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The Elite Interior Design Academy
Organisation Group Coaching Privacy Policy

Effective date: 1 July 2026

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1. About this Privacy Policy

FOS Collective Pty Ltd ABN 89 655 956 013, trading as Elite Interior Design Academy (“EIDA”, “we”, “us” or “our”), provides group coaching, mentoring, workshops, facilitation and professional development services to design practices, businesses, associations and other organisations.

This Privacy Policy explains how EIDA handles personal information about:

  • Client representatives;

  • owners and directors;

  • employees and contractors;

  • Program Participants;

  • individual coaching Participants;

  • speakers and facilitators;

  • suppliers; and

  • other individuals connected with an organisational engagement.

EIDA intends to handle personal information consistently with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable laws.

This Policy should be read with:

  • the Organisation Group Coaching Services Agreement;

  • the relevant Proposal or statement of work;

  • any participant collection notice;

  • any confidentiality or data-sharing arrangement;

  • EIDA’s website cookie notice; and

  • any recording or marketing consent form.

 

2. Information we may collect

EIDA may collect:

Client representative information

  • name;

  • position;

  • business contact details;

  • authority to approve the engagement;

  • billing information;

  • communications;

  • meeting notes; and

  • project or Program requirements.

Participant information

  • name;

  • preferred name;

  • email address;

  • telephone number;

  • job title;

  • career level;

  • employment or contractor status;

  • professional experience;

  • location;

  • attendance;

  • participation;

  • development goals;

  • survey responses;

  • Program feedback;

  • completed activities; and

  • certificate information.

Organisational information connected to individuals

  • team structure;

  • reporting relationships;

  • professional responsibilities;

  • capability observations;

  • communication challenges;

  • leadership goals;

  • role expectations;

  • participant nominations;

  • performance-development themes; and

  • workplace examples.

EIDA does not provide formal employee surveillance, workplace investigation or psychological assessment services.

Individual coaching information

Where individual coaching is included, EIDA may collect:

  • professional goals;

  • development concerns;

  • self-assessments;

  • mentoring questions;

  • agreed actions;

  • session attendance;

  • brief coaching notes; and

  • feedback.

Sensitive information

EIDA may collect limited sensitive information where reasonably necessary, including:

  • accessibility requirements;

  • health information relevant to participation;

  • dietary requirements;

  • safety information; or

  • information voluntarily disclosed during coaching.

Express consent will generally be sought before sensitive information is collected unless another lawful basis applies.

Financial, technical and website information

EIDA may also collect:

  • invoices;

  • transaction information;

  • payment status;

  • IP address;

  • browser and device information;

  • website activity;

  • cookie information;

  • email interactions; and

  • virtual-platform participation information.

EIDA does not ordinarily retain complete payment card details.

 

3. How information is collected

Information may be collected:

  • directly from the Client;

  • directly from a Participant;

  • through the Proposal and onboarding process;

  • through questionnaires and surveys;

  • during group or individual sessions;

  • through email, telephone and video calls;

  • through attendance records;

  • through feedback and evaluation;

  • from a manager or authorised Client representative;

  • through digital, website, payment and learning platforms; and

  • from publicly available professional sources where reasonably necessary.

Where the Client gives EIDA information about Participants, the Client is responsible for ensuring it is authorised to do so and for giving Participants any notice required by law.

EIDA may also provide Participants with a direct collection notice.

 

4. Why EIDA collects information

EIDA may collect, hold, use and disclose information to:

  • prepare and administer Proposals;

  • design and tailor coaching programs;

  • understand participant experience levels;

  • schedule and deliver Services;

  • provide reasonable adjustments;

  • communicate with Participants;

  • facilitate group activities;

  • provide individual coaching;

  • monitor attendance;

  • issue certificates;

  • evaluate engagement and Program effectiveness;

  • provide agreed reporting;

  • manage payment and invoicing;

  • protect safety and confidentiality;

  • manage complaints and disputes;

  • protect intellectual property;

  • improve EIDA services;

  • maintain business records;

  • comply with legal obligations; and

  • send marketing where consent or another lawful basis exists.

 

5. Consequences of not providing information

Participants are not required to disclose unnecessary personal or sensitive information.

However, EIDA may be unable to:

  • include an individual in a Program;

  • communicate session information;

  • tailor content;

  • provide individual coaching;

  • make an accessibility adjustment;

  • issue a certificate; or

  • respond properly to a concern

where necessary information is not provided.

 

6. Relationship between EIDA and the Client

Depending on the engagement, EIDA may:

  • collect information directly for its own Program administration;

  • handle information on the Client’s instructions;

  • independently hold coaching, attendance or complaint records; or

  • jointly manage certain information with the Client.

The Proposal or a separate data-sharing schedule may clarify these responsibilities.

Where there is an inconsistency between this Policy and an agreed data-sharing schedule, the specific data-sharing schedule will apply to the extent of the inconsistency.

 

7. Information EIDA may provide to the Client

Subject to the Proposal, EIDA may provide the Client with:

  • attendance;

  • participation or completion status;

  • aggregate evaluation results;

  • broad development themes;

  • Program feedback;

  • certificate eligibility;

  • implementation recommendations;

  • agreed outcomes reporting; and

  • serious safety, conduct or confidentiality concerns.

Reports should ordinarily be aggregated or de-identified where individual identification is unnecessary.

 

8. Individual coaching confidentiality

Individual coaching is intended to provide a professionally safe environment for reflection and development.

Unless otherwise clearly agreed before coaching begins, EIDA will not ordinarily disclose to the Client:

  • detailed coaching notes;

  • the substance of private discussions;

  • personal reflections;

  • sensitive information; or

  • individual comments about colleagues or management.

EIDA may disclose information where:

  • the Participant gives consent;

  • disclosure is required by law;

  • there is a serious or imminent safety concern;

  • there is suspected serious unlawful conduct;

  • confidentiality or intellectual property has been seriously breached;

  • disclosure is necessary to respond to a complaint; or

  • the reporting arrangement expressly permits the disclosure.

EIDA may provide the Client with high-level, de-identified themes without identifying the Participant.

Participants will be informed of the reporting boundaries where individual coaching is included.

 

9. Performance and employment decisions

EIDA does not ordinarily make employment, promotion, remuneration, disciplinary or termination decisions for the Client.

The Client remains responsible for its own workplace and employment decisions.

EIDA’s coaching observations, questionnaires and Program feedback should not be treated as the sole basis for an adverse employment decision.

EIDA does not provide formal psychometric assessment, medical assessment, workplace surveillance or human resources investigation unless expressly qualified and engaged to do so.

 

10. Group confidentiality

EIDA may establish confidentiality expectations for Participants, but it cannot guarantee that every Participant will comply.

Participants should not disclose:

  • legally privileged information;

  • client-confidential information;

  • confidential project details;

  • trade secrets;

  • unnecessary sensitive information;

  • personal complaints requiring formal human resources management; or

  • information they are not authorised to share.

The Client remains responsible for its internal policies, staff conduct and disciplinary processes.

 

11. Disclosures to service providers and advisers

EIDA may disclose information where reasonably necessary to:

  • EIDA employees and contractors;

  • facilitators and guest contributors;

  • virtual meeting and learning-platform providers;

  • website and email providers;

  • payment processors;

  • accountants and bookkeepers;

  • legal and professional advisers;

  • information technology and security providers;

  • insurers;

  • venue and event providers;

  • regulators or law-enforcement bodies; and

  • emergency services where necessary.

Service providers will only receive information reasonably necessary for their role.

 

12. Recordings

A session will not be recorded unless recording has been agreed or Participants have been appropriately notified.

Where recording is approved:

  • the Client must ensure Participants receive appropriate notice;

  • consent will be obtained where required;

  • access will be limited to approved users;

  • the recording must not be redistributed;

  • EIDA intellectual property remains protected;

  • private coaching sessions will not ordinarily be recorded; and

  • the recording will be retained only for the agreed period or purpose.

Recording permission does not automatically permit use for future cohorts, public marketing or artificial intelligence training.

 

13. Artificial intelligence and digital tools

EIDA may use digital tools to assist with administration, Program development, drafting, de-identified analysis or delivery.

EIDA will not knowingly upload identifiable individual coaching notes, sensitive workplace information, confidential Client data or identifiable Participant responses to a public generative artificial intelligence platform unless:

  • the information has been appropriately de-identified;

  • the Client and affected individuals have been clearly informed and consented; or

  • the service operates under approved privacy, confidentiality and security protections.

EIDA does not ordinarily use artificial intelligence as the sole decision-maker for participant removal, certification or reporting of serious individual concerns.

 

14. Direct marketing

EIDA may send authorised Client representatives or Participants information about relevant professional development, events, services and Program opportunities where consent or another lawful basis exists.

Individuals may opt out by:

Electronic marketing opt-out requests will be actioned within five business days.

Operational communications about an existing engagement are not marketing communications.

 

15. Cookies and website information

EIDA’s website may use essential, analytics, preference and marketing technologies.

These tools may collect:

  • IP address;

  • browser type;

  • device information;

  • referring source;

  • website interactions;

  • form activity; and

  • email campaign interactions.

Non-essential cookies may be managed through available cookie settings or browser controls.

 

16. Overseas handling

EIDA’s online service providers may store, process or access information outside Australia, potentially including in:

  • the United States;

  • Israel;

  • the United Kingdom;

  • countries within the European Economic Area; and

  • other locations used by the relevant supplier or subcontractor.

EIDA will take reasonable steps appropriate to the engagement when selecting and managing providers.

Where the Client requires Australian-only hosting or specific data residency, this must be disclosed and agreed before the Proposal is accepted.

 

17. Storage and security

Information may be held in:

  • email systems;

  • cloud storage;

  • website databases;

  • customer relationship systems;

  • survey platforms;

  • learning platforms;

  • accounting systems;

  • facilitator notes;

  • password-protected devices; and

  • limited physical files.

EIDA may use:

  • access restrictions;

  • multi-factor authentication where available;

  • secure payment systems;

  • password protection;

  • confidentiality obligations;

  • supplier due diligence;

  • software updates;

  • backups; and

  • secure destruction processes.

No system can be guaranteed to be completely secure.

 

18. Retention

EIDA retains information for only as long as reasonably necessary for:

  • Program delivery;

  • evaluation;

  • contractual administration;

  • payment and taxation records;

  • certificate verification;

  • complaints and disputes;

  • legal obligations; and

  • legitimate business requirements.

As a general operating practice:

  • Client contracts, invoices and core engagement records may be retained for at least seven years;

  • individual coaching notes may be deleted or de-identified after they are no longer reasonably required;

  • certificate and attendance records may be retained for verification;

  • recordings will be retained only for the agreed access or operational period; and

  • de-identified information may be retained for Program improvement and planning.

 

19. Access and correction

An individual may request access to, or correction of, personal information EIDA holds about them by emailing info@foscollective.com.au.

EIDA may:

  • verify identity;

  • consult the Client where information is held in connection with the engagement;

  • provide access directly;

  • refer part of the request to the Client; or

  • refuse or limit access where permitted by law.

EIDA will ordinarily aim to respond within 30 days.

Where access or correction is refused, EIDA will provide reasons where required.

 

20. Privacy complaints

A complaint may be submitted to:

Privacy Officer
FOS Collective Pty Ltd
Trading as Elite Interior Design Academy
Email: info@foscollective.com.au

The complaint should identify:

  • the information or conduct concerned;

  • relevant dates;

  • the people involved;

  • any supporting documents; and

  • the outcome sought.

EIDA will acknowledge and investigate the complaint and will ordinarily aim to respond within 30 days.

EIDA may consult the Client where necessary, but will avoid disclosing unnecessary personal or sensitive information.

An unresolved complaint may be referred to the Office of the Australian Information Commissioner or another relevant body where available.

 

21. Data breaches

EIDA will take reasonable steps to:

  1. contain a suspected breach;

  2. assess the information and individuals affected;

  3. reduce potential harm;

  4. coordinate with the Client and relevant providers;

  5. notify affected individuals where appropriate; and

  6. notify the Office of the Australian Information Commissioner where legally required.

The Client must promptly notify EIDA if it becomes aware of a breach involving information supplied to, received from or jointly handled with EIDA.

 

22. Publicity and testimonials

EIDA will not publicly identify the Client or a Participant in:

  • a case study;

  • testimonial;

  • photograph;

  • video;

  • media release;

  • social media post; or

  • promotional campaign

without the relevant approval or consent.

Approval for one specific use does not create permission for unrelated future use.

 

23. Changes to this Policy

EIDA may update this Policy when its Services, providers, technology or legal obligations change.

The current version will be published on the EIDA or FOS Collective website.

Material changes affecting an active engagement may also be communicated to the Client.

 

24. Contact

FOS Collective Pty Ltd
Trading as Elite Interior Design Academy
ABN 89 655 956 013
Email: info@foscollective.com.au
Website: www.foscollective.com.au

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