IAC is committed to a culture of corporate compliance and high ethical behaviour. Our ethical values are set out in the IAC Code of Conduct.
This policy complements the Code of Conduct and highlights misconduct, improper behaviour or the existence of an improper situation at IAC. IAC is committed to conforming with its compliance obligations described within the Commonwealth Corporations Act and Regulations 2001.
The guiding principles of this policy aims to protect personal information records for confidentiality and privacy.
The personal information for clients also known as client records we collect and hold (file, archive) is what is reasonably necessary or our business functions and activities. Personal information for clients is defined as:
Some of our products and/or services require us to collect health information from you for the purposes of determining student support services, and public liability considerations involving you.
When we collect personal information about you, we do so by making a record of it. We do this when you:
The personal information we collect and hold about you is from direct dealings with us. We hold your personal information within hard-copy and electronic files. These files may be managed by us, our service providers, or third parties, such as government authorities. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, personal information.
When we collect, manage (hold, use) and disclose your personal information, we do so to provide our services to you.
We disclose personal information we collect for purposes which are incidental to the provision of products and services to you.
We may collect, manage and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law.
We may de-identify your personal information for use and disclosure of the anonymous data to assist us in providing services.
We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy officer at:
Before we provide you with access to your personal information we may require some proof of identity. We may charge a reasonable fee for giving you access to your personal information if your request requires substantial effort on our part. If you need your personal information corrected, please contact our Privacy Officer using one of the above contact methods.
Before we provide you with access to your personal information we may require some proof of identity. We may charge a reasonable fee for giving you access to your personal information if your request requires substantial effort on our part. If you need your personal information corrected, please contact our Privacy Officer using one of the above contact methods.
If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy officer using one of the above contact methods. We may ask you to put your complaint in writing and to provide details about it.
We may discuss your complaint with our personnel, service providers and third parties, as appropriate.
Our Privacy officer will investigate the matter and attempt to resolve it within our complaint timeframes. Our Privacy officer will inform you in writing about the outcome of the investigation. If our Privacy officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy officer will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Privacy Commissioner’s contact details.
We may allow your personal information to be shared with our group companies located within countries other than Australia. Our business locations are in Australia and (country).
IAC shall collect, store and use personal information necessary for the provision of products and services to clients, personnel, visitors and where required by third parties. We take all reasonable steps to prevent unauthorised access to, maintain disclosure of, and secure personal information to reduce the misuse or loss of personal information. In providing these products and services, we seek each person’s consent for the use of their personal information to allow IAC to communicate effectively with the client, deliver contract requirements, and in most cases, where client consent is received, share approved information with third parties. If personal information is shared with third parties it shall be done to:
A breach is notifiable if it meets the following criteria:
A breach may not be notifiable if the harm is not serious or if steps can be implemented to reduce its impact.
If an NDB occurs, you should report it to the OAIC and any affected individuals. The OAIC statement should include:
Notification to impacted individuals should:
Whether a data breach could result in “serious harm” depends on the perspective of a “reasonable person”. It considers several factors, including:
A notifiable data breach (NDB) occurs when personal data maintained by your business is lost or accessed by an unauthorised 3rd party. The NDB Scheme is managed by the Office of the Australian Information Commissioner (OAIC) and applies to businesses with an annual turnover of over $3 million, credit reporting bodies, businesses that trade in personal information, health service providers, and tax file number recipients.
If the NDB Scheme applies to your business, you should comply with the scheme’s reporting obligations. This factsheet explains what a data breach is and when one is serious, your reporting obligations, and limiting an NDB’s impact.
You can limit the impact of a breach by implementing a Data Breach Response Plan. Your plan should set out:
If a breach occurs, you can limit its impact by:
The Policy shall be:
Dr Gloria Carter
ManagingDirector
1 July 2025