AERO is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty and integrity in our business activities.

Privacy policy

The Australian Education Research Organisation (AERO) is committed to handling your personal information appropriately. This Privacy Policy explains how we handle your personal information by complying with the obligations set out in the Privacy Act 1988 and its Australian Privacy Principles (APPs).

Definition of personal information

Personal information means any ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable’. Personal information could include an individual’s name, signature, address, phone number, date of birth, disability status, photographs, student identification number, school name and location, opinions and survey responses – as long as the individual is reasonably identifiable from the information.

Information does not have to contain an individual’s name to be personal information. Certain combinations of information may mean that a person is ‘reasonably identifiable’.

Who we are and what we do

We are the Australian Education Research Organisation (AERO). We were set up by the Australian Government and state and territory governments as an Australian ministerial-owned company, governed by an independent Board. One of our purposes is to generate and present high-quality evidence, which may involve conducting surveys and research in Australian schools. We will use this information to improve education outcomes for children and young people.

Why do we need to collect your personal information?

We collect personal information necessary to fulfil our functions or activities. There are different reasons why we may collect your information. For example, we might collect your information if you:

  • participate in a research project, consultation or focus group run by AERO (or your school-age child does)
  • collaborate on a research project with AERO  
  • make an enquiry or contact AERO
  • attend an event run by AERO
  • apply for a job at AERO
  • provide services to AERO or
  • connect with us via social media.

How we collect your personal information

We collect personal information in a non-intrusive, lawful and fair way. We may collect personal information:

  • in person
  • in writing (for example, if you correspond with us or fill out a survey)
  • by audio-visual means (for example, if we record sound or video of an interview or focus group)
  • through our website and social networking services (for example, if you connect with us via LinkedIn or fill out an online survey via our website)
  • from a trusted third party (such as the Australian Curriculum, Assessment and Reporting Authority (ACARA) or the Australian Bureau of Statistics (ABS) or a publicly available source.

Where possible, we will collect personal information from you directly. We will only collect information about you from someone else if it is unreasonable or not feasible to collect it directly.

How we collect student information

When conducting research, we collect information directly from students (such as via interviews or group activities) and also from trusted third parties (such as ACARA and ABS). If the student is under 15, we will provide information to parents and carers about the research before we collect any information. If we need consent, we will seek consent from parents and carers.

The kinds of personal information we collect

The kinds of personal information we collect will depend on the reason for our engagement with you.


Occasionally we conduct research by surveying, interviewing, holding focus groups or conducting classroom observations with educators, students and others in the education sector. The types of information we collect depends on the research project and what we are trying to find out. The information we might collect about students includes:

  • responses to survey questions or answers to interview/focus group questions
  • demographic information (such as age and gender)
  • their school or early childhood education and care (ECEC) service and other details about the school or service
  • educational outcomes such as NAPLAN or exam scores.

The information we might collect about educators (such as early childhood professionals, teachers, principals and other staff) includes:

  • responses to survey questions or answers to interview/focus group questions
  • demographic information
  • their service, school and other details about the service or school
  • information about their role, including experience, salary and job satisfaction

At times we collect ‘sensitive information’ about students or educators. This can include:

  • health information (such as disability status or information about wellbeing)
  • Aboriginal and/or Torres Strait Islander status
  • language background
  • photos or video recordings.

Sensitive information has some extra protections under the Privacy Act. We will always ask first, before we collect this information.

Where possible, we will not collect the names and addresses of research participants, unless it is necessary to meet the research objective. Regardless of whether we collect names or not, we protect the information and treat it appropriately.

All research undertaken at AERO is approved by either the Board or an appropriate Human Research Ethics Committee (HREC).  All research is undertaken in accordance with the terms and conditions specified by the relevant HREC Committee, and the principles specified in the AERO Principles for the ethical and responsible conduct of research and the Australian Research Council’s Australian Code for the Responsible Conduct of Research 2007 (the Australian Code). Participants enrolled in trials or research will be given further information about how their personal information will be handled by AERO.

Engagement and contact

AERO maintains a database of people we have engaged with or people who have taken part in our research. Our database contains contact details and information about which research you participated in.


AERO collects and holds personal information as part of our procurement processes. This includes the names and contact details of tenderers or contracting parties. We also collect financial information required for procurement purposes.

Job vacancy or recruitment

AERO collects personal information such as name, contact details, qualifications and resumes, as part of job applications and internships. We aim to delete the information if the application is not successful unless the applicant remains on a possible future employment list.


AERO collects your name and email address when you choose to sign up to receive our newsletter.

Visiting our website

Log information (browsing)

When you visit our website, the AERO server makes a record of your visit and logs information such as your client IP address, the time and date of your visit to the AERO website, the pages and documents you have accessed or viewed, previous sites visited, browser type and language, and one or more cookies that may uniquely identify your browser.


The AERO website uses Google Tag Manager and Google Analytics, web analytics services provided by Google Inc. Google uses cookies, which are text files placed on your computer, to help us analyse how people use the AERO website. The cookie identifies your browser, not you personally. The information generated by the cookie about your use of the AERO website (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States.

Google Inc. uses this information for the purpose of evaluating your use of the AERO website, compiling reports on website activity for AERO and providing other services relating to website activity and internet usage. Google Inc. may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google Inc's behalf. Google Inc. will not associate your IP address with any other data held by Google Inc.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however if you do this you may not be able to use the full functionality of the AERO website.

Social media

AERO uses social networking sites, including LinkedIn, Facebook and Twitter/X to engage with the public.

AERO may collect your personal information if you engage with us on these services. We will only use the information to help us achieve our organisation’s objectives.

Please note that these social networking sites will also handle your personal information for their own purposes in accordance with their own privacy policies.

Anonymity and use of pseudonym

Where possible, AERO will provide you the option of not identifying yourself, or to use a pseudonym.

How we use and disclose your personal information

We use and disclose your personal information only for the reason we collected it. AERO will not use or disclose it for another purpose (a secondary purpose) unless you consent or an Australian law requires or allows us to. When using data for research, we may aggregate it, analyse it, combine it with other datasets, or de-identify it. We carry out these activities to support the primary purpose we collected it for – to meet our research objectives and gain insights about Australian education. Further information about types of disclosures is given below.


AERO discloses data to researchers in some cases. To access AERO data, researchers must apply to AERO. Data sharing with researchers must follow AERO's third party research policy and be for legitimate research projects in the public interest. Researchers must sign a data sharing agreement and agree to protect data.

Trusted third parties and service providers

AERO may disclose personal information to trusted third parties to assist us with activities including data collection, processing and analysis, information technology services and support, website maintenance/development, printing, record archiving, sending newsletters, market research and research and consultation services.

The information may also be shared with contractors and service providers engaged to help us conduct and share our research. When we engage such parties, we ensure that they are bound by privacy and security obligations.


We publish research and survey findings on the AERO website to benefit the education community. We may also publish articles, reports, papers, presentations, visualisations and other resources. Generally, research will be presented in such a way that individuals cannot be identified. On some occasions we may identify people and specific schools (for example, in case studies) but we will ask permission first.

Overseas disclosure

We do not routinely disclose personal information to overseas recipients. However, from time to time our researchers may be working overseas and require access to such information. AERO will only disclose personal information to overseas recipients where reasonable steps have been taken to ensure the recipient does not breach the Australian Privacy Principles.

AERO has engaged the third-party provider Mailchimp to send newsletters on its behalf. MailChimp stores data in servers located in the United States of America (USA).

AERO uses surveys that are created and distributed using Qualtrics, a US-based cloud service. Qualtrics is a US-based software company that uses Amazon Web Services for its data hosting services. As outlined in the Qualtrics Subprocessor list, most data will be hosted and processed in the USA, using a number of third-party service providers.

Keeping your personal information safe

AERO is a cloud-first data organisation. We do not host any information on our physical premises.

AERO protects the personal information that we hold against misuse, interference, loss, unauthorised access, modification or disclosure by using up-to-date electronic and physical security controls that comply with relevant industry standards and guidelines. Only authorised staff have access to your personal information and your information will only be used in accordance with this policy.

The information we collect for research, employment, recruitment, procurement and managing our organisation is stored in Australia in an enterprise-grade data centre with advanced security and compliance capabilities. This excludes the information collected via Qualtrics and Mailchimp (see above).

How long will we keep your personal information?

The duration that we keep your personal information depends on the purposes for which we have collected it, the nature of the information and regulatory requirements.

Accessing and correcting personal information we hold about you

If you would like to:

  • know what, if any, personal information AERO holds about you
  • correct any personal information AERO that holds about you or
  • opt out of receiving communications from AERO,

you may contact AERO using the contact information below.

If you request access to your personal information or ask us to correct or update information about you, we may need to verify your identity. In some cases, there may be a valid reason for us to deny your request to access or correct your information. If we do this, we will notify you of the reason within 30 working days.

Assurance reviews

We will undertake regular assurance to ensure we follow our Privacy policy and meet community expectations.

How to make a complaint

If you are unhappy with how we have handled your personal information, please contact us. You can make a complaint using the contact details below. To ensure that we fully understand the nature of your complaint and the outcome you are seeking, we prefer that you make your complaint in writing.

Contact us

If you have any questions, comments or concerns about privacy, please contact us by:

  • Post: Australian Education Research Organisation, WeWork 320 Pitt St, Sydney, 3000. 
  • Email:

We will do our best to address and resolve any issues you raise.

If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner.

Changes to this privacy policy

AERO may make changes to this Privacy policy from time to time to take account of changes to AERO's operation and practices. 

Types of personal information our education research files may include

For school and student data

  • Student NAPLAN dataset ID
  • Student scholastic year
  • Student date of birth
  • Student gender
  • Student Aboriginal and/or Torres Strait Islander status
  • Student background indicator (for example, Language Background Other than English [LBOTE status])
  • Disability status
  • School socioeconomic indicator (for example, Index of Community Socio-Educational Advantage [ICSEA])
  • Student NAPLAN score
  • Student HSC score
  • School code or name
  • School sector (government, Catholic, Independent)
  • School type (for example, primary or secondary)
  • School location (for example, state, Australian Statistical Geography Standard [ASGS] remoteness)
  • Total school enrolments
  • Total enrolments in scholastic year

For educator/teacher/principal data

  • Role (for example, teacher, principal.)
  • Time in role
  • Time at service/school
  • Years of experience
  • Gender
  • School/service code or name
  • School/service location (for example, state, ASGS remoteness)
  • School/service size (estimate number of children/students/staff)
  • School sector (government, Catholic, Independent)
  • School type (for example, primary or secondary)
  • Type of service (for example, preschool, long day care)
  • Type of service (for example, private, community, government)
  • Job satisfaction
  • Wellbeing indicators
  • Salary range


Whistleblower policy

The Whistleblower policy has been put in place to ensure any concerns raised regarding any misconduct or improper state of affairs or circumstances in relation to the AERO’s business are dealt with effectively, securely, appropriately, and in accordance with the Corporations Act 2001 (Cth) (the Act).

AERO encourages the reporting of any instances of suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving AERO’s business and provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal.

This policy will be provided to all employees and officers of AERO upon commencement of their employment or engagement.

The policy is also available to persons outside the organisation. 

AERO may invite officers, senior management and employees to attend training sessions to ensure ongoing education regarding the application of the policy.


This policy applies to any person who is, or has been, any of the following with respect to the Company:

  • employee
  • officer
  • Director
  • contractor (including sub-contractors and employees of contractors)
  • supplier (including employees of suppliers)
  • consultant
  • auditor
  • associate
  • relative, dependant, spouse, or dependant of a spouse of any of the above.

This policy is intended to apply to the above persons in all countries in which AERO operates.

Reportable Conduct

You may make a report or disclosure under this policy if you have reasonable grounds to believe that an AERO Director, officer, employee, contractor, supplier, consultant or other person who has business dealings with the company has engaged in conduct (Reportable Conduct) which is:

  • dishonest, fraudulent or corrupt
  • illegal (such as theft, dealing in or use of illicit drugs, violence or threatened violence and criminal damage to property)
  • unethical including any breach of the company’s policies such as the Code of Conduct
  • oppressive or grossly negligent
  • potentially damaging to the company, its employees or a third party
  • misconduct or an improper state of affairs
  • a danger, or represents a danger to the public or financial system
  • harassment, discrimination, victimisation or bullying.

Any disclosures that do not fall within the definition of Reportable Conduct, will not qualify for protection under the Act. It will be at AERO’s discretion whether it considers there is a reasonable suspicion that the Reportable Conduct is occurring and/or whether the conduct constitutes “misconduct or improper state of affairs” under the Act.

For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the company. Examples of personal work-related grievances are as follows:

  • an interpersonal conflict between the staff member and another employee
  • a decision relating to the engagement, transfer or promotion of the staff member
  • a decision relating to the terms and conditions of engagement of the staff member
  • a decision to suspend or terminate the engagement of the staff member, or otherwise to discipline the staff member.

Personal work-related grievances should be reported to your manager or the Senior Manager, Strategy and Operations, in accordance with AERO’s Code of Conduct.

Making a disclosure

AERO relies on its employees maintaining a culture of honest and ethical behaviour. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure under this policy. 

There are several ways in which you may report or disclose any issue or behaviour which you consider to be Reportable Conduct.

Internal reporting

You may disclose any Reportable Conduct to the Whistleblower Protection Officers:

You can make a disclosure outside of business hours by contacting the above Whistleblower Protection Officers via email.

You are also encouraged to contact the above Whistleblower Protection Officers to obtain any additional information you may require before making a disclosure or for any clarification regarding this policy.

If you are unable to use any of the above reporting channels, a disclosure can be made to an “eligible recipient” within, or adjacent to the company. Eligible recipients include:

  • officers
  • Directors
  • senior managers
  • auditor or member of an audit team conducting an audit of the company
  • actuary.

The Whistleblower Protection Officer or eligible recipient will safeguard your interests and will ensure the integrity of the reporting mechanism.


When making a disclosure, you may do so anonymously. It may be difficult for AERO to properly investigate the matters disclosed if a report is submitted anonymously and therefore AERO encourages you to share your identity when making a disclosure, however you are not required to do so.

Where a disclosure has been made externally and you provide your contact details, those contact details will only be provided to a Whistleblower Protection Officer with your consent. 

Reporting to regulators

You may also make a disclosure to the Australian Securities and Investments Commission (ASIC) or the Australian Prudential Regulation Authority (APRA) in relation to a Reportable Conduct. You will be covered by the protections outlined in this policy if you have reported your concerns to ASIC or APRA.

Reporting to a legal practitioner

You may choose to discuss your concerns with a legal practitioner for the purposes of obtaining legal advice or representation. You will be covered by the protections outlined in this policy if you have reported your concerns to a legal practitioner.

Public interest and emergency disclosure

In certain situations, the conduct or wrongdoing may be of such gravity and urgency that disclosure to the media or a parliamentarian is necessary.

A public interest and emergency disclosure can only be made to:

  • a journalist, defined to mean a person who is working in a professional capacity as a journalist for a newspaper, magazine, or radio or television broadcasting service; or
  • a Member of the Parliament of the Commonwealth or of a State or Territory parliament.

You may only make a public interest and emergency disclosure if:

  • you have previously disclosed the information to ASIC or APRA;
  • at least 90 days has passed since the previous disclosure was made;
  • you have reasonable grounds to believe that action is not being taken to address the matters which you have disclosed;
  • you have reasonable grounds to believe that making a further disclosure to a journalist or member of parliament would be in the public interest;
  • you have given written notification, including sufficient information to identify the previous disclosure to the authority to which the previous disclosure was made that you intend on making a public interest disclosure; and
  • you have given written notification, including sufficient information to identify the previous disclosure to the authority to which the previous disclosure was made that you intend on making a public interest disclosure; and
  • the extent of information disclosed is no greater than is necessary to inform the recipient of the misconduct or improper state of affairs.

You will be qualified for protection where you have made a public interest disclosure if:

  • you have previously disclosed the information to ASIC or APRA;
  • you have reasonable grounds to believe that the information concerns a substantial and imminent danger to the health or safety of one or more persons, or to the natural environment; and
  • you have given written notification, including sufficient information to identify the previous disclosure to the authority to which the previous disclosure was made that you intend on making a public interest disclosure; and
  • no more information is disclosed than is reasonably necessary to inform the recipient of the substantial and imminent danger.


AERO will investigate all matters reported under this policy as soon as practicable after the matter has been reported. The Whistleblower Protection Officer will investigate the matter and where necessary, appoint an external investigator to assist in conducting the investigation. All investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation.

If the report is not anonymous, the Whistleblower Protection Officer or external investigator will contact you, by your preferred method of communication to discuss the investigation process and any other matters that are relevant to the investigation.

Where you have chosen to remain anonymous, your identity will not be disclosed to the investigator or to any other person and AERO will conduct the investigation based on the information provided to it.

Where possible, the Whistleblower Protection Officer will provide you with feedback on the progress and expected timeframes of the investigation. The person against whom any allegations have been made will also be informed of the concerns and will be provided with an opportunity to respond (unless there are any restrictions or other reasonable bases for not doing so).

To the extent permitted by law, the Whistleblower Protection Officer may inform you and/or a person against whom allegations have been made of the findings. AERO will document the findings in a report, however any report will remain the property of AERO and will only be shared with you or any person against whom the allegations have been made if AERO deems it appropriate.

Protection of whistleblowers

AERO is committed to ensuring that any person who makes a disclosure is treated fairly and does not suffer detriment and that confidentiality is preserved in respect of all matters raised under this policy.

Protection from legal action

You will not be subject to any civil, criminal or administrative legal action (including disciplinary action) for making a disclosure under this policy or participating in any investigation.

Any information you provide will not be admissible in any criminal or civil proceedings other than for proceedings in respect of the falsity of the information.

Protection against Detrimental Conduct

AERO (or any person engaged by AERO) will not engage in “Detrimental Conduct” against you, if you have made a disclosure under this policy.

Detrimental Conduct includes actual or threatened conduct such as the following (without limitation):

  • termination of employment
  • injury to employment including demotion, disciplinary action
  • alteration of position or duties
  • discrimination
  • harassment, bullying or intimidation
  • victimisation
  • harm or injury including psychological harm
  • damage to a person’s property
  • damage to a person’s reputation
  • damage to a person’s business or financial position
  • any other damage to a person.

AERO also strictly prohibits all forms of Detrimental Conduct against any person who is involved in an investigation of a matter disclosed under the policy, in response to their involvement in that investigation.

AERO will take all reasonable steps to protect you from Detrimental Conduct and will take necessary action where such conduct is identified. If appropriate, AERO may allow you to perform your duties from another location or reassign you to another role (at the same level) or make other modifications to your workplace or your duties to protect you from the risk of detriment.

If you are subjected to Detrimental Conduct as a result of making a disclosure under this policy or participating in an investigation, you should inform a Whistleblower Protection Officer or eligible recipient in accordance with the reporting guidelines outlined above.

You may also seek remedies including compensation, civil penalties or reinstatement if:

  • you suffer loss, damage or injury because of a disclosure; and
  • AERO failed to take reasonable precautions and exercise due diligence to prevent any Detrimental Conduct.

Protection of confidentiality

All information received from you will be treated confidentially and sensitively.

You will not be required to provide your name when making a disclosure. To make a disclosure on an anonymous basis, it is recommended that you use a pseudonym and contact the Whistleblowing Protection Officers in the manner outlined above.

If you report on an anonymous basis, you will still qualify for the protections in this policy.

If you make a disclosure under this policy, your identity (or any information which would be likely to identify you) will only be shared if:

  • you give your consent to share that information; or
  • the disclosure is allowed or required by law (for example, where the concern is raised with a lawyer for the purposes of obtaining legal advice); or
  • the concern is reported to the Australian Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA), the Australian Taxation Office (ATO) or the Australian Federal Police (AFP).

Where it is necessary to disclose information for the effective investigation of the matter, and this is likely to lead to your identification, all reasonable steps will be taken to reduce the risk that you will be identified. For example, all personal information or reference to you witnessing an event will be redacted from any report, you will be referred to in a gender-neutral context, where possible you will be contacted to help identify certain aspects of your disclosure that could inadvertently identify you. Any disclosure under this policy will also be handled and investigated by qualified staff.

AERO will also take the following measures for protecting your identity:

  • All paper and electronic documents and other materials relating to disclosures will be stored securely.
  • Access to all information relating to a disclosure will be limited to those directly involved in managing and investigating the disclosure.
  • Only a restricted number of people who are directly involved in handling and investigating a disclosure will be made aware of your identity (subject to your consent) or information that is likely to lead to your identification.
  • Communications and documents relating to the investigation of a disclosure will not be sent to an email address or to a printer that can be accessed by other staff.
  • Each person who is involved in handling and investigating a disclosure will be reminded about the confidentiality requirements, including that an unauthorised disclosure of your identity may be a criminal offence.

If you are concerned that your identity has been disclosed in relation to a disclosure, and without your consent, you should inform a Whistleblower Protections Officer or eligible recipient immediately.

Support available

Any employee who makes a disclosure under this policy or is implicated as a result of a disclosure that is made may access AERO’s Employee Assistance Program (EAP), which is a free and confidential counselling service.

Where appropriate, AERO may also appoint an independent support person to deal with any ongoing concerns you may have.

You may also access third-party support providers such as Lifeline (13 11 14) and Beyond Blue (1300 22 4636) for support.

Other matters

Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including termination of employment.

In so far as this policy imposes any obligations on AERO, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract. 

AERO may unilaterally introduce, vary, remove or replace this policy at any time.

Employees are encouraged to read this policy in conjunction with other relevant company policies, including the Code of Conduct.