy, publish or share images containing other children without appropriate permission.

6. OWNA and other service providers

Happy Steps uses OWNA as a childcare management, documentation and family-communication platform. Personal information entered into OWNA may include enrolment information, authorised-contact details, attendance records, health information, learning documentation, photographs and communications.

OWNA acts as a technology service provider supporting our childcare operations. Access is restricted according to authorised roles and account permissions. OWNA states that its childcare data is stored within Australia.

We may also use other service providers for:

• Website hosting and online forms.
• Email and document storage.
• Payment processing and accounting.
• Information technology and cybersecurity.
• Advertising and analytics, including Google.
• Professional advice, insurance and auditing.
• Government reporting and Child Care Subsidy administration.

These providers may only receive information reasonably necessary to perform their services or where disclosure is authorised or required by law.

7. When we may disclose personal information

We may disclose personal information to:

• Parents, guardians and authorised nominees.
• Our educators, employees, contractors, volunteers and students where access is necessary.
• OWNA and other approved technology providers.
• Medical practitioners, hospitals and emergency services.
• Schools, allied health professionals and support agencies where authorised or legally permitted.
• Child Care Subsidy and other relevant government agencies.
• Regulatory authorities, law-enforcement bodies and child-protection agencies.
• Insurers, auditors, accountants, legal advisers and other professional advisers.
• Website, email, payment, advertising and information-technology providers.
• Other parties where consent has been provided.
• Any person or organisation where disclosure is authorised or required by law.

We do not sell personal information.

8. Overseas processing and disclosure

Some technology and online service providers, including Google and certain website, email, analytics or advertising providers, may process, store or permit access to information outside Australia. These locations may include the United States and other countries in which those providers operate.

OWNA states that its childcare data remains within Australian borders.

Where personal information may be disclosed to an overseas recipient, we take reasonable steps appropriate to the circumstances and consider the privacy and security practices of the provider. However, overseas recipients may be subject to different privacy laws.

9. Website, cookies and advertising

Our website may use cookies and similar technologies to:

• Make the website function correctly.
• Remember preferences.
• Understand how visitors use the website.
• Measure website and advertising performance.
• Support Google Ads conversion measurement.
• Improve our website and communications.

Information collected through these technologies may include IP address, browser type, device information, pages viewed, approximate location, referral information and advertising identifiers.

Visitors can adjust cookie settings through their browser. Disabling some cookies may affect website functionality.

Information submitted through website or Google Ads forms is used to respond to the person’s request and manage the relevant childcare enquiry. Consent to be contacted may be withdrawn at any time.

10. Direct marketing

Where permitted, we may use contact information to communicate about childcare availability, centre tours, enrolment opportunities, resources, programs or relevant promotions.

Individuals may opt out of marketing communications at any time by using an unsubscribe option where provided or contacting us directly. We may still send essential service, enrolment, safety, billing or administrative communications.

11. How we protect personal information

We take reasonable administrative, physical and technical steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

These measures may include:

• Role-based access and account permissions.
• Password and authentication controls.
• Secure childcare-management and communication systems.
• Staff confidentiality obligations and privacy training.
• Controlled access to physical and electronic records.
• Secure transmission, storage, backup and disposal practices.
• Reviewing access when employment or authorised access ends.
• Responding to suspected privacy and cybersecurity incidents.

No electronic transmission or storage method is completely secure. If a data breach occurs, we will assess and respond to it in accordance with applicable legal requirements, including the Notifiable Data Breaches scheme where applicable.

12. Retention and disposal

We retain personal information for as long as reasonably necessary to provide our services and meet our legal, regulatory, insurance, employment, taxation and recordkeeping obligations.

Different records may be subject to different legal retention periods. When personal information is no longer required and we are legally permitted to dispose of it, we take reasonable steps to securely destroy or de-identify it.

13. Accessing or correcting personal information

Individuals may request access to personal information we hold about them or their child and may ask us to correct information that is inaccurate, incomplete, out of date or misleading.

To protect privacy, we may ask for proof of identity or authority before providing access or making a correction.

In some circumstances, access may be limited or refused where permitted or required by law, including where providing access could unreasonably affect another person’s privacy or create a safety risk. If access or correction is refused, we will explain the reason where legally permitted.

Requests may be made using the contact details below.

14. Privacy enquiries and complaints

Questions, access requests, correction requests or privacy complaints can be directed to:

Please provide enough information for us to understand and investigate the matter.

We will acknowledge and investigate privacy complaints fairly and aim to provide a response within 30 days. More complex matters may take longer, and we will keep the complainant informed where appropriate.

15. Anonymity and pseudonyms

Where practical and lawful, individuals may interact with us anonymously or using a pseudonym for general enquiries.

However, identification is generally required when enrolling a child, arranging education and care, processing payments or Child Care Subsidy, managing safety and emergencies, responding to formal access requests or meeting legal obligations.

16. Automated decisions

Happy Steps does not currently use personal information in a fully automated system to make decisions that could reasonably be expected to significantly affect a person’s rights or interests.

If this practice changes, this Privacy Policy will be updated as required.

17. Changes to this policy

We may update this Privacy Policy when our services, technology, legal obligations or information-handling practices change.

The current version will be published on our website with the date it was last updated.