PRIVACY AND CONFIDENTIALITY POLICY

1. PURPOSE AND SCOPE

The purpose of this policy is to outline Thrive Learning Co.’s requirements for collecting, using, storing, and disclosing personal and confidential information relating to employees, tutors, students, contractors, and other stakeholders.

This policy applies to:

• All staff involved in the management and administration of staff, tutor, and student records
• All employees, contractors, and tutors engaged by Thrive Learning Co.
• Any individual who may have access to sensitive information in the course of their engagement
• All information handled inside or outside work hours, whether in hard copy, electronic systems, or verbally

The obligation to maintain privacy and confidentiality continues after employment or engagement ends.

2. LEGISLATIVE CONTEXT

This policy is guided by the following legislation relevant to tutoring and education service providers operating in Australia:

Commonwealth

• Privacy Act 1988 (Cth)
• Australian Privacy Principles (APPs)
• Privacy Regulation 2013

New South Wales

• Privacy and Personal Information Protection Act 1998 (NSW) (PPIP Act)
  (Applicable when information is exchanged with NSW public sector entities or where a NSW-based individual’s privacy rights are engaged.)

NOTE: Although Thrive Learning Co operates under the ACE Community Colleges ABN, no RTO legislation has been applied as it does not deliver nationally recognised training.

3. INFORMATION REQUISITES

Thrive Learning Co. collects and holds personal information necessary to:

• Manage employment, tutor arrangements, and contractor engagements
• Verify qualifications and experience
• Conduct enrolments and identity checks
• Provide tutoring services delivered in-person or through Vedamo
• Support students and communicate with families/carers
• Process payments and subscription-based communication where consent is given
• Meet any legal or regulatory obligations applicable to tutoring businesses

Types of information collected

Personal Information:
Name, address, contact details, date of birth, nationality, emergency contact information, and other details defined as personal information under the Privacy Act 1988.

Financial Information:
Banking or payment information used to complete transactions.

Online and Statistical Information:
Website analytics, LMS activity logs, session attendance, platform preferences, and information provided through surveys or feedback systems.

Information Provided Directly by the Individual:
Emails, uploaded learning materials, assessments, parent/guardian communication, session notes, or documentation submitted through Vedamo or directly to tutors.

Third-party services

Thrive Learning Co. uses external service providers—including Vedamo Virtual Classroom—to deliver tutoring services, manage learning activities, and store information.

Personal information stored through these platforms is subject to the privacy policies and security measures of those third-party providers.

4. POLICY STATEMENT

4.1 Information Collection

Thrive Learning Co. ensures that personal information:

• Is collected only when relevant to service delivery or business operations
• Is collected lawfully and fairly
• Is accurate, complete, and up-to-date where reasonably practicable
• Is used only for the purpose for which it was collected
• Is collected for subscription or marketing purposes only on an opt-in basis

4.2 Information Retention and Security

Information may be stored electronically (including in Vedamo and secure cloud systems) or in hard copy.

Thrive Learning Co. will:

• Retain information only as long as required under law or for business purposes
• Take reasonable steps to protect information from unauthorised access, loss, misuse, or modification
• Destroy or de-identify information once no longer required
• Store archived information securely where retention is necessary

Thrive Learning Co. is not responsible for the privacy practices of third parties who are permitted to receive information under this policy or under relevant laws.

4.3 Online and In-Person Tutoring Delivery Using Vedamo

Thrive Learning Co. uses Vedamo Virtual Classroom and LMS as its sole platform for:

• Online tutoring sessions
• Supporting in-person tutoring through digital activity management
• Uploading resources, communicating with students, and facilitating interactive learning

Based on Vedamo’s publicly available privacy policy:

• Vedamo processes personal information (such as names, login details, activity logs, files uploaded by users, recordings where enabled) only for providing the platform’s services
• Vedamo stores data on servers located in the European Union (EU) and applies security controls compliant with EU data protection standards
• Vedamo may use cookies, log information, and technical identifiers to ensure platform performance
• Third-party processors may be used for hosting or maintenance under contractual confidentiality obligations

More information can be accessed on the Vedamo Website – https://www.vedamo.com/page/id/3/

Thrive Learning Co. will ensure all users (students, parents, tutors) are informed of how their data may be stored and processed through Vedamo.

5. DISCLOSURE OF INFORMATION

Thrive Learning Co. will not disclose personal information to third parties without consent except where:

• Required or authorised by law (Commonwealth or State)
• Necessary to prevent or lessen a serious threat to life, health, or safety
• Authorised in writing by the individual or a parent/guardian for minors
• An individual becomes legally incapable of managing their affairs and information may be released to a parent, guardian, or attorney
• Required for payment processing, communication services, or LMS functionality (e.g., data processed through Vedamo)

Students and parents/guardians will be informed at enrolment if their data may be disclosed to any external platform or service provider as part of normal tutoring operations.

Where judgement is required prior to disclosure (e.g., emergencies), approval must be sought from the Principal or Consumer Protection Officer, unless delay would cause harm.

6. ACCESS TO RECORDS

Individuals may request access to their personal information by submitting a written request.

Access may be granted where:

• Proof of identity is provided
• Access does not compromise the privacy of others
• Viewing is supervised where appropriate
• Records are not removed or altered

Access may be lawfully refused in circumstances where release would:

• Endanger another person’s privacy or safety
• Breach a legal or contractual obligation
• Be deemed inappropriate under relevant legislation

7. RESPONSIBILITY

All staff, tutors, contractors, and stakeholders with access to private or confidential information are responsible for protecting that information in accordance with:

• This policy
• The Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
• Privacy and Personal Information Protection Act 1998 (NSW), where applicable
• Thrive Learning Co. operational procedures