Your family.
Your privacy.

Last updated: 6 October 2026

1. Introduction

Smart Steps Early Learning Centre (“Smart Steps”, “we”, “us”, “our”) is committed to protecting the privacy of the children, families, educators and visitors who are part of our community. We understand that you are trusting us with some of the most personal information there is — about your child, your family and your health — and we take that responsibility seriously.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information, and how you can access or correct the information we hold about you. It applies to information collected through our centre, our website, our enrolment and waitlist processes, our parent-communication app (OWNA) and any related services.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and we manage children’s records consistent with the Education and Care Services National Law and National Regulations. Where the Children’s Online Privacy Code applies to our online services, we will comply with it.

By enrolling with us, using our website or providing us with personal information, you consent to the collection, use and disclosure of personal information as described in this policy.

2. What personal information we collect

The personal information we collect depends on your relationship with us. It may include:

About children

• Full name, date of birth, gender, address and languages spoken.
• Enrolment, attendance and booking details.
• Emergency, medical and developmental information — including allergies, dietary requirements, medical conditions, medications, health-management and action plans, immunisation status, and any additional needs or support requirements.
• Cultural, religious and dietary information relevant to care (for example, to cater for halal or other dietary needs).
• Observations, learning records, photographs and developmental documentation created as part of our educational program.
• Court orders or parenting arrangements where relevant to the child’s care and safety.

About parents, guardians, carers and emergency/authorised contacts

• Names, relationship to the child, addresses, phone numbers and email addresses.
• Customer Reference Numbers (CRN) and information required to administer the Child Care Subsidy and NSW Start Strong fee relief.
• Payment and billing information.
• Employment or activity details where relevant to subsidy eligibility.
• Identification and authorisation details for collecting children.

About prospective families (waitlist and tour enquiries)

• Contact details, your child’s name and age, and preferred start dates and days.

About job applicants, educators and volunteers

• Contact details, qualifications, Working With Children Check details, employment history and related records.

Some of this information is sensitive information under the Privacy Act (for example, health, medical, immunisation, cultural or religious information). We only collect sensitive information where it is reasonably necessary for our functions and, where required, with your consent.

3. How we collect personal information

We collect personal information in a range of ways, including:

• Enrolment forms, waitlist and tour-booking forms, and other documents you complete.
• Our website and online forms.
• The OWNA parent-communication and management app (for enrolment, attendance, sign-in/out, daily updates, photos and billing).
• In person, by phone, by email and during tours and orientation.
• CCTV operating at our centre for safety and security.
• Third parties where relevant and lawful — for example, government agencies, medical practitioners (with consent), or another authorised parent or guardian.

Wherever it is reasonable and practicable, we collect personal information directly from you. Where we collect information about your child from you, we rely on you having authority to provide it.

4. Why we collect, use and hold personal information

We collect, use and hold personal information to:

• Provide education and care for your child and administer your enrolment.
• Keep children safe and healthy, including managing allergies, medical conditions, medication, dietary needs and emergencies.
• Deliver and document our educational program (including EYLF and Arkki learning records).
• Communicate with you about your child, our program, events and centre operations.
• Administer waitlists, tours, bookings, billing and payments.
• Administer the Child Care Subsidy and NSW Start Strong fee relief on your behalf.
• Meet our obligations under the Education and Care Services National Law and Regulations, and other laws.
• Recruit and manage educators and staff.
• Maintain the safety and security of our premises (including CCTV).
• Improve our services and respond to your enquiries, feedback and complaints.

If you do not provide the information we request, we may be unable to enrol your child, provide safe care, or administer subsidies.

5. How we use and disclose personal information

We do not sell personal information. We may disclose personal information to:

• Our educators and staff, on a need-to-know basis, to care for your child.
• OWNA and other IT/software providers who host or process information on our behalf under confidentiality obligations.
• Services Australia / Centrelink and the Australian Government Department of Education, to administer the Child Care Subsidy.
• The NSW Department of Education, to administer Start Strong fee relief.
• The Australian Children’s Education & Care Quality Authority (ACECQA), the NSW Regulatory Authority and other government bodies where required or authorised by law.
• Medical practitioners, ambulance and emergency services in a medical emergency or where necessary to prevent a serious threat to health or safety.
• Other parties you authorise (for example, an authorised contact collecting your child).
• Professional advisers, insurers and payment processors where reasonably necessary.
• Law enforcement, courts or government agencies where required or authorised by law, including to meet child-safety and mandatory-reporting obligations.

We may also use and disclose personal information where the law otherwise permits or requires it.

6. Photographs, images and video

As part of our program we take photographs and videos of children — for learning documentation, daily updates through OWNA, displays within the centre, and (with your specific consent) for marketing, our website and social media.

• We will seek your consent at enrolment for the different ways images of your child may be used, and you can specify your preferences.
• You may withdraw or change your consent at any time by contacting us.
• We will not publish a child’s full name alongside their image in public marketing without consent.

7. CCTV

We operate closed-circuit television (CCTV) at our centre to support the safety and security of children, families and staff, and the security of our premises. CCTV footage is treated as personal information, stored securely, accessed only by authorised personnel, retained only as long as necessary, and disclosed only where permitted or required by law (for example, to police).

8. Our website, cookies and analytics

When you visit our website or use our online forms, we may collect limited information such as your device and browser type, IP address and pages visited, including through cookies and analytics tools, to operate and improve the site. You can manage cookies through your browser settings. Our website may contain links to third-party sites, which have their own privacy policies that we do not control.

Because our services relate to children, where the Children’s Online Privacy Code applies we will handle children’s online information in accordance with it.

We use the Google Ads tag to measure how our Google search ads perform: it records ad visits and the fact that an expression-of-interest form was sent, using Google cookies on your device. In the EU/EEA, UK, Switzerland and Quebec, or where your location can't be confirmed, the tag runs in consent-denied mode: no advertising cookies are set, nothing is personalised and no form conversions are sent, though Google may receive limited cookieless signals. No form answers or contact details are sent to Google. We also use Google Analytics to count visits, pages viewed and general device and region information, plus named actions such as clicking the enquiry button; it follows the same consent settings and never receives names, contact details or form answers. Learn how Google uses this data at business.safety.google/privacy; you can opt out of personalised ads at adssettings.google.com. Like the Meta pixel, it does not load for visitors in the EU, UK, Switzerland or Canada.

We use the Meta (Facebook and Instagram) pixel to measure how our ads perform: it records page visits and the fact that an expression-of-interest form was sent, linked to Meta cookies on your device. We never send your name, contact details, your child’s details or any form answers to Meta. Visitors in regions that require prior consent (such as the EU and UK) are not measured. You can opt out of ad measurement by blocking third-party cookies in your browser or through your Facebook ad settings.

9. Data quality and security

We take reasonable steps to ensure the personal information we hold is accurate, up to date and complete, and to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure. These steps include secure physical storage, access controls, staff confidentiality obligations and secure electronic systems. No method of storage or transmission is completely secure, but we work to protect your information and to respond promptly to any risk.

10. Storage, retention and destruction

We store personal information in secure physical and electronic form, including within the OWNA platform and other trusted systems. We retain personal information only for as long as necessary for the purposes described in this policy or as required by law.

Children’s and other records are retained in line with the Education and Care Services National Regulations (which set minimum retention periods — for example, longer periods for records relating to a child’s illness, injury or trauma). When information is no longer required and we are not legally obliged to keep it, we take reasonable steps to destroy or de-identify it.

11. Overseas disclosure

Some of our service providers (including cloud-based software) may store or process information on servers located outside Australia. Where personal information is disclosed to an overseas recipient, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles. [Confirm the storage locations used by OWNA and any other providers, and list relevant countries here.]

12. Direct marketing

We may send you information about our centre, programs and events — for example, waitlist updates, newsletters and community news. You can opt out of marketing communications at any time by using the unsubscribe function or contacting us at admin@smartstepsearlylearning.com.au. We will not use sensitive information for direct marketing without your consent.

13. Access and correction

You have the right to request access to the personal information we hold about you and your child, and to ask us to correct it if it is inaccurate, out of date or incomplete. To make a request, contact us using the details below. We will respond within a reasonable time and in accordance with the Privacy Act. In limited circumstances we may decline access as permitted by law, in which case we will explain why. There is generally no charge to request access, though a reasonable cost may apply for retrieving or copying extensive records.

14. Data breaches

We have processes to identify, contain and assess data breaches. Where a data breach is likely to result in serious harm to an affected individual, we will comply with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

15. Children’s privacy

The privacy of children is central to how we operate. We collect children’s information primarily from parents and guardians, use it only for the purposes described in this policy, and take particular care with its security and disclosure. We support parents and guardians in exercising privacy rights on behalf of their children.

16. Complaints and how to contact us

If you have a question or concern about your privacy, or wish to make a complaint about how we have handled your personal information, please contact our Privacy Officer:

Privacy Officer, Smart Steps Early Learning Centre
Email: admin@smartstepsearlylearning.com.au
Phone: (02) 9071 7209
Post: 22–24 Thompson Avenue, Moorebank NSW 2170

We will acknowledge your complaint promptly and aim to resolve it fairly and quickly. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au · Phone: 1300 363 992

17. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or the law. The current version will always be available on our website, with the “last updated” date shown above. We encourage you to review it periodically.