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Registered Training Organisation – Learner Privacy Directive


This document establishes the Learner Privacy Directive aligned with Babcock Pty Ltd Privacy Policy.


This Privacy Directive is applicable to all Babcock’s training staff and learners (current and previous).


We understand the importance of, and are committed to, protecting your personal information. This Privacy Directive details how we manage your learner personal information (that is, information or an opinion about an identified individual, or an individual who is reasonably identifiable), including our obligations and your rights in respect of our dealings with your personal information.
Policies are written in clear, concise, simple language.

Policy statements address what is the rule rather than how to implement the rule.


4.1 Compliance

Babcock complies with the obligations under the Privacy Act 1988 (Privacy Act). Babcock is bound by the Australian Privacy Principles which regulate how agencies may collect, store, use and disclose personal information, and how individuals may access and correct information held about them.

‘Personal information’ is defined in the Privacy Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • Whether the information or opinion is true or not; or
  • Whether the information or opinion is recorded in a material form or not.

The Privacy Act only applies to the collection of personal information by Babcock for inclusion in a document, in an electronic or other device, or in a generally available publication.

4.2 The Australian Privacy Principles

Babcock acknowledges that the privacy principles are designed to protect the rights of the individual, yet still allow access by particular authorities in specific circumstances and for specific purposes. To meet its obligation to comply with these principles under privacy laws, Babcock will ensure that these principles are adhered to by our management and all our employees and agents.

Babcock will ensure that it complies with privacy principles pertaining to:

  • The necessity of personal information to be collected, and the means of collection of this information;
  • The use or disclosure of personal information about an individual;
  • Ensuring that information held is accurate, complete and up to date;
  • The protection of information from misuse, loss and unauthorised access, modification or disclosure;
  • The way in which personal information is managed, including the right of individuals to know what type of personal information relating to them is collected, held, used or disclosed;
  • Allowing individuals reasonable access to information held about them to the extent allowed by law;
  • The identification of individuals;
  • The right of individuals to anonymity when entering into transactions where lawful and practicable;
  • The transfer of personal information to persons in a foreign country except where allowed by law; and
  • The collection of sensitive information without consent or legal authority.

4.3  Learner Information Collected by Babcock
The types of personal information that Babcock may collect about you as a learner are set out below:

  • Information stated on the student enrolment form, including contact details, proof of identity, VET Student Loan (VSL) eligibility criteria and your Unique Student Identifier (USI).
  • If you provide Babcock with feedback about our service, we collect the personal information you provide.
  • If you use social media to interact with Babcock, we may collect your username and any information that you allow the social media site to share.
  • Registration details needed to attend workshops and external training.
  • VSL Student information will be provided in certain circumstances to the Commonwealth and designated authorities and, if relevant, the tuition assurance scheme operators.

4.4 Your Consent
Babcock will assume that, unless you advise otherwise, you consent to the collection of the information that you provide (either directly or indirectly) for the use and disclosure by Babcock in accordance with this Privacy Statement.

Babcock will only collect sensitive information (which is a category of personal information that includes information about things like health, religion etc) from you with your consent and where it is reasonably necessary for us to provide you with services or activities.

Babcock may take a photo of you to place you on the site access database and learner management system for internal use, such as providing you with a learner pass (if required) and compiling a student class list.

You will be given the opportunity to consent or refuse permission for Babcock to use your photo on our website if required.

4.5 Anonymity
The Australian privacy principles require Australian government agencies to allow individuals the option of not identifying themselves, or using a pseudonym when dealing with the agency when it is lawful and practicable to do so.

Babcock generally provides individuals with the option of not identifying themselves or using a pseudonym. However, the following circumstances do not enable this practise:

  • Course enrolment forms;
  • USI verification; and
  • VET Student Loans entitlements

4.6 Disclosure to other parties
The parties to which Babcock may disclose personal information collected include the following:

  • Commonwealth of Australia;
  • Tuition assurance scheme operators;
  • VET provider requirements under ASQA to collect and report ‘Total VET Activity’ data. This includes full Australian Vocational Education and Training Management Information Statistical Standard (AVETMISS) data, in accordance with the National VET Data Policy.
  • VSL data collection, including courses and student information reported through the Higher Education Provider Client Assistance Tool (HEPCAT).
  • Applicants under the Freedom of Information Act 1982.

4.7 Visiting Babcock’s Website
When you browse Babcock’s website, the service provider logs the following information for statistical purposes: your server address, top level domain name (e.g. .com, .gov, .au, .uk), the date and time of your visit, the pages accessed, documents downloaded, the previous site visited and the type of browser used.

We use the following cookies on our website:

  • Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features.
  • Performance cookies: These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.  This information cannot be used to identify who you are.  Google stores the information collected by these cookies on servers in the United States. Google may transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google’s behalf.
  • Functionality cookies: These cookies allow our website to remember choices you have made when using the website or they may be used to provide services such as watching video on line.

Certain cookies on the website are session cookies and others are persistent cookies.  If you wish to adjust which cookies may be placed on your computer by this website, please look at the help or settings menu on your browser, which should allow you to set your own preference as to how you wish to manage cookies.

By using our website, you agree that we can place the abovementioned types of cookies on your device.

4.8 Other Websites
Our website may contain links to other web sites which are outside our control and not covered by this Privacy Statement.  If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

4.9 Access and correction
The Privacy Act allows individuals to seek access to and request correction of records containing their personal information. The Freedom of Information Act 1982 also sets out the process by which you can access, change or annotate records held by Babcock, which contain your personal information.

You can request access to your personal information or correct and update your personal information by contacting the following Babcock staff below:

Babcock Training Co-ordinatorBabcock National Training Manager
[email protected]
+61 8 8440 1498 or
+61 8 8440 1400
[email protected]
+61 8 8440 1457 or
+61 8 8440 1400

4.10 Complaints
Complaints about breaches of the Australian Privacy Principles by Babcock may be made to the National Training Manager, contactable on +61 8 8440 1457 or email [email protected]

4.11  Notifiable data breaches
Babcock is regulated under the Privacy Act and is required to notify affected individuals and the Office of the Australian Information Commissioner (OAIC) when a data breach is likely to result in serious harm to staff whose personal information is involved in the breach.


Party / PartiesRoles and responsibilities
Babcock Pty Ltd CEOListed as “Fit and Proper Person” and accountable to ASQA for RTO performance and verification of ASQA Financial Viability Risk Assessment
General Manager Land and Corporate Services Exco Representative for governance and approval of Babcock RTO policies and procedures
National Training Manager AustralasiaResponsible for all activities related to compliance, training delivery and management of the RTO as delegated by the GM and CEO


The Privacy Directive will be reviewed every 24 months, or as required due to legislation or circumstantial change.


ASQAAustralian Skills Quality Authority
AVETMISSAustralian Vocational Education and Training Management Information Statistical Standard
RTORegistered Training Organisation
USIUnique Student Identifier
VETVocational Education and Training
VSLVET Student Loans

Registered Training Organisation (RTO) Policy


This document establishes the Registered Training Organisation (RTO) Policy within Babcock Pty Ltd (Babcock).


This policy is applicable to all Babcock Australasia’s training staff, employees and learners (current and previous).


Babcock is committed to providing quality training services that are compliant with the Vocational Education and Training (VET) Quality Framework (VQF), the Australian Skills Quality Authority (ASQA) and all other legislative requirements and standards in order to award nationally recognised qualifications for learners undertaking Nationally Recognised Training (NRT) with Babcock.

Our training services will be delivered according to the standards prescribed in the Standards for RTOs 2015 (supplement 2019). We will ensure that all learners are adequately supported in a training environment that is free from discrimination and harassment, providing fair and equal opportunity for each learner.

The senior leadership responsible for the RTO (Babcock Pty Ltd Chief Executive Officer (CEO) and Chief Financial officer (CFO) and Babcock International Group CEO) will comply with ASQA’s “Fit and Proper Persons” requirements and follow the RTO’s process for ongoing verification of their status.


4.1 Regulatory Compliance
4.1.1 Governance
Babcock uses a streamlined approach to the management of the RTO with a strong focus on business outcomes and customer satisfaction. Training staff and employees will comply with all associated training procedures, practices and instructions outlined in the RTO Process Manual and with any lawful and reasonable instructions issued from time to time in support of the policy.

4.1.2 ASQA Audits
A risk assessment strategy and implementation plan relating to all aspects of RTO operations, including reporting (see 4.1.3 for detail) and financial risk, will audited at least annually by an independent ASQA auditor. The audit is applicable to all RTOs as per the ASQA annual audit and reporting process.

4.1.3 ASQA Reporting
Babcock will comply with annual ASQA training activity reporting pertaining to:

  • Total Australian VET Management Information Statistical Standard (AVETMISS) activity (including  zero returns);
  • Declaration on Compliance against the Standards for RTOs 2015; and
  • Quality Indicator Data reporting, including statement of Financial Viability.

4.2 Payment of Fees
Babcock will ensure timely payment of the annual ASQA RTO registration charge and annual audit fees to retain operational training status.

4.3 Trainer Competencies and Qualifications
Babcock’s Quality Policy governs the competencies and skills expected of all Babcock employees, as well as  the management and conduct of the delivery of products and services to meet customer expectations and regulatory requirements.

Babcock will ensure that all VET accredited trainers are competent and qualified to train and assess the Units of Competency and/or courses on the Babcock RTO scope. Babcock will comply with the annual or periodic updates to qualifications as mandated by ASQA to ensure our trainers are compliant with the regulatory training requirements.

4.4 Learner Information
Babcock is committed to ensuring all learners and prospective learners are fully informed of all training requirements when undertaking a course or training activity with us.

In remaining compliant with ASQA and VET requirements, Babcock will make the following artefacts available to all learners via the Babcock Training portal on the company website:

  • Learner Privacy Directive;
  • Learner Unique Student Identifier (USI);
  • Learner Handbook; and
  • Learner Complaints, Grievances and Appeals Process.

4.5 Award of Nationally Recognised Training and Recognition of Prior Learning
Babcock will provide NRT awards to all learners who successfully meet the competency requirements of their respective training as per the Australian Qualification Framework (AQF) guidelines and as mandated by ASQA. We commit to ensuring all qualifications awarded are achieved by the learner themselves and evidenced appropriately and accurately.

Recognition of Prior Learning (RPL) will be assessed and awarded according to the guidelines mandated by ASQA and credible evidence provided by the learner requiring the RPL.


Party / PartiesRoles and responsibilities
Babcock Pty Ltd CEOListed as “Fit and Proper Person” and accountable to ASQA for RTO performance and verification of ASQA Financial Viability Risk Assessment
National Training Manager AustralasiaResponsible for all activities related to compliance, training delivery and management of the RTO as delegated by the CEO


This policy will be monitored in accordance with Babcock’s Quality, Privacy and Grievance policies. Review of this policy will be annually, or as required by ASQA and NVER.


AQFAustralian Qualification Framework
ASQAAustralian Skills Quality Authority
AVETMISSAustralian Vocational Education and Training Management Information Statistical Standard
CEOChief Executive Officer
CFOChief Financial Officer
NRTNationally Recognised Training
NVERNational Vocational and Education Regulator
RPLRecognition of Prior Learning
RTORegistered Training Organisation
USIUnique Student Identifier
VETVocational Education and Training
VQFVocational Education and Training Qualification Framework