This policy outlines Industry Currency's commitment to maintaining business and financial viability, appropriate insurance coverage, fit and proper person requirements, and protection of student fees.

This policy contributes to compliance with:

• Outcome Standard(s): 4.2 (Governance and Accountability)
• Compliance Standard(s): 8 (Information Management)
• ISO 9001:2015: 7.5 (Documented Information)

This policy applies to:

• All personal information collected, stored, used or disclosed by Industry Currency
• All staff, contractors and third parties handling personal information on behalf of Industry Currency
• All students, prospective students and other individuals whose information is collected

ASQA means Australian Skills Quality Authority, the national VET regulator and the RTO's registering body.

Compliance Standards means the National Vocational Education and Training Regulator (Compliance Standards for Registered Training Organisations) Instrument 2025.

Data Provision Requirements means the Data Provision Requirements 2020 that set out the information an RTO is required to submit to ASQA.

Documented Information means information required to be controlled and maintained by an organisation, including the medium on which it is contained (ISO 9001:2015 Clause 7.5).

National VET Data Policy means the National VET Data Policy issued by the Australian Department of Education, which includes the National VET Provider Collection Data Requirements Policy.

Outcome Standards means the National Vocational Education and Training Regulator (Outcome Standards for Registered Training Organisations) Instrument 2025.

Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Privacy Act means the Privacy Act 1988 (Cth).

RTO means Registered Training Organisation.

Sensitive Information means information or an opinion about an individual's: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record; health information; genetic information; or biometric information.

Student Identifiers Act means the Student Identifiers Act 2014 (Cth).

Unique Student Identifier (USI) means a unique reference number issued to an individual by the Australian Government, made up of numbers and letters, which enables an individual to access their training records through an online database.

National VET Data Policy is Part B of the National VET Data Policy www.dese.gov.au/national-vet-data/resources/national-vet-data-policy

CEO/Governing Persons

• Ensure compliance with all regulatory requirements
• Provide Annual Declaration of Compliance
• Monitor changes to legislation and standards
• Notify ASQA of material changes within required timeframes

Chief Operations Officer

• Maintain VET Legislation and Regulations Register
• Monitor regulatory updates
• Coordinate internal audits
• Prepare data submissions (AVETMISS, Quality Indicators)

All Staff

• Comply with policies and procedures
• Report compliance concerns
• Participate in compliance training
• Cooperate with audits and investigations

In collecting personal information, Industry Currency complies with the requirements set out in the Privacy Act 1988, including Australian Privacy Principles 3 and 5 (in accordance with the National VET Data Policy clause 4.4).

Personal information, including sensitive information, is collected from individuals in order that Industry Currency can carry out its business functions. Industry Currency only collects and stores information that is directly related to its business purposes and legal requirements of providing nationally recognised training and assessment.

Sensitive information is only collected by Industry Currency if a permitted general or health situation applies in accordance with the Privacy Act (16A, 16B) such as, if:

• The collection of the information is required or authorised by, or under, an Australian law or a court/tribunal order
• It is unreasonable or impracticable to obtain the individual's consent to the collection, use or disclosure
• It genuinely and reasonably believes that the collection, use or disclosure is necessary to lessen or prevent a serious threat to life, health, or safety
• Unlawful activity, or misconduct of a serious nature, that relates to Industry Currency functions or activities has been, is being or may be engaged in
• The collection, use or disclosure is reasonably necessary to assist in locating a person who has been reported as missing
• The collection, use or disclosure is reasonably necessary for the establishment, exercise, or defence of a legal or equitable claim

Industry Currency ensures each individual:

• Knows why their information is being collected, how it will be used and who it will be disclosed to
• Is made aware of any legal requirement for Industry Currency to collect the information
• Is able to access their personal information upon request
• Does not receive unwanted direct marketing
• Can ask for personal information that is incorrect to be corrected
• Can make a complaint about Industry Currency if they consider that their personal information has been mishandled
• Is made aware of any consequences for not providing the information requested
• Whether the information is likely to be disclosed to overseas recipients, and if so, which countries such recipients are likely to be located in

Industry Currency retains evidence that the student has acknowledged the following Privacy Notice and Student Declaration as part of their enrolment process: www.education.gov.au/privacy-notice-and-student-declaration

Under the Data provision requirements 2020, Industry Currency is required to collect personal information about students undertaking nationally recognised training and disclose that personal information to the National Centre for Vocational Education Research Ltd (NCVER).

In general, personal information will be collected through course application and/or enrolment forms, training records, assessment records and online forms and submissions.

The types of personal information collected include:

• Personal and contact details
• Employment information, where relevant
• Academic history
• Background information collected for statistical purposes
• Training, participation, and assessment information
• Fees and payment information
• Information required for the issuance of a USI

All students participating in nationally recognised training from 1 January 2015 are required to have a Unique Student Identifier (USI) and provide it to Industry Currency upon enrolment. Alternatively, Industry Currency can apply for a USI on behalf of an individual.

The Student Identifiers Act 2014 authorises the Australian Government's Student Identifiers Registrar to collect information about USI applicants.

When Industry Currency applies for a USI on behalf of a student, we collect:

• Name, including first or given name(s), middle name(s) and surname or family name
• Date of birth
• City or town of birth
• Country of birth
• Gender
• Contact details

In order to create a USI on behalf of a student, Industry Currency will verify the identity of the individual by receiving a copy of an accepted identification document. This document will only be used for the purposes of generating the USI. Once the USI has been generated and validated, the identity documents will be securely destroyed.

Information disclosure: The information provided in connection with a USI application may be disclosed to Commonwealth and State/Territory government departments, VET Regulators, VET Admission Bodies, RTOs, schools, NCVER, researchers, and other authorised entities for VET administration, policy, and research purposes.

The consequences of not providing the Registrar with personal information are that the Registrar will not be able to issue a USI, and therefore Industry Currency will be unable to issue a qualification or statement of attainment.

Industry Currency will store all records containing personal information securely and take all reasonable security measures to protect the information collected from unauthorised access, misuse, or disclosure. Personal information will be stored electronically in a cloud-based storage to which only authorised staff have access.

The personal information held about individuals will only be used by Industry Currency to enable efficient student administration, report data to provide information about training opportunities, issue statements of attainment and qualifications to eligible students, and to maintain accurate and detailed records of student course participation, progress and outcomes.

Industry Currency may use the personal information provided by an individual to market other internal products and services to them. An individual may opt out of being contacted for marketing purposes at any time by contacting our office. Information will not be passed onto any third-party marketing companies without the prior written consent of the individual.

Industry Currency will not disclose an individual's personal information to another person or organisation unless:

• They are aware that information of that kind is usually passed to that person or organisation
• The individual has given written consent
• Industry Currency believes on reasonable grounds that the disclosure is necessary to prevent or lessen a serious threat to life or health
• The disclosure is required or authorised by law
• The disclosure is reasonably necessary for the enforcement of the criminal law or protection of public revenue

Personal information may be disclosed to:

• Schools - for secondary students undertaking VET
• Employers - where students are enrolled in training paid for by their employer
• Commonwealth and State or Territory government departments and authorised agencies, such as ASQA
• NCVER
• Organisations conducting student surveys
• Researchers

Personal information disclosed to NCVER may be used for:

• Issuing VET qualifications and statements of attainment
• Facilitating statistics and research relating to education
• Understanding how the VET market operates
• Administering VET, including program administration and regulation

Individuals have the right to access or obtain a copy of the information that Industry Currency holds about them including personal details, contact details and information relating to course participation, progress and AQF certification and statements of attainment issued.

Requests to access or obtain a copy of the records held about an individual must be made by contacting our office using the Request to Access Records Form. The individual must prove their identity to be able to access their records.

There is no charge for an individual to access the records that Industry Currency holds about them, however there may be a charge for any copies made. Arrangements will be made within 10 days for the individual to access their records.

Any individual wishing to make a complaint or appeal about the way information has been handled within Industry Currency can do so by following Industry Currency Complaints and Appeals Policy and Procedure.

Website enquiries

Information submitted through website enquiry forms (such as your name, email, and message) is used to respond to your query. This information may be retained for follow-up purposes and to improve our services.

Payment processing

When you make a payment through our website, you are redirected to Stripe, a third-party payment processor. Industry Currency does not collect or store your credit card details. Payment information is handled directly by Stripe in accordance with their privacy policy: stripe.com/au/privacy

Third-party services

Industry Currency uses third-party platforms to support training delivery and administration, including:

• aXcelerate (student management system)
• Stripe (payment processing)

These providers may store and process your personal information in accordance with their own privacy policies. We only share information necessary for the delivery of our services.

Cookies and analytics

Our website may use cookies and analytics tools to understand how visitors use the site. This data is aggregated and is not used to identify individuals. You can disable cookies in your browser settings.

This policy will be reviewed on an annual basis from the date of the latest release. Please refer to the internal quality review schedule for more information.

• Outcome Standards for RTOs 2025
• Compliance Standards for RTOs 2025
• National VET Regulator Act 2011
• Data Provision Requirements 2020
• ISO 9001:2015 Quality Management Systems