1About this policy

Little Scholars School of Early Learning is operated by The Scholars Group Pty Ltd (ABN 64 169 563 482, ACN 169 563 482), trading as Little Scholars School of Early Learning. We operate 17 early learning campuses across the Gold Coast, Brisbane, Ipswich and Redland Bay under ACECQA provider approval PR-40002184.

Each campus operates under its own Australian Business Number. In this policy, “we” means The Scholars Group Pty Ltd and the campus entities within the Little Scholars group. Information may be shared between these entities where necessary for the purposes described below.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. As an approved provider of education and care services, we also handle information under:

• the Education and Care Services National Law and the Education and Care Services National Regulations
• the Family Assistance Law, including obligations relating to the Child Care Subsidy
• the Child Protection Act 1999 (Qld) and the Working with Children (Risk Management and Screening) Act 2000 (Qld)
• the Public Health Act 2005 (Qld), in relation to immunisation
• the National Principles for Child Safe Organisations

Where these laws require us to collect, keep or disclose information, those obligations take precedence over any preference you express.

This policy covers our website, our campuses, our family app, our recruitment and employment activities, and our community programs. It does not cover third-party websites we link to, which have their own policies.

2The kinds of information we collect

Personal information

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Sensitive information

Sensitive information is a subset of personal information that attracts additional protection. It includes health information, immunisation status, disability, cultural or ethnic background, religious beliefs, and criminal record information.

We collect sensitive information only where you have consented, or where the law requires or authorises us to collect it. Because of the nature of early education and care, collecting sensitive information is unavoidable — we cannot safely care for a child without knowing about their allergies, medical conditions or court-ordered arrangements.

3What we collect, and from whom

Children enrolled with us

• Full name, date of birth, gender, and address
• Photographs and video, and observations of learning and development
• Health and medical information: allergies, dietary requirements, medical conditions, medical management and action plans, medication authorisations, GP details, and records of incidents, illness, injury or trauma
• Immunisation history statements
• Cultural background, language spoken at home, and any Aboriginal or Torres Strait Islander identification
• Developmental information, including any diagnosed disability, additional needs, or allied health and specialist support
• Attendance records, and arrival and departure times
• Sleep and rest records, including when your child slept and the physical checks educators completed while they were sleeping
• Assessments, learning documentation and transition-to-school records
• Court orders, parenting orders and parenting plans affecting the child
• Any child protection information we are required to record or report

Parents, guardians and authorised nominees

• Name, residential and postal address, phone numbers and email address
• Relationship to the child, and parental responsibility details
• Customer Reference Number (CRN) and other details required to administer Child Care Subsidy
• Emergency contact details, and details of people authorised to collect a child
• Employment or study details where these relate to subsidy eligibility or session preferences
• Billing and payment information, direct debit authorisations, and account history
• Communications with us, including enquiries, tour bookings, feedback and complaints
• Identity documents where we need to verify identity or authority

Prospective families and website visitors

• Name, email address, phone number, preferred campus, preferred tour date and time, your child’s name, age or date of birth, and intended start timing
• Enquiry content and waitlist details
• Technical information about your visit — see section 13

Educators, staff and job applicants

• Contact details, resumes, qualifications and transcripts, employment history and referee reports
• Working with Children Check (Blue Card) numbers and expiry dates
• Right-to-work and visa status
• Tax file numbers, superannuation details and bank account details
• Training records, performance records and professional development
• Health information relevant to workplace safety, workers’ compensation or reasonable adjustments
• Criminal history information where lawfully required for child-related work

Visitors, contractors, volunteers and students

• Name, organisation, contact details, sign-in and sign-out records, and Blue Card details where applicable

Community program participants

• Details you provide when registering for programs such as Pram Pals or Grandfriends, or for events, competitions or our newsletter

4How we collect information

We collect information:

• Directly from you — through enrolment and waitlist forms, tour bookings, website forms, phone and email, our family app, in-person conversations at campus, surveys, events, and job applications
• From your child — through everyday observation and documentation of their learning, wellbeing and participation
• From third parties, where you have consented or the law allows, including:
  • Services Australia and the Australian Government Department of Education, in relation to Child Care Subsidy and enrolment confirmation
  • the Australian Immunisation Register
  • your child’s medical practitioners, allied health professionals and specialists, where you have authorised this
  • previous education and care services, where you have authorised a transfer of records
  • referees and Blue Card screening bodies, for recruitment
  • courts, or the other parent or guardian, in relation to parenting orders
• Automatically, when you use our website or app — see section 13

If we receive information about you that we did not ask for and are not permitted to keep, we will destroy or de-identify it where lawful to do so.

5Why we collect, hold, use and disclose information

We use personal information only for the purpose we collected it, for a directly related purpose you would reasonably expect, or where you have consented or the law requires or permits it.

Caring for and educating your child

• Delivering our educational program and documenting each child’s learning and development
• Meeting each child’s health, dietary, medical and additional needs
• Keeping children safe, including supervision, medication administration, emergency response, and complying with court orders about who may collect a child
• Meeting our child safeguarding and mandatory reporting obligations

Administering your enrolment

• Managing waitlists, bookings, attendance and session arrangements
• Processing fees, invoicing, direct debits and account management
• Administering Child Care Subsidy and other government funding, including Free Kindy
• Communicating with you about your child, your account, and campus operations

Meeting our legal and regulatory obligations

• Complying with the National Law and National Regulations, and cooperating with the Queensland regulatory authority and ACECQA
• Complying with Family Assistance Law reporting requirements
• Responding to lawful requests from courts, police, child protection authorities and other government agencies
• Managing insurance, workplace health and safety, and legal claims

Running and improving our business

• Responding to enquiries and arranging campus tours
• Recruiting, employing and supporting our educators
• Training, quality improvement, complaint handling and internal reporting
• Marketing our services, where permitted — see section 14
• Producing aggregated, de-identified statistics and reporting

6Who we disclose information to

We do not sell your personal information. We may disclose it to:

• Our campuses and group entities, where necessary for the purposes above
• Government agencies and regulators — Services Australia, the Australian Government Department of Education, the Queensland Department of Education and its Early Childhood Regulatory Authority, ACECQA, the Australian Immunisation Register, the Australian Taxation Office, and child protection and law enforcement agencies
• Emergency services and health professionals — ambulance, hospital and medical staff in a medical emergency
• Our software and service providers, including:
  • OWNA, our childcare management and family app platform, which also processes fee payments and direct debits
  • LineLeader by ChildcareCRM, our enquiry and waitlist management system
  • Mailchimp, our email marketing platform
  • website hosting, IT support, analytics and advertising providers, insurers, auditors and professional advisors
• Visiting practitioners who deliver services at our campuses — see section 10
• Schools, where you consent to us sharing transition-to-school documentation
• A purchaser or prospective purchaser of our business or any part of it, where a transaction is being contemplated or completed, subject to confidentiality obligations
• Any person you authorise, or where disclosure is required or authorised by law

We require our service providers to protect personal information and to use it only for the purposes we engage them for.

7Information sent or accessed overseas

Our website is hosted in Australia, and OWNA — which holds our enrolment, attendance, learning documentation and payment records — stores its data in Australia.

Some of our other providers and contractors are located overseas, or are operated by overseas parent companies. Information may be stored or accessed outside Australia in the following cases:

• LineLeader by ChildcareCRM, our enquiry and waitlist system, which is operated by a United States company through an Australian related entity
• Mailchimp, our email marketing platform, operated from the United States
• Google and Meta, in connection with website analytics and advertising, which may involve the United States and other countries
• Marketing and website contractors located in the Philippines, who work on our website and marketing systems. This includes access to enquiry form submissions and email marketing lists, which contain the contact details you provide when you enquire with us. They do not have access to enrolment, health, attendance or payment records.

Before disclosing personal information overseas, we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles, including through contractual protections and access controls.

8Photographs, video and your child’s image

Photographs and video of children are personal information, and we treat them carefully.

Your consent is split by use

We do not ask for a single blanket permission. At enrolment you make a separate choice for each way we might use images of your child, and you can say yes to some and no to others:

• Learning documentation and your child’s digital portfolio
• Display within your child’s campus, such as room displays and floor books
• The OWNA family app, visible to your family
• Our website
• Our social media channels
• Printed marketing material and advertising
• Media, press and public relations

Declining any of these does not affect your child’s enrolment or their participation in any part of our program. Where you decline a use, your child is excluded from it.

How we handle images

• We do not publish children’s full names alongside their images in public-facing material.
• Educators use only service-issued devices to photograph or film children. Personal devices are not permitted for this purpose.
• Where a court order or safety concern applies, we exclude a child from any external use of images.
• We ask families not to photograph or film other people’s children at our campuses or events, and not to post such images to social media.

Changing or withdrawing your consent

You can change or withdraw your consent at any time by speaking to your Campus Manager. Withdrawal applies from the date we receive it. We will make reasonable efforts to remove images from material we control, but we cannot always recall material already printed, distributed or shared publicly.

9Sleep room monitors and CCTV

Sleep room monitors

Our nursery sleep rooms are fitted with monitors so educators can maintain continuous supervision of sleeping infants. This is a child safety measure and forms part of our safe sleep practice.

Written sleep and rest records

Separately from the monitors, educators do keep a written record of your child’s sleep and rest. This documents when your child slept and the physical checks educators completed while they were sleeping, and it forms part of our safe sleep practice and our obligations under the National Regulations.

These records are held in the OWNA app as part of your child’s record. You can see them in the app, you can request a copy under section 20, and they are retained for the periods set out in section 18.

CCTV

One campus has CCTV covering an outdoor playground area, in place for safety and security purposes. We do not have CCTV in indoor learning rooms or in any sleep room.

Access to CCTV footage is restricted to authorised management personnel. Footage is retained for approximately four months and is then overwritten in the ordinary course. We may retain footage for longer where it relates to an incident, a complaint, an insurance matter, or a request from a regulator or law enforcement.

Requesting CCTV footage of your child

Where an incident has occurred involving your child in an area covered by CCTV, you may request access to relevant footage by contacting your Campus Manager or our Privacy Officer. Because footage usually shows other children, we may need to refuse access, or provide it in a way that protects the privacy of others — for example, by arranging supervised viewing rather than providing a copy. This is consistent with our obligations under the Australian Privacy Principles.

10Visiting practitioners and on-site services

Through our Family Time Program, we host visiting practitioners at our campuses, including doctors, dentists, allied health and specialist providers, and hairdressers.

• Where you book an appointment for your child, we pass on your child’s name only.
• Visiting health practitioners are independent providers. They keep their own clinical records under their own privacy policies. Little Scholars does not receive, hold or store any records, notes, results or findings from those consultations.
• If you want us to hold health information arising from a consultation — for example, an updated medical management plan — you need to provide it to us directly.
• No records are created or kept in relation to on-site haircuts.

11WonderNest

Our WonderNest program uses virtual reality headsets that operate completely offline. The headsets do not connect to the internet, and no data identifiable to an individual child is collected, transmitted or stored by the platform.

12Our family app

We use OWNA to deliver daily updates, learning documentation, digital portfolios, attendance records, account information and fee payments to families. OWNA stores its data in Australia.

• Access is restricted to authorised parents, guardians and nominees, and to educators who need it for their role.
• You are responsible for keeping your login credentials secure and for not sharing them.
• Content in the app, including images of children, is for your personal use. Please do not download, republish or share content showing other children.

13Our website, cookies and online tracking

When you visit our website we collect technical information automatically, including your IP address, device and browser type, operating system, pages viewed, time spent, referring website, and the search terms used to reach us.

We use cookies and similar technologies, including:

• Essential cookies, needed for the site to function
• Analytics, including Google Analytics 4 and Google Search Console, to understand how the site is used
• Advertising and remarketing technologies, including Google Ads and the Meta pixel, which may allow us to show you our advertising on other platforms and to measure its effectiveness
• Tag management, via Google Tag Manager

These tools may set their own cookies and collect information subject to their own privacy policies. You can control cookies through your browser settings, and you can opt out of personalised advertising through your Google and Meta account settings. Disabling cookies may affect how parts of our site work.

Information you submit through our website forms — including tour bookings, enquiries and waitlist registrations — is recorded in our enquiry management and marketing systems.

14Direct marketing and reviews

We may send you information about our services, campus news, events and programs by email, SMS or post, where you have consented or where you would reasonably expect it — for example, if you have enquired with us or your child is enrolled. We use Mailchimp to send email marketing.

SMS messages we send are triggered by specific events, such as an enquiry, a booked tour or an enrolment milestone. We do not run general SMS marketing campaigns.

We may also invite enrolled families to leave a review of their campus. These invitations are sent automatically following certain events in your enrolment.

We do not use sensitive information for direct marketing, and we do not disclose your information to other organisations for their own marketing.

15Automated decision-making

We do not use computer programs to make, or substantially assist in making, decisions that significantly affect your rights or interests. Specifically:

• Waitlist prioritisation and enrolment offers are decided by our Enrolment Manager, not by software.
• Fee calculations, subsidy estimates and any action on overdue accounts, including suspension or termination of a place, are reviewed and decided by our team.
• We do not use automated screening or ranking of job applications.
• We do not use automated risk flagging of attendance patterns, incident trends or safeguarding concerns.

Our software systems assist our team by organising and presenting information, but a person makes the decision.

16How we protect your information

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These include:

• Physical security at our campuses, including locked storage for paper records and controlled access to enrolment files
• Access controls and role-based permissions, so staff can only see information they need for their role
• Password protection and multi-factor authentication on key systems
• Encryption in transit for our website forms and family app
• Confidentiality obligations in employment contracts and in contracts with service providers
• Staff training on privacy, confidentiality and child safeguarding at induction and ongoing
• Regular review of systems, vendors and access

No system is completely secure. If you believe your information has been compromised, contact us immediately using the details in section 21.

17Data breaches

We maintain a data breach response plan. If we suspect a data breach, we will contain it, assess it promptly, and take steps to reduce harm.

Where a breach is likely to result in serious harm to any individual, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth).

18How long we keep information

We keep personal information only as long as we need it, or as long as the law requires — whichever is longer. Under the Education and Care Services National Regulations, this includes:

Other retention obligations also apply — for example, employment and payroll records under the Fair Work Act 2009 (Cth), tax records under Australian Taxation Office requirements, and records relating to child sexual abuse allegations, which in line with the recommendations of the Royal Commission into Institutional Responses to Child Sexual Abuse we retain for at least 45 years.

CCTV footage is retained as described in section 9. Sleep room monitors do not video record, so no footage is retained. Written sleep and rest records form part of your child’s record and are retained under the periods in the table above.

When information is no longer needed and no legal obligation requires us to keep it, we destroy it securely or de-identify it.

19Dealing with us anonymously

Where it is lawful and practicable, you may deal with us anonymously or under a pseudonym — for example, when making a general enquiry or providing anonymous feedback.

This is not practicable for enrolment, subsidy administration, employment, or any matter involving a child’s safety or care, where we must know who we are dealing with.

20Accessing and correcting your information

Access

You may request access to the personal information we hold about you or your child. We will respond within 30 days. In most cases access is free, though we may charge a reasonable fee for retrieving and copying large volumes of material. We may ask you to put your request in writing and to verify your identity.

We may refuse access in limited circumstances permitted by the Privacy Act — for example, where giving access would have an unreasonable impact on another person’s privacy, would pose a serious threat to someone’s life, health or safety, or would prejudice an investigation or a legal proceeding. If we refuse, we will tell you why in writing and explain how to complain.

Where a parenting order or child protection matter is in place, access may be limited to what the order permits.

Correction

If information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, tell us and we will correct it. If we disagree that correction is warranted, we will note your request on the record and explain our reasons in writing.

Families with an active enrolment can update many of their own details directly in the OWNA app.

21Contact us and how to make a complaint

If you have a concern about how we have handled your personal information, please contact our Privacy Officer. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. We will tell you the outcome in writing.

If you are not satisfied with our response, you can escalate to the Office of the Australian Information Commissioner:

• Online: oaic.gov.au/privacy/privacy-complaints
• Phone: 1300 363 992
• Email: [email protected]
• Post: GPO Box 5218, Sydney NSW 2001

Concerns about the operation of an education and care service may also be raised with the Queensland regulatory authority within the Department of Education.

22Changes to this policy

We review this policy regularly and may update it to reflect changes in our practices or in the law. The current version is always available at https://mylittlescholars.com.au/privacy-policy/. Where changes are significant, we will notify enrolled families directly.