Functional Solutions
International p/l

Privacy Policy

Scope

Functional Solutions International Pty Ltd (FSI) are committed to the protection of personal information and maintaining the privacy of individuals utilising any of our product lines, service websites, customer service centres or public websites.

This privacy policy details how FSI collect, maintain, utilise and disburse information on persons interacting with FSI customer service staff, websites or products including:
SmartSuite-Library
SmartClassrooms
SmartLessons
SmarteCloud
TV4Education
MyLessons
MyTV4Education

By providing FSI with personal information, you consent to us handling the data (whether your data or third party data) in accordance with FSI’s privacy policies and the IPP’s detailed in the Australian Privacy Act 1988.

FSI reserves the right to update these policies from time to time.

Information FSI collects

FSI hosts information which may identify individuals in order to use FSI products, service websites, to communicate with FSI customer service centres and to communicate with FSI new business staff.

Identifiable information that FSI may collect includes any data which is entered or uploaded by administrators into any FSI product. This information may include but is not limited to; legal names, date of birth, email addresses, parent information and images.

Why FSI collects personal information

FSI hosts information in order to allow access for individuals to utilise any of FSI’s product
lines.

Functions available to users include, but are not limited to;
- Authenticating to products
- Transacting business functions for libraries
- Managing access security for resources (e.g. videos and books)
- Delivering support and customer satisfaction services
- Providing system notifications (e.g. TV4Ed requests completed, bulk data changes,
overdue book notices)
- Providing FSI notifications (e.g. Updates, outages, security information)

How FSI collects and holds personal information

FSI collects and stores personal information only via product user interfaces. The ability to
input, modify or remove personal information is limited to administrative user roles granted to
individuals during the on-boarding process or by other administrators throughout the course
of the subscription.

All FSI product lines secure and encrypt data at rest utilising state of the art encryption
technology and upstream security protocols.

During general customer service duties, FSI customer service technicians may be required
to interrogate or view data from your database. This will be communicated and logged, in
customer service tickets for audit purposes.

FSI may collect information from third parties only under expressed written agreements by
the FSI customer.

We hold information on you in secured data centres owned and operated by FSI in electronic
formats.

Disclosure of your personal information

Under no circumstances will FSI disclose your information to third-parties without written
consent.

Under general business, FSI products and services does not require the use of third-parties
and thus does not require personal information to be stored or disclosed to third parties
including situations of:
- System plugins
- Hosting services
- Training events
- Online training platforms
- Notification and alerts systems

Exceptions to disclosure of information include:
- Data evacuation: Where a customer nominates to evacuate all organisational data
including personal information and assets. FSI will invoice a nominal Data Evacuation
fee which will provide an industry standard database of all data stored in an FSI
product to the customer. 48hrs from confirmation of receipt of the database, FSI will
purge all organisational data from FSI’s data centres including backups.
- Discontinuation of service: Where a customer nominates to discontinue a
subscription with FSI, 48hrs from notification of the discontinuation of service or 2
weeks from the last lapsed subscription date, FSI will purge all organisational data
from FSI’s data centres including backups. - No pro rata refunds are eligible for
contracts discontinuing within the 12 month cycle.
- IPP’s as outlined by requirements under the IPP’s the Australian Privacy Act 1988

How FSI protects personal information

FSI protects data stored in all product lines from misuse, interference, loss, unauthorised
access, unauthorised modification, unauthorised disclosure by utilising physical and
electronic measures.

These measures include:
- All FSI staff members and contractors passing police checks and holding valid
working with children cards.
- Utilising no third-party hosting services
- Owning physical buildings for our data centres
- Secured data centre premises
- Locked infrastructure cabinets
- Secured individual organisation database (avoiding cross-contamination with multiple
sites on one database)
- Password and user role access
- Anti-virus software
- Firewalls
- Audit logs
... and more

Information supplied is transacted via the internet. Whilst every reasonable measure is made
by FSI to secure data in transit, you provide personal information at your own risk.

How FSI will update this privacy policy

FSI will provide written notice to customers of any changes made to this policy with
instructions on accessing the updated policies.

Where is your data stored

FSI doesn’t subscribe to any third-party hosting service or apps to produce any and all of its
product lines.

All proprietary data centres are located in Victoria, Australia.

FSI data protection procedures

All FSI staff undergo periodic training in data management and requirements throughout
each year.

All existing product lines undergo regular penetration testing.

System artificial intelligence and monitoring has been developed and updated to avoid any
attempt to harvest, breach or hack FSI product lines. These AI’s and monitoring systems are
both proactive and reactive, alerting FSI infrastructure teams to pending or active threats to
organisational data (including personal information).

All pending updates undergo rigorous penetration, performance and security testing prior to
BETA release. During BETA release, FSI will monitor system AI’s and alerts for any potential
threats to security or data breaches. On full deployment, FSI’s infrastructure teams will
engage full system AI and monitoring systems to ensure all data is secure.

All FSI staff undergo periodic state and federal checks to ensure no new or pending criminal
offences have been recorded against individuals under the employ of FSI. Any breach of
employee contracts pertaining to criminal offences result in immediate termination and
auditing of information accessed by the employee.

How to contact FSI regarding privacy concerns

Should you have any concerns regarding your data or our handling procedures, please
contact our customer service team on:

Telephone: 03 9079 1000 ext. 1
Or
Email: support@functionalsolutions.com.au

How privacy concerns are managed

All privacy concerns are referred to members of the FSI executive team:
- Chief Executive Officer
- VP-Operations
- General Manager

If you are not satisfied with the outcome of your concern, please request an alternate FSI
executive via email: support@functionalsolutions.com.au

Date of publication

Current as of 16th January 2020

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