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

Kevork Krozian kevork at edulists.com.au
Sun Sep 9 10:16:18 EST 2012


Hi Roland,

 

Very topical as  I have heard of some schools deciding to use the VSN as the
new login codes especially when there are a number of students from outside
schools who attend VET and similar courses and need access to the systems.
These externals are from both government and private schools and will be
given logon codes using their VSNs along with all the regular internal
students ( no more Cases codes to logon  ) starting from next year. 

 

Section 7.2(b) of the NPP refers to the case where one or more exclusions of
2.1(e) to 2.1(h) (inclusive) apply to the use or disclosure

The exclusion 2 (b) refers to  the individual consenting to the use or
disclosure 

 

I wonder if students can be considered to be consenting to the disclosure
when asked for their VSN to create a login account. Perhaps a form to sign
that states by furnishing their VSN there are giving consent for its use
within the limited purpose of identifying them uniquely to access the
school's IT facilities?

 

Very interesting .

 

Kevork Krozian

Edulists Creator Administrator

www.edulists.com.au

tel: 0419 356 034

 

From: itapps-bounces at edulists.com.au [mailto:itapps-bounces at edulists.com.au]
On Behalf Of Roland Gesthuizen
Sent: Sunday, 9 September 2012 6:55 AM
To: Year 12 IT Applications Teachers' Mailing List
Subject: Re: [Year 12 IT Apps] VCAA vs VCAA and the NPP's

 

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-questi
ons-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 <tel:%2B61%203%209798%201877>  
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 <mailto:Damien.ATKINSON-BUCK at ivanhoe.com.au>  

To: Year 12 IT Applications Teachers' Mailing List
<mailto: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



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