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Privacy Policy

About this policy

Blu Edge Pty Ltd (ABN 41 163 823 201) trading as Bluedge RTO Consulting (“Bluedge”, “we”, “us” or “our”) respects your privacy and is committed to handling personal information openly and transparently. 

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This policy explains how we collect, hold, use, disclose and protect personal information in connection with our websites at bluedge.com.au and bluedgeconsulting.com.au (together, our “websites”), our enquiry and subscription forms, and our consulting, RTO shared services and outsourcing activities. 

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We handle personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) in Schedule 1 of that Act. Where we handle information of individuals located overseas, other privacy laws may also apply. 

1. What is personal information

“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not — for example a name, address, email address, phone number or job title. 

“Sensitive information” is a special category of personal information that attracts stronger protections. It includes information about a person’s health, racial or ethnic origin, religious beliefs, criminal record and biometric information. We generally do not seek sensitive information, and we collect it only where it is reasonably necessary and, where required, with consent. 

2. The kinds of personal information we collect and hold

Depending on how you interact with us, the personal information we collect and hold may include: 

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Contact and identity information 

  • Your name, job title, the organisation or RTO you represent, and business contact details such as email address, phone number and postal or business address. 

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Website and enquiry information 

  • The content of enquiry forms, requests to download our brochures and lead magnets, newsletter subscriptions, and any correspondence you send us. 

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Information handled during client engagements 

  • Information you provide when we deliver consulting, shared services or outsourcing work. This may include personal information about your staff, trainers, assessors and learners that is contained in the documents, systems and records you share with us (for example training and assessment records, validation samples and audit evidence). 

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Recruitment information 

  • Where you apply for a role with us, information in your application, CV, references and related correspondence. 

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Technical and usage information 

  • Information collected automatically when you use our websites, such as your IP address, device and browser type, pages viewed, referring pages and the dates and times of your visit, and information collected through cookies and analytics (see section 4). 

3.  How we collect personal information 

We collect personal information by lawful and fair means and, where reasonable and practicable, directly from you. We collect it: 

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  • Directly — when you complete a form on our websites, email or call us, meet with us, enter into an engagement, or provide records in the course of our work; 

  • From third parties — for example referral and delivery partners (such as eSkilled / CLR), client organisations that provide us their records, and publicly available sources such as company websites and professional networks; and 

  • Automatically — through cookies and analytics when you use our websites (see section 4). 

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Where we collect your personal information, we take reasonable steps to notify you (or ensure you are aware) of the matters required by APP 5, including who we are, why we are collecting it, and to whom we usually disclose it — typically at the point of collection or through this policy. If we receive personal information we did not solicit, we deal with it in accordance with the APPs. 

4.  Cookies, analytics and website tracking 

Our websites use cookies and similar technologies to help them function, to remember your preferences, and to understand how visitors use the sites so we can improve them. Cookies are small text files stored on your device. We may use essential cookies (needed for a site to work), functional cookies (to remember choices) and analytics cookies (to measure usage). 

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We use third-party analytics tools, including Google Analytics, that set their own cookies and process usage data under their own privacy terms. You can control or delete cookies through your browser settings; blocking some cookies may affect how a site works. 

5.  Why we collect, hold, use and disclose your information

We collect, hold, use and disclose personal information for purposes connected with our business, including to: 

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  • Respond to your enquiries and provide the brochures, information and updates you request; 

  • Provide, manage and improve our consulting, RTO shared services and outsourcing engagements, and administer the related contracts and invoicing; 

  • Communicate with you and manage our relationship with you and your organisation; 

  • Send you marketing about our services where permitted, and manage your marketing preferences (see section 8); 

  • Consider and process job applications; 

  • Operate, secure, analyse and improve our websites; and 

  • Meet our legal, regulatory and record-keeping obligations, and establish, exercise or defend legal claims. 

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We use and disclose personal information for the purpose we collected it (the primary purpose) and for related secondary purposes you would reasonably expect, or as otherwise permitted or required by law (APP 6).

6.  Who we disclose personal information to 

We may disclose personal information to: 

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  • Our personnel and related entities, including Bluedge Outsourcing OPC (our Philippines-based delivery arm), who support our client work under confidentiality and privacy obligations; 

  • Service providers and contractors who help us run our business (for example IT, hosting and cloud providers, email and CRM platforms, analytics providers and professional advisers), who are permitted to use the information only to provide their services to us; 

  • Referral and delivery partners (such as eSkilled / CLR), where relevant to a service you have engaged and under appropriate arrangements; 

  • Regulators, courts and other authorities where required or authorised by law; and 

  • A purchaser or successor in the event of a sale or restructure of our business, subject to appropriate confidentiality. 

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We do not sell personal information. 

7. Disclosure of personal information overseas 

We are likely to disclose personal information to recipients located outside Australia. In particular, some of our work is delivered by Bluedge Outsourcing OPC and personnel located in the Philippines. We may also use IT, hosting and cloud service providers that store data overseas, including in the United States. 

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Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the recipient handles it consistently with the APPs — for example through contractual confidentiality and data-protection obligations. You should be aware that overseas recipients are subject to the laws of their own country, which may differ from Australian privacy law.

8. Direct marketing 

We may send you marketing communications about our services, such as newsletters, updates and event invitations, where you would reasonably expect this or where you have opted in. Every marketing message includes a simple way to opt out, and you can unsubscribe or update your preferences at any time by using the unsubscribe link or by contacting us. We handle electronic marketing in line with the Spam Act 2003 (Cth). If you ask us to stop, we will. 

9.  Keeping your information accurate 

We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, up to date, complete and relevant. If your details change, or you believe our records are inaccurate, please contact us so we can update them (see sections 11). 

10.  Security, retention and data breaches 

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include access controls, secure systems, staff confidentiality obligations and contractual protections with our service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. 

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We retain personal information only for as long as we need it for the purposes described in this policy or as required by law, after which we take reasonable steps to destroy it or de-identify it. 

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We are committed to the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. If we experience an eligible data breach that is likely to result in serious harm, we will notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

11.  Accessing and correcting your information 

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details in section 16. We will verify your identity and respond within a reasonable time (we aim to respond within 30 days). 

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Access is usually free, although we may charge a reasonable cost for retrieving and supplying information in some cases; we do not charge for making a request or for correcting information. In limited circumstances we may decline access or correction as permitted by the Privacy Act — if so, we will explain why in writing and how you can respond, and, where appropriate, note your requested correction on our records. 

12.  Automated decision-making 

Where a computer program is used to make, or to substantially and directly assist in making, a decision that could reasonably be expected to significantly affect your rights or interests, we will explain in this policy how automated decision-making is used and how it affects that decision, in line with our obligations under the Privacy Act. 

13. Making a complaint

If you have a concern or complaint about how we have handled your personal information, please contact us first using the details in section 16. We will acknowledge your complaint, look into it, and respond within a reasonable time (we aim to acknowledge within 5 business days and resolve within 30 days). 

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If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC): phone 1300 363 992; post GPO Box 5218, Sydney NSW 2001; or online at www.oaic.gov.au. 

14.  Changes to this policy 

We may update this policy from time to time to reflect changes in our practices or the law. The current version will always be available on our websites, and the effective date is shown at the top of this document. We encourage you to review it periodically.

How to contact us

For any privacy question, request or complaint, please contact: 

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Privacy contact: Managing Director / Privacy Officer 

Entity: Blu Edge Pty Ltd t/as Bluedge RTO Consulting (ABN 41 163 823 201) 

Email: darren@bluedge.com.au 

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