Privacy Policy

Purpose

FrontTier collects, stores, uses, discloses, and otherwise manages Personal Information in carrying out its functions and activities. It has a responsibility to ensure that its management of Personal Information complies with the Privacy Act.

The purpose of this Policy is to provide a clear and up to date description of how FrontTier manages Personal Information.

Definitions

For the purposes of this policy, “College of Law trading as FrontTier” means College of Law New Zealand Limited (NZBN 9429036109722) and will be referred to throughout as “FrontTier”.

“Personal Information” has the meaning given to it by the Privacy Act and means information about an identifiable individual.

“Privacy Act” means the (NZ) Privacy Act 2020.

“Related Company” means a subsidiary of the College of Law.

“Sensitive Information” means: information or an opinion about an individual’s: racial or ethnic origin; or political opinions; or membership of a political association; or religious beliefs or affiliations; or philosophical beliefs; or membership of a professional or trade association; or membership of a trade union; or sexual orientation or practices; or criminal record; that is also Personal Information; or health information about an individual; or genetic information about an individual that is not otherwise health information; or biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or biometric templates.

“Staff” means an employee of the College of Law (including casual and adjunct employees) and honorary and visiting appointees, consultants and contractors, agency staff, emeriti, members of College of Law trading as FrontTier committees and any other person appointed or engaged by the College of Law trading as FrontTier to perform duties or functions for the College of Law trading as FrontTier.

Commitment to Privacy

FrontTier is committed to protecting the privacy of individuals by collecting, storing, using and disclosing and otherwise handling Personal Information only in accordance with the Privacy Act and in the manner described in this Policy.

FrontTier will collect Personal Information only when it is for a lawful purpose in connection with a function or activity of FrontTier, and if the collection of the Personal Information is necessary for that purpose. FrontTier will only collect Sensitive Information relating to an individual with that individual's consent.

How Personal Information is collected

FrontTier collects Personal Information only by lawful and fair means. It will collect Personal Information directly from the subject individual unless the individual has consented to the collection of his or her personal information from a third party, where it is unreasonable or impractical to make a direct collection and or where FrontTier is required or authorised by law to collect his or her information from a third party.

FrontTier may collect Personal Information when an individual:

  • registers for, enrols in, attends and or otherwise takes part in a FrontTier course, assessment, event, webinar, survey or contest
  • communicates with FrontTier, including by physical post, email, social media, telephone, text message or fax
  • visits a website that displays or links to this Policy
  • visits and or posts a comment or other communication on a FrontTier branded social media page
  • visits FrontTier and or meets with FrontTier representatives
  • uses FrontTier cloud products, IT systems or services as an authorised user, including when providing government higher education enrolment information
  • applies for a job at FrontTier, and or offers to supply or supplies goods or services to FrontTier.

Third parties from whom FrontTier may collect Personal Information about other individuals include information brokers, referees, educational institutions attended and others, as authorised by the individual who is the subject of the Personal Information.

FrontTier uses information gathering tools, including tools for collecting usage data, cookies and web beacons, to automatically collect information that may contain Personal Information from computers and mobile devices used to navigate FrontTier websites, FrontTier services, or to interact with emails sent by FrontTier. For more information, please see: FrontTier Cookies and Electronic Marketing Policy.

The kinds of Personal Information collected

FrontTier collects names, addresses, tax file numbers, contact details, job titles, educational history, course preferences, course results and details associated with FrontTier related transactions with individual students and suppliers. FrontTier may also collect internet data (including user behaviour data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles. FrontTier may combine information provided by third parties with information provided directly to FrontTier.

If FrontTier receives Personal Information from someone other than the individual subject of the Personal Information, FrontTier will consider whether it is authorised to collect the information. If the information is not relevant to any of the functions or activities of FrontTier, and or the collection of the Personal Information would require consent that has not been obtained, FrontTier will securely destroy or deidentify the Personal Information.

FrontTier gathers certain Personal Information automatically in connection with the use of the website and in connection with the use of cloud based products and services by individual users.

Purposes of the Collection, of Personal Information

FrontTier collects and uses Personal Information to carry out the business of FrontTier, including enrolling students, providing courses and for business administration purposes. Some Personal Information is collected for the purpose of targeted advertising, delivering relevant email content, event promotions and profiling.

To carry out one or more of the purposes recorded directly above, FrontTier collects Personal Information on behalf of relevant government and admitting authorities. These may include the following departments, as named below and also as renamed from time to time:

  • New Zealand Qualifications Authority
  • Ministry of Education
  • New Zealand Council for Legal Education
  • Tertiary Education Commission
  • Inland Revenue Department
  • Public Trust
  • Ministry of Social Development – StudyLink
  • Immigration New Zealand, and
  • New Zealand Law Society.

If FrontTier is required to collect, use and or disclose Personal Information by law or if the collection of Personal Information is necessary for the organisation, management or delivery of a service to an individual, and the required Personal Information is not provided, FrontTier may not be able to contract with the subject individual and or deliver the service.

Disclosure of Personal Information

FrontTier shares Personal Information with staff, its Related Companies, third party service providers and business partners to conduct the business, and deliver the services of FrontTier and its Related Companies and to develop, improve, and expand products and services of FrontTier and its Related Companies.

Personal Information relating to students at FrontTier may be disclosed:

  • when enrolling into a course, on provision of access to a course or for business administration purposes
  • when attempting to contact or locate a student or to notify the relevant authority or the student’s emergency contact if there are reasonable grounds to be concerned about the student’s welfare or safety
  • in order to generate learning or business analytics to assist the College of Law trading as FrontTier to make better decisions regarding operations and services, to improve the student learning experience and outcomes, to offer personalised services and support to students and to promote academic excellence
  • for the purpose of determining eligibility for and administering public transport concessions and for directly related purposes such as audit, management and operational activities for concessions
  • to issue invitations to participate in approved research or surveys, while a student and after graduation
  • to confirm completion of a student’s course (only name, degree(s) conferred, and date(s) of completion will be disclosed), and
  • to publish the name and award of graduates online and or in a College of Law, trading as FrontTier, graduation booklet for the student’s graduation ceremony.

If Personal Information is shared with third party service providers or business partners, use and disclosure of the Personal Information by the third party service providers and business partners is strictly limited to the extent necessary to deliver the service requested by FrontTier, and is subject to FrontTier privacy and security requirements.

FrontTier shares anonymous usage data with FrontTier’s service providers for the purpose of helping FrontTier to analyse the data and to improve its services, products and operations. FrontTier may share anonymous usage data on an aggregate basis in the normal course of operating its business, for example, FrontTier may share information publicly to show trends about the use of its services.

Any Personal Information or other information that an individual may submit in communities, forums, blogs or chat rooms on the websites of FrontTier may be read, collected and used by others who visit these forums, depending on the account settings selected by the individual.

FrontTier may use or disclose Personal Information in circumstances expressly permitted by the Privacy Act, for example, where FrontTier believes on reasonable grounds that:

  • the purpose for which the Personal Information is to be used or disclosed is the purpose, or one of the purposes for which the information was obtained, or is directly related to the purposes in connection with which the Information was obtained
  • the use or disclosure is authorized by the individual concerned
  • the use or disclosure of the Personal Information is necessary to lessen or prevent a serious threat to life, health, or safety of any individual or public health or safety
  • the source of the information is publicly available information and that, in the circumstance of the case it would not be unfair or unreasonable to disclose the information, or
  • the information is to be used in a form in which the individual concerned is not identified.

FrontTier may also disclose Personal Information when:

  • compelled by law including by warrant or subpoena
  • required by lawful order of a government authority
  • required by lawful order of a regulator of the College of Law trading as FrontTier, and or
  • required by an admitting authority.

Retention and security of Personal Information

FrontTier takes precautions to help safeguard against the accidental or unlawful destruction, loss, alteration, misuse, and unauthorised disclosure of, or access to, the Personal Information held, used and disclosed by FrontTier. These precautions include implementing organisational, technical, and physical security measures.

FrontTier will only hold Personal Information for as long as is required for the purposes for which the Personal Information may lawfully be used. Subject to any legal requirements to retain Personal Information, if Personal Information is no longer needed for the purpose(s) for which the information may be lawfully used or disclosed in accordance with this Policy, FrontTier will take reasonable steps to delete or deidentify the Personal Information. If there is any Personal Information that FrontTier is unable, for technical reasons, to delete entirely from FrontTier systems, FrontTier will put in place appropriate measures to prevent any further use and disclosure of such Personal Information, and ensure that the Personal Information is deleted or deidentified as soon as it can be.

International access to Personal Information

Personal Information will be collected, transferred to, and stored by FrontTier in FrontTier’s Student Management System which is stored in Japan. Backup of this data is stored in Ireland. The FrontTier Learning Management System (Canvas) stores data in Australia. All other Personal Information is stored in New Zealand and or Australia and is accessible only from New Zealand and or Australia. FrontTier takes steps to ensure that any offshore recipient of Personal Information collected from an individual in New Zealand deals with the Personal Information in accordance with the Privacy Act.

Where a Related Company of FrontTier collects Personal Information from an individual located outside of New Zealand, the privacy policy of that Related Company will apply to the Personal Information. If Personal Information collected by a Related Company located outside of New Zealand is disclosed to FrontTier, FrontTier will handle the Personal Information in accordance with this Policy, the privacy policy of the Related Company and the law of the country where the Related Company is located.

Access to and correction of Personal Information

FrontTier will respond to all inquiries from an individual requesting confirmation of whether FrontTier holds any Personal Information about that individual and will allow access to, and correction of, any such Personal Information held by FrontTier relating to the individual, subject to any limitations or grounds for refusal set out in the Privacy Act.

Privacy inquiries and complaints

All privacy related enquiries are handled by FrontTier’s Privacy Officer who can be contacted by writing to the address below or emailing FrontTier at: privacy@collaw.ac.nz

Privacy Officer
FrontTier
Level 8, College of Law Centre, 3 City Road
Auckland 1010

Individuals that wish to raise any matter associated with the way that FrontTier manages his or her Personal Information, including any possible breach of privacy, may contact the FrontTier Privacy Officer setting out in writing the details of the issue or concern and stating any associated observations or requests.

FrontTier Privacy Officer will respond to all enquiries relating to access to Personal Information within 20 working days after the day on which the request is received. All such other inquiries will be responded to by the Privacy Officer within 30 days.

FrontTier is committed to working with every complainant to obtain a fair resolution of any complaint or concern about privacy.

If not satisfied by the response from FrontTier, the individual should contact the Office of the Privacy Commissioner.

Changes to this Policy

FrontTier will update this Policy from time to time to reflect changes in practices, technologies, legal requirements, and other factors. Updates will be effective on the “effective date” stated at the top of this Policy. If a material update is made, FrontTier will highlight the change by posting a conspicuous notice on the FrontTier website or by email communication.

FrontTier encourages students, staff, and suppliers to periodically review this Policy to stay informed about collection, processing and sharing of personal information practices.