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Policies

Please find a full list of Immanuel College policies below.

Child Safety Policy & Code of Conduct

IMMANUEL COLLEGE CHILD SAFE POLICY

This Child Safe Policy has been developed in accordance with and implements Principle 1 of the National Principles for Child Safe Organisations (National Principles).

The Child Safe Policy is published on the College’s public website and provided to new Staff, and to Volunteers and Contractors at induction. It is also communicated through other mediums such as newsletters, external and internal websites, and welcome/induction packs.

Purpose

Our Child Safe Policy, which includes our Statement of Commitment to Child Safety, was written to demonstrate the strong commitment of Immanuel College to promoting children’s wellbeing and safeguarding children from harm, and to provide an outline of the policies and practices that we have developed to keep our students safe, including from abuse or other harm.

It is an overarching policy that provides the key elements of our approach as a child-safe organisation and sets the tone for the College’s entire Child Safe Program.

The Child Safe Policy provides the framework for:

  • implementing the National Principles,
  • developing systems, practices, policies and procedures that promote child protection within Immanuel College,
  • creating a safe and supportive environment and a positive and robust child protection culture,
  • promoting and openly discussing child safety issues within the College, and
  • complying with all laws, regulations and standards relevant to child protection in South Australia.

Scope

The Immanuel College Child Safe Policy applies to all adults in the College, including Staff, Volunteers, Contractors, External Education Providers, parents/carers and other family members. This Policy applies in all College environments, both physical and online, and on-site and off-site grounds (e.g. camps and excursions).

Statement of Commitment to Child Safety

All children and young people who come to Immanuel College have a right to feel and be safe. We are committed to providing a child-safe and child-friendly environment, where children and young people are safe and feel safe, and are able to actively participate in decisions that affect their lives.

We have a zero-tolerance for harm to children and young people and are committed to acting in students’ best interests and keeping them safe from harm.

The College regards its child safety responsibilities with the utmost importance and as such, is committed to providing the necessary resources to ensure compliance with all relevant child protection laws and regulations and maintaining a child-safe culture.

Each member of the College has a responsibility to understand the important and specific role that they play individually and collectively to ensure that the well-being and safety of all students is at the forefront of all that they do and every decision that they make.

Child Safe Standards

The National Principles for Child Safe Organisations

The National Principles were developed by the Australian Human Rights Commission in response to recommendations of the Royal  Commission into Institutional Responses to Child Sexual Abuse. The National Principles are comprised of 10 Principles that were informed by but go further than, the 10 Child Safe Standards recommended by the Royal Commission. They are:

Children and Young People’s Rights to Safety, Information and Participation

Immanuel College is a child-safe and child-centred organisation. Our environment is friendly and welcoming to all children and young people.

We actively seek to include students in decisions that affect them. This includes decisions about organisational planning, delivery of services, management of facilities, and learning and assessment environments.

We ensure students know about their rights to safety, information and participation. We recognise the importance of friendships and support from peers. We actively seek to understand what makes students feel safe in our College and regularly communicate with students about what they can do if they feel unsafe.

Parents/Carers, Families and Community Involvement at Immanuel College

Immanuel College recognises that parents and carers have the primary responsibility for the upbringing and development of their children. We ensure they participate in decisions affecting their children.

We ensure that families and relevant communities (Aboriginal and Torres Strait Islander communities, culturally and linguistically diverse communities, other communities that make up our Staff and student cohort, and the local community in which the College operates) know about the College’s operations and policies, including the Child Safe Policy and Child Safe Codes of Conduct, record-keeping practices, risk management, and complaints and investigation processes.

We actively seek to include families and relevant communities in decisions about organisational planning, delivery of services, management of facilities, and learning and assessment environments.

We build cultural safety at the College through partnerships with relevant communities.

Valuing Diversity in the College

Immanuel College values diversity and does not tolerate any discriminatory practices. To achieve this, we:

  • support the cultural safety, participation and empowerment of Aboriginal and Torres Strait Islander students and their families,
  • support the cultural safety, participation and empowerment of students from culturally and linguistically diverse backgrounds and their families,
  • support students with a disability and their families and act to promote their participation,
  • welcome students and families of diverse sexuality and act to promote their participation,
  • seek to recruit a workforce that reflects a diversity of cultures, abilities and identities,
  • ensure that all Staff, Direct Contact Volunteers and Direct Contact Contractors have training about Aboriginal and Torres Strait Islander cultures, disability, culturally and linguistically diverse backgrounds, and communities with particular experiences or needs,
  • have a physical environment that actively celebrates diverse cultures and recognises cultural difference, and
  • commit to ensuring that our facilities promote the inclusion of students of all abilities.

Our Child Safe Program

Immanuel College is committed to the effective implementation of our Child Safe Program and ensuring that it is appropriately reviewed and updated. We adopt a risk management approach by identifying key risk indicators and assessing child safety risks based on a range of factors including the nature of our activities, physical and online environments and the characteristics of the student body.

Our Child Safe Program relates to all aspects of child safety and protecting students from harm, and establishes work systems, practices, policies and procedures to create and maintain a child-safe environment and culture at the College. It includes:

  • Child Safe Codes of Conduct,
  • clear information as to what constitutes harm and associated key indicators of different forms of harm to children,
  • procedures for reporting to external agencies, including Mandatory Notifications to the Department for Child Protection (DCP), and Reporting to Police, which make clear that all Staff, Volunteers and Contractors must, as their first priority, fulfil their legal obligations to report harm or risk of harm to a child to the Child Abuse Report Line (CARL) and to Police,
  • procedures for reporting to external agencies, including Mandatory Notifications to DCP, and Reporting to Police, which make clear that all Staff, Volunteers and Contractors must, as their first priority, fulfil their legal obligations to report harm or risk of harm to a child externally,
  • clear procedures for reporting child safety incidents or concerns internally, and for responding to incidents or allegations  of harm to a child or young person,
  • strategies to support, encourage and enable Staff, Volunteers, Contractors, parents/carers and students to understand, identify, discuss and report child safety matters,
  • procedures for recruiting and screening members of the Executive Team, Staff, Volunteers and Contractors,
  • pastoral care strategies designed to empower students and keep them safe,
  • strategies to support and encourage the participation and inclusion of Aboriginal and Torres Strait Islander students, students from culturally and/or linguistically diverse backgrounds and students with disability,
  • child safety training,
  • information regarding the steps to take after a disclosure of harm to protect, support and assist students,
  • guidelines with respect to record-keeping and confidentiality,
  • policies to ensure compliance with all relevant laws, regulations and standards (including the National Principles)
  • a system for continuous review and improvement.

As a part of Immanuel College’s induction process, all Staff, as well as Volunteers and Contractors are required to complete induction in our child safety policies, practices and procedures. All Staff, as well as Volunteers and Contractors also receive refresher and ongoing child safety training.

Staff, Contractors, and Volunteers are supported and supervised by the College’s Child Safety Officers and Executive Team to ensure that they are compliant with the College approach to child safety.

Reporting Child Safety Incidents or Concerns to the Immanuel College

Any person, including a staff member, Volunteer, Contractor, parent/carer or student, can at any time report a reasonable suspicion about harm to a child or young person directly to CARL on 13 14 78 or online.

CARL is open 24 hours a day, seven days a week.

Whenever there are concerns that a child is in immediate danger the Police should be called on 000.

If you need guidance on making a report or have questions regarding child safety, contact one of the Child Safety Officers.

Our Child Safe Program provides detailed procedures with respect to the reporting of child safety incidents and concerns to relevant external authorities.

It also contains detailed guidance for Members of the Council, Staff, Volunteers and Contractors on how to identify key indicators of different forms of harm to children and young people and how to report child safety incidents or concerns:

  • to relevant external authorities, including DCP and the Police
  • internally to one of our College Child Safety Contact Officers.

Students at the College are provided with information about and encouraged to use multiple pathways to raise child safety incidents or concerns about or at the College. These include contacting CARL and/or reporting internally to the College via informal and formal ways, an ‘anonymous’ way, and through external child advocacy or child safety organisations.

Parents/carers, family members and other community members who have child safety concerns or who suspect that a child or young person associated with the Immanuel College may be subject to harm should immediately contact CARL. They should then  also contact:

  • the Immanuel College Senior Child Safety Officer Kevin Richardson, by phoning 8375 1770 or emailing childsafe@immanuel.sa.edu.au, or
  • if the concern relates to the Principal, the Chair of the Council.

Any person can also contact the Senior Child Safety Officer if they have concerns regarding College leadership in relation to child safety.

Communications will be treated confidentially on a “need to know basis”.

Whenever there are concerns that a child is in immediate danger the Police should be called on 000.

Responsibilities for Child Safe at the Immanuel College

Child safety is everyone’s responsibility. All adults in the College have a shared responsibility for contributing to the safety and protection of students. Specific responsibilities include:

College Child Safety Officers

A number of senior staff members are nominated as the College’s Child Safety Officers. Our Child Safety Officers receive additional specialised training with respect to child safety and protection issues and can support Staff and Volunteers making a report to CARL. They are a point of contact for raising child safety concerns within the College, subsequent to reporting directly to CARL. They are also responsible for championing child safety within the College and assisting in coordinating responses to child safety incidents.

Contact details for our Child Safety Officers are set out below:

NamePosition
Kevin RichardsonPrincipal
Heath KerleyStudent Counsellor
Luise LowndesHead of Senior School
Paul WrightHead of Middle School
Bernie DeanHead of Boarding

The above Child Safety Officers can be contacted on 08 8375 1700 or by emailing childsafe@immanuel.sa.edu.au

Immanuel College has appointed Kevin Richardson as the Immanuel College Senior Child Safety Officer. The Senior Child Safety Officer is contactable by phone on 8375 1700 or by emailing childsafe@immanuel.sa.edu.au.

The Senior Child Safety Officer has additional child safety responsibilities, such as being the College contact person for child safety concerns or queries by parents/carers and other members of the wider College, and coordinating the College’s response to child safety incidents in consultation with the Executive Team and Council.

The Council

The Council is the College’s governing body. It is responsible for approving our Child Safe Program and ensuring that the College has appropriate resources to effectively implement the National Principles, and our Child Safe Program.

The Council’s Child Safe Champion

The Chair of Council has been appointed as a Child Safe Champion. The Child Safe Champion is responsible for ensuring that a child-safe culture is prioritised, modelled and championed at the Council level of the College.

The Principal

The Principal is responsible, and will be accountable for, the operational management of the College, and the Child Safe Program. The Principal is responsible for taking all practical measures to ensure that this Child Safe Policy and the College Child Safe Program is implemented effectively and that a strong and sustainable child safe culture is maintained within the College.

The Immanuel College Executive Team

Each member of the Immanuel College Executive Team is required to ensure that appropriate resources are made available in their area of operations to allow the Child Safe Program to be effectively implemented within the College, and to support the Principal in the practical application of the child safety strategies, policies, procedures and work systems.

Staff Members

All Staff are required to comply with our Child Safe Policy and Child Safe Codes of Conduct, be familiar with our Child Safe Program and understand their legal obligations with respect to the reporting of harm and risk of harm to children and young people and Working with Children Checks.

Each current and new College staff member is required to sign a written statement indicating that they have read and acknowledged the Immanuel College Child Safe Policy and Child Safe Codes of Conduct.

It is each individual’s responsibility to be aware of key indicators of harm and risk of harm, to be observant, to meet their legal obligations to report harm and risk of harm directly to CARL and the Police, and subsequently raise all child safety incidents and concerns with one of the Child Safety Officers.

Volunteers

All Volunteers are responsible for contributing to the safety and protection of students in the  College environment.

All Volunteers are required to comply with our Child Safe Policy, and Child Safe Codes of Conduct, and are required to understand their legal obligations with respect to the reporting of harm and risk of harm to children and young people.

Direct Contact Volunteers are required to maintain a valid Working with Children Check as set out in the Child Safe Human Resources Management section, below.

It is each individual’s responsibility to be aware of key indicators of harm to children and young people, to be observant, to meet their legal obligations to report harm and risk of harm directly to CARL and the Police, and subsequently raise all child safety incidents and concerns with one of the Child Safety Officers.

Contractors

Contractors engaged by the College are responsible for contributing to the safety and protection of students in the College environment.

Contractors engaged by the College are required to comply with our Child Safe Policy, and Child Safe Codes of Conduct and are required to understand their legal obligations with respect to the reporting of harm and risk of harm to children and young people.

Direct Contact Contractors, as set out in the Child Safe Human Resources Management section below, are required to maintain a valid Working with Children Check.

The College may include these requirements in the written agreement between it and the Contractor. Relevant contractors are required to maintain a valid Working with Children Check as set out in the Child Safe Human Resources Management section, below.

Contractors include, for example, maintenance and building personnel, consultants, casual teachers, tutors, sports coaches and cleaners. This also includes music teachers and other extra-curricular teachers and instructors who are engaged by students and their families directly, rather than the College, but have an agreement with the Immanuel College to use the College’s facilities.

External Education Providers

An External Education Provider is any organisation that the College has arranged to deliver a specified course of study that is part of the curriculum, to a student or students enrolled at the Immanuel College. The delivery of such a course may take place on the College premises or elsewhere.

External Education Providers engaged by the Immanuel College are responsible for contributing to the safety and protection of students in all Immanuel College environments. They must have lodged a child-safe environments statement to the Department of Human Services prior to being engaged by the College.

External Education Providers engaged by the College are required to comply with our Child Safe Policy and Child Safe Codes of Conduct.

The College includes these requirements in the written agreement between it and the External Education Provider.

Child Safe Human Resources Management

Immanuel College applies best-practice standards in the recruitment and screening of Staff, Contractors and Volunteers. Our recruitment procedures ensure that all reasonable steps are taken to engage the most suitable and appropriate people to work with children and young people. All Staff and Direct Contact Contractors and Volunteers are required to maintain a valid Working with Children Check.

The Immanuel College ensures that the Immanuel College Executive Team, Staff and Volunteers and Contractors undergo child safety induction, and ongoing education and training as part of our commitment to safeguarding children and young people from harm.

Staff, Volunteers and Contractors are provided with regular supervision and performance monitoring by their manager/a senior member of Staff.

The College ensures that professional development programs for Staff include child safety education and training programs.

Child Safe Risk Management

The College recognises the importance of a risk management approach to minimising the potential for harm to children and young people to occur and we use this information to inform our policies, procedures and activity planning.

The College has developed a comprehensive Risk Management Program to assist in the identification, assessment and management of child safety risks in all Immanuel College environments.

Record Keeping

The College has a Child Safe Record Keeping policy and is committed to best practice record keeping.

In accordance with our policy, and as required by our Procedures for Responding to and Reporting Child Safety Incidents or Concerns, all internal and external reports of child safety incidents and concerns, as well as any other responses by the Immanuel College are recorded using the Responding to an Incident, Disclosure or Suspicion of Harm to a Child or Young Person Template.

When keeping records of child safety incidents or concerns, the College maintains confidentiality and privacy for students and families in accordance with federal privacy legislation.

Program Review

The College is committed to continuous improvement. The Program as a whole is reviewed yearly for overall effectiveness and to ensure compliance with all child protection-related laws, regulations and standards.

When undertaking these reviews, the College actively seeks, actions, and incorporates feedback from students, families, the wider Immanuel College, Staff, Volunteers and Contractors, and will communicate any adjustments or amendments widely throughout the College.

Non-Compliance with Our Child Safe Policy

Immanuel College enforces this Child Safe Policy and our Child Safe Codes of Conduct. In the event of any non-compliance, we will instigate a review that may result in a range of measures including (depending on the severity of the breach):

  • remedial education,
  • counselling,
  • increased supervision,
  • the restriction of duties,
  • suspension, or
  • in the case of serious breaches, termination of employment, contract or engagement.

Policy and Child Protection Program Review  

Immanuel College is committed to the continuous improvement of our Child Protection Program. The Program is regularly reviewed for overall effectiveness, in response to a significant change at the College and to ensure compliance with all child protection-related laws, regulations and standards.

Approval Authority: Immanuel College Council
Responsible Officer: Principal
Approval Date: June 2022
Review Date*: June 2025

* Unless otherwise indicated, this policy will still apply beyond the review date. This policy will also be updated as required as per Policy and Child Protection Program Review above.  

CHILD SAFE ADULT CODE OF CONDUCT

The Child Safe Adult Code of Conduct outlines appropriate standards of behaviour for all adults in the College environment towards students. It serves to protect students, reduce any opportunities for abuse, risk of harm or harm to students to occur, and promote child safety at the College. It provides guidance on how to best support students and how to avoid or better manage difficult situations.

It is the College’s policy that any breach of the Child Safe Adult Code of Conduct is a child safety incident that must be reported internally. Any breach that meets the threshold for external reporting must also be reported to the relevant external authority.

For more information, refer to Procedures for Responding to and Reporting Child Safety Incidents or Concerns.

The College reviews the Child Safe Adult Code of Conduct annually. The Council has endorsed the Child Safe Adult  Code of Conduct.

The Child Safe Adult Code of Conduct is published on our public website.

Our Child Safe Program also includes a Staff and Student Professional Boundaries Policy that provides detailed guidance for all  Staff, Volunteers, Contractors and External Education Providers on how to maintain professional boundaries between students and adults at Immanuel College.

Scope

The Child Safe Adult Code of Conduct applies to:

  • the Principal and the Learning Community Executive Team,
  • College Council members,
  • all staff members, including non-teaching Staff and temporary or casual Staff,
  • all Volunteers,
  • all Contractors,
  • External Education Providers,
  • teaching students on placement at the Learning Community,
  • parents/carers and other adult family members of students, and
  • Visitors.

Together referred to as “the Learning Community” for the purposes of this Code.

The Child Safe Adult Code of Conduct applies in all College environments including both physical and online environments, as well as any environment (including those outside the College’s grounds) where College-related activities are occurring.

Immanuel College’s Child Safe Adult Code of Conduct

Each adult member of the Learning Community is responsible for promoting the safety and well-being of students by adhering to the following standards of behaviour:

DO:

  • Uphold Immanuel College’s Statement of Commitment to Child Safety at all times.
  • Comply with applicable guidelines published by the College, such as the Staff and Student Professional Boundaries Policy.
  • Behave as a positive role model to students.
  • Promote the safety, welfare and wellbeing of students.
  • Be vigilant and proactive with regard to student safety and child protection issues.
  • Provide age-appropriate supervision for students.
  • Treat all members of the College with dignity, respect, sensitivity and fairness.
  • Promote the safety, participation and empowerment of students with a disability.
  • Promote the cultural safety, participation and empowerment of linguistically and culturally diverse students and Aboriginal and Torres Strait Islander students.
  • Use positive and affirming language toward students.
  • Encourage students to ‘have a say’ and then listen to them with respect.
  • Respect cultural, religious and political differences.
  • Help provide an open, safe and supportive environment for all students to interact and socialise.
  • Intervene when students are engaging in bullying or inappropriate behaviour towards others, for example humiliating or vilifying others.
  • Ensure as far as practicable that adults are not left alone with a child.
  • Report any breaches of this Child Safe Adult Code of Conduct (for more information, refer to Report Any Concerns, below).
  • Report concerns about child safety externally to the Department for Child Protection (DPC) and Police as required by law, and internally to one of the College’s Child Safety Officers.
  • Where an allegation of harm to a student is made, ensure as quickly as possible that the student involved is safe.
  • Call the Police on 000 if you have immediate concerns for a student’s safety.
  • Respect the privacy of students and their families and only disclose information to people who have a need to know.

DO NOT:

  • Engage in any form of inappropriate behaviour towards students or expose students to such behaviour.
  • Engage in prejudicial or oppressive behaviour or use inappropriate language with students.
  • Express personal views on cultures, race or sexuality in the presence of students or discriminate against any student based on culture, race, ethnicity or disability.
  • Engage in open discussions of an adult nature in the presence of students.
  • Engage in any form of sexual conduct with a student including making sexually suggestive comments and sharing sexually suggestive material.
  • Engage in inappropriate or unnecessary physical conduct or behaviours including doing things of a personal nature that a student can do for themselves, such as toileting or changing clothes.
  • Engage in any form of physical violence towards a student including inappropriately rough physical play.
  • Use physical means (other than as expressly outlined in the Restraint of Students policy) or corporal punishment to discipline or control a student.
  • Engage in any form of behaviour that has the potential to cause a student serious emotional or psychological harm.
  • Develop ‘special relationships’ with students that could be seen as favouritism (for example, the offering of gifts or special treatment for specific students).
  • Engage in undisclosed private meetings with a student who is not your own child.
  • Engage in inappropriate personal communications with a student through any medium, including online.
  • Engage in meetings with a student who is not your child, outside of school hours and without permission from the student’s parent/carer.
  • Take or publish (including online) photos, movies or recordings of a student without parental/carer consent.
  • Post identifying information about a student online unless it is necessary for the school’s activities or you have consent from the student and/or their parents/carers. Identifying information includes things such as the student’s: full name, age, e-mail address, telephone number, residence, school or details of a club or group they may attend.
  • Ignore or disregard any suspected or disclosed harm to a student.

Agreement to Child Safe Adult Code of Conduct

A copy of the Child Safe Adult Code of Conduct is provided to all Staff, Contactors and Volunteers at induction, or otherwise prior to them commencing work at the Learning Community. It is also communicated via refresher training at regular intervals.

All Staff, as well as Contractors and Volunteers must sign an agreement to adhere to the Child Safe Adult Code of Conduct prior to commencing work at the College.

A copy of the Child Safe Adult Code of Conduct is provided to parents/carers, who must sign an agreement to abide by the Child Safe Adult Code of Conduct on enrolment.

Consequences for Breaching the Child Safe Adult Code of Conduct

Staff, including the Executive Team and Principal, Volunteers and Contractors who breach the Child Safe Adult Code of Conduct  may be subject to disciplinary actions that could include (depending on the severity of the breach):

  • remedial education
  • counselling
  • increased supervision
  • the restriction of duties
  • appointment to an alternative role
  • suspension or
  • in the case of serious breaches, termination of employment, contract or engagement.

Where any other member of the College breaches any obligation, duty or responsibility within our Child Safe Adult  Code of Conduct, Immanuel College will take appropriate action.

Report Any Concerns

Any person, including Staff, Volunteers, Contractors, parents/carers and students, can at any time report a reasonable suspicion about harm to a child or young person directly to the Department for Child Protection (DCP) using the Child Abuse Report Line (CARL) on 13 14 78 or online at https://www.childprotection.sa.gov.au/reporting-child-abuse/report-child-abuse-or-neglect.

Whenever there are concerns that a child or young person is in immediate danger, the Police should be contacted on 000.

All Staff, Contractors and Volunteers who witness, or suspect, any breach of the Child Safe Adult Code of Conduct that rises to the level of a reasonable suspicion about harm or risk of harm to students  must report their concern to CARL. They must also report externally to Police if required.

It is the College’s policy that all breaches of the Child Safe Adult Code of Conduct, including those that do not require external reporting, are a child safety incident. Therefore, all Staff, Contractors and Volunteers who witness, or suspect, any breach of the Code of Conduct must report their concern internally to a Child Safety Officer.

Our Child Safe Program includes information for the College’s Executive Team, Staff, Contractors and Volunteers about how to identify key indicators of harm to children and young people and how to report child safety incidents or concerns internally. It also contains detailed procedures with respect to the reporting of child safety incidents or concerns to relevant authorities. For more information, refer to our Procedures for Responding to and Reporting Child Safety Incidents or Concerns.

Students are provided with information about and encouraged to use multiple pathways to raise child safety incidents or concerns about or at the Learning Community, including breaches of the Child Safe Adult Code of Conduct. These include by contacting CARL and/or by reporting internally to the Learning Community via informal and formal ways, an ‘anonymous’ way, and external child advocacy or child safety organisations. For more information, refer to our Child Safe Complaints Management.

Parents/carers, family members  or other community members who witness or suspect that there has been a breach of this Code of Conduct, or have concerns that a child or young person associated with the College may be subject to harm from a member of Staff, a Volunteer or a Contractor, can contact CARL and/or:

  • the Learning Community’s Senior Child Safety Officer Kevin Richardson, by phoning 8375 1700 or emailing childsafe@immanuel.sa.edu.au, or
  • if the concern relates to the Principal, the Chair of Council.

Communications will be treated confidentially on a ‘need to know basis’.

Whenever there are concerns that a child or young person is in immediate danger, the Police should be contacted on 000.

Approval Authority: Immanuel College Council
Responsible Officer: Principal
Approval Date: June 2022
Review Date*: June 2025

* Unless otherwise indicated, this policy will still apply beyond the review date. This policy will also be updated as required as per Policy and Child Protection Program Review above.  

Privacy Policy

In the course of Immanuel College’s activities, we manage and protect personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the 13 Australian Privacy Principles (APPs). Our policy outlines the circumstances in which we obtain personal information, how we use and disclose that information, and how we manage requests to access and/or change that information. Below is a summary of the key areas of our Privacy Policy:

What is personal information and how do we collect it?

Personal information is information or an opinion about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from the individual in their capacity as a student, contractor, volunteer, stakeholder, job applicant, alumni, visitors or others that come into contact with the school. In the course of providing services we may collect and hold:
– Personal Information
– Sensitive Information
– Health Information

Generally, we will seek consent from the individual in writing before we collect their sensitive information (including health information).

How we collect personal information

The collection of personal information depends on the circumstances in which Immanuel College is collecting it. 

Solicited Information

– We collect personal information via forms (e.g. an Enrolment Form), as well as email, letters, notes, via our website, over the telephone, in face-to-face meetings, through financial transactions and through surveillance activities such as CCTV or email monitoring.
– We may also collect personal information from other people (e.g. a third-party administrator, referees for prospective employees) or independent sources.
– We collect information website data via “cookies’’ and other data collection methods to improve our website and marketing. We do not use this information to personally identify individuals.  

Unsolicited information

We may be provided with personal information without having sought it through our normal means of collection, such as misdirected postal mail and email and employment applications sent to us that are not in response to an advertised vacancy.

Collection and use of sensitive information 

We only collect sensitive information if it is:
– reasonably necessary for our functions, and we have the individual’s consent 
– necessary to lessen or prevent a serious threat to life, health or safety
– another permitted general or health situation.

How do we use personal information?

We only use personal information that is reasonably necessary for our functions or for a related secondary purpose that would be reasonably expected by you, or for an activity or purpose to which you have consented including, but are not limited to:
– providing education, pastoral care, extra-curricular and health services
– satisfying our legal obligations including our duty of care and child protection obligations
– keeping parents informed as to school community matters through correspondence, newsletters and magazines
– marketing, promotional and fundraising activities
– supporting the activities of school associations such as Immanuel College Old Scholars Association and Immanuel College Parents and Friends Association
– supporting the activities of the College foundation
– supporting community based causes and activities, charities and other causes in connection with the school’s functions or activities
– helping us to improve our day-to-day operations including training our staff
– systems development; developing new programs and services; undertaking planning, research and statistical analysis
– school administration including for insurance purposes
– the employment of staff and the engagement of volunteers.

How do we store your information and keep it secure?

We store personal information in a variety of formats and takes all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:
– Restricting access and user privilege of information by staff depending on their role and responsibilities.
– Ensuring staff do not share personal passwords.
– Ensuring hard copy files are stored in lockable filing cabinets in lockable rooms.  
– Ensuring access to Immanuel College’s premises are secured at all times.
– Implementing physical security measures around the school buildings and grounds to prevent break-ins.
– Ensuring our IT and cyber security systems, policies and procedures are implemented and up to date.
– Ensuring staff comply with internal policies and procedures when handling the information. 
– Undertaking due diligence with respect to third party service providers who may have access to personal information to ensure as far as practicable that they are compliant with the APPs or a similar privacy regime. 
– The destruction, deletion or de-identification of personal information we hold that is no longer needed, or required to be retained by any other laws.

Immanuel College will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC). If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.

Disclosure of personal information

Personal information is used for the purposes for which it was given to Immanuel College, or for purposes which are directly related to one or more of our functions or activities. Personal information may be disclosed, if the individual:
– Has given consent; or 
– Would reasonably expect the personal information to be disclosed in that manner.

Immanuel College may disclose personal information without consent or in a manner which an individual would reasonably expect if:
– We are required to do so by law.
– The disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety.
– Another permitted general situation applies.
– Disclosure is reasonably necessary for a law enforcement related activity.
– Another permitted health situation exists.

Disclosure of your personal information to overseas recipients

Personal information about an individual may be disclosed to an overseas organisation in the course of providing our services, for example when storing information with a “cloud service provider” which stores data outside of Australia. We will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless:

– we have the individual’s consent (which may be implied);
– we have satisfied ourselves that the overseas recipient is compliant with the APPs, or a similar privacy regime;
– we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or 
– we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.

The quality of personal information

We take all reasonable steps to ensure the personal information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information. If Immanuel College becomes aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.

Access and correction of personal information

You may submit a request to us to access the personal information we hold, or request that we change the personal information. We will take steps to verify your identity before granting access or correcting the information. 

Personal information of students

The Privacy Act does not differentiate between adults and children and does not specify an age after which individuals can make their own decisions with respect to their personal information.

We take a common sense approach to dealing with a student’s personal information and generally will refer any requests for personal information to a student’s parents/carers. We will treat notices provided to parents/carers as notices provided to students and we will treat consents provided by parents/carers as consents provided by a student.

We are however cognisant of the fact that children do have rights under the Privacy Act, and that in certain circumstances (especially when dealing with older students and especially when dealing with sensitive information), it will be appropriate to seek and obtain consents directly from students. We also acknowledge that there may be occasions where a student may give or withhold consent with respect to the use of their personal information independently from their parents/carers.

There may also be occasions where parents/carers are denied access to information with respect to their children, because to provide such information would have an unreasonable impact on the privacy of others, or result in a breach of the school’s duty of care to the student.

Complaints

You can make a complaint about how Immanuel College manages personal information, including a breach of the APPs, by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response. Immanuel College does not charge a fee for the handling of complaints. If you are not satisfied with our response, you may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.

How to contact us about our Privacy Policy

If practical, you can contact us anonymously or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do. 

Download a copy of the full Privacy Policy here

Whistleblower Policy

Download a copy of the full Whistleblower Policy here

Complaints Handling Policy


Immanuel College recognises that from time to time, there might be instances where individuals or organisations may disagree with the way the College has handled matters, and may wish to lodge a complaint. Such individuals may include parents, students, suppliers, local residents, and other external bodies with whom the College has dealings.

The College acknowledges that complaints present an opportunity to improve and is fully committed to resolving complaints in an efficient, fair and timely manner. The College recognises that its complaints handling procedures must be fair to the complainant as well as the person about whom the complaint is made. Accordingly, the College will:

  • document all formal discussion and processes involving a complaint
  • acknowledge receipt of the complaint within two working days
  • treat all parties with sensitivity, respect and courtesy
  • investigate matters impartially and fairly
  • provide all parties with a response within 14 days, or provide interim information if a response is not yet available
  • provide clear reasons as to why any actions have been taken or are proposed to be taken
  • keep matters confidential
  • monitor the effectiveness of outcomes
  • provide a right of appeal to the Principal and Chair of the College Council if the College’s response to the complaint is not satisfactory.

Making a Complaint

We ask that, where appropriate, you first raise the matter directly with the relevant staff member. If that is not appropriate or the issue was not addressed to your satisfaction, please contact the Director of Community Relations on 08 8375 1700 or at immanuel@immanuel.sa.edu.au

Complaints Relating to Child Protection Incidents

There may, at times, be concerns or complaints relating to the College’s Child Protection Program, for example regarding the College’s management of a child protection incident. When a child protection-related complaint is made, the College will first consider whether the complaint raises any concerns about unreported abuse and/or risk of abuse at the College. If concerns of this nature are raised by the complainant, the College’s Procedures for Responding to and Reporting Child Protection Incidents should be followed.

Child protection complaints that do not raise concerns of unreported abuse, or a risk of abuse at the College will be managed in the same manner as other complaints received by the College. The complaints will be recorded to ensure that any further developments relating to the same incident or issue are monitored.

Note that neither the Minister for Education and Child Development nor the Department for Education and Child Development has any power to directly intervene in any complaints relating to the operations of the College.

If you have any questions or require clarification on anything, please reach out to us through one of the following channels.


Contact Information:

Address: 32 Morphett Road, Novar Gardens, South Australia 5040
Phone: 08 8375 1700
Fax: 08 8294 2658
Email: immanuel@immanuel.sa.edu.au

Office Hours:

Monday – Friday: 8.00am – 4.30pm during school terms
Monday – Friday: 8.00am – 4.00pm during school holidays