[Year 12 IT Apps] VCAA vs VCAA and the NPP's

Sun Sep 9 06:55:12 EST 2012

Microchips and tattoos aside, there is a good privacy reason why teachers
and schools cannot use particular numbers and from memory it has to do with
data-linking and matching. I am just thinking this through aloud and I am
not a lawyer so this is not to be taken as any form of  legal advice.
Still, have a glance at my concerns below.

By illustration, whilst the Ultranet uses a VSN number to identify students
and assist with record sharing between schools, it cannot be viewed or
easily extracted. Instead, an different login code is generated for use by
teachers and students. If a student changes schools, their login might
change but at least their details and records will follow.

 http://www.vcaa.vic.edu.au/Documents/vsn/information_for_student.pdf
<http://www.vcaa.vic.edu.au/Documents/vsn/information_for_student.pdf>

> "The information will be used only for educational purposes and the ways
> in which the VSN can be used is prescribed by legislation. The legislation
> also includes criminal offences for use of the data for other than the
> prescribed purposes. Commonwealth and State Privacy Principles have also
> been used to guide the design of the VSN system."

When I mentioned this to my wife who works as a nurse, she remarked about
the security around the patient identify number system that is in use by
hospitals and the strict provisions governing its use.

http://www.privacy.vic.gov.au/privacy/web2.nsf/pages/frequently-asked-questions-general-public

> IPP 7 Unique identifiers: A unique identifier is usually a number
> assigned to an individual in order to identify the person for the purposes
> of an organisation's operations. Tax File Numbers and Driver's Licence
> Numbers are examples. Unique identifiers can facilitate data matching. Data
> matching can diminish privacy. IPP 7 limits the adoption and sharing of
> unique identifiers.

Now it has me thinking that perhaps the current practice for schools to use
a student CASES identity number may be in breach of just this information
privacy principle. The CASES identifier is often regularly published,
freely shared, used by other school databases and provided to TSSP
contractors to set up these systems such as local network accounts or email
addresses. It could be used to provide access to sensitive information
about user access, notes or files. I suspect that this is a usage that
should probably be discouraged as it edges well beyond the scope of the
original reason and database for the identification number. By
illustration, some schools use a locally generated timetable initial, not a
teachers payroll or 'T0 number' to identify teachers and similarly, edumail
uses a locally generated user name (sometimes with a middle initial tweak)
not the T0 identifier to generate an email address.

Perhaps the Paula or the privacy commissioner could provide some advice
about this.
*Roland Gesthuizen* | eLearning Leader
Keysborough College
Acacia Campus | T +61 3 9798 1877
www.keysboroughsc.vic.edu.au
Regards Roland

*Roland Gesthuizen* | eLearning Leader
Keysborough College
Acacia Campus | T +61 3 9798 1877
www.keysboroughsc.vic.edu.au
On 4 September 2012 16:39, Robert Timmer-Arends <timmer at westnet.com.au>wrote:

> **
> Hello Damien
>
> I have had this quoted to me in the context of a query regarding the use
> of students' VSN. The VCAA bulletin ran an article suggesting we could *
> not* use the VSN internally in the school (I was interested in doing this
> because the CASES code can change so there is no way of tracking students
> over time).
>
> I think the 'out' for VCAA and VCAT might be 7.2a (and 7.1A sounds like
> another opportunity for an out - are either or both VCAA and VCAT
> 'prescribed organisations'?)
>
> Also, while they are separate entities they are both govenment agencies
> and I vaguely remember reading something in the NPPs that could allow you
> to interpret that as a single organisation???
>
>
> Regards
> Robert T-A
> Brighton SC
>
>
> ----- Original Message -----
>
> *From:* ATKINSON-BUCK, Damien <Damien.ATKINSON-BUCK at ivanhoe.com.au>
> *To:* Year 12 IT Applications Teachers' Mailing List<itapps at edulists.com.au>
> *Sent:* Tuesday, September 04, 2012 2:49 PM
> *Subject:* [Year 12 IT Apps] VCAA vs VCAA and the NPP's
>
>  Hi folks,
>
>             I was going through the NPP’s with my year 12’s today. When we
> were discussing NPP 7 Identifiers (see below) one of my students asked why
> VCAA and VTAC both use their student numbers as the primary identifier.
> Does anyone out there know if this is indeed the case and if so, how they
> are allowed to do it, they are separate entities aren’t they?
>
> Thanks
>
> Damien
>
>
>
> *7.1 An organisation must not adopt as its own identifier of an
> individual an identifier of the individual that has been assigned by: *
>
> *(a) an agency; or*
>
> *(b) an agent of an agency acting in its capacity as agent; or*
>
> *(c) a contracted service provider for a Commonwealth contract acting in
> its capacity as contracted service provider for that contract*.
>
> *7.1A However, subclause 7.1 does not apply to the adoption by a
> prescribed organisation of a prescribed identifier in prescribed
> circumstances. *
>
> *Note: There are prerequisites that must be satisfied before those
> matters are prescribed: see subsection 100(2).*
>
> *7.2 An organisation must not use or disclose an identifier assigned to
> an individual by an agency, or by an agent or contracted service provider
> mentioned in subclause 7.1, unless: *
>
> *(a) the use or disclosure is necessary for the organisation to fulfil
> its obligations to the agency; or*
>
> *(b) one or more of paragraphs 2.1(e) to 2.1(h) (inclusive) apply to the
> use or disclosure; or*
>
> *(c) the use or disclosure is by a prescribed organisation of a
> prescribed identifier in prescribed circumstances.*
>
> *Note: There are prerequisites that must be satisfied before the matters
> mentioned in paragraph (c) are prescribed: see subsection 100(2). *
>
> *7.3 In this clause:*
>
> *identifier includes a number assigned by an organisation to an
> individual to identify uniquely the individual for the purposes of the
> organisation's operations. However, an individual's name or ABN (as defined
> in the A New Tax System (Australian Business Number) Act 1999) is not an
> identifier. *
>
>
>
>
>
> *Damien Atkinson-Buck*
> KLA Head - MYP Technology & SYP Info Tech
>
> *p:*
>
> +61 3 9490 3848
>
> *f:*
>
> +61 3 9490 3490
>
> *e:*
>
> damien.atkinson-buck at ivanhoe.com.au
>
> *w:*
>
> http://myivanhoe.net
>
> *The Ridgeway Campus*
> PO Box 91 The Ridgeway
> Ivanhoe Victoria
> 3079 Australia
>
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> [image: Description: Description: Description: Description:
> cid:image003.gif at 01CA7CC2.074C48E0] <http://myivanhoe.net/>
>
>
>
>
>
>
>
>
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-- 
--
Roland Gesthuizen - eLearning Coordinator - Keysborough Secondary College

"Never doubt that a small group of thoughtful, committed citizens can
change the world; indeed it is the only thing that ever has." --Margaret
Mead
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