Data & Privacy

1. Who We Are and How to Contact Us

Invigila is developed by a team based in Sydney, Australia. We provide software that helps schools and other institutions plan, administer, and deliver examinations and invigilation. Questions about this policy or Invigila’s handling of personal information can be submitted through Contact Us.

2. Scope, Roles, and Applicable Law

This policy applies to personal information handled through the Invigila website, administrator tools, invigilation features, feedback and contact forms, and related support services. It should be read together with the privacy notice and policies of the school or institution using Invigila.

The institution generally decides what examination and student information is entered and why it is used. The institution is responsible for having a lawful basis for that handling, limiting entries to what is necessary, managing its authorised users, and giving required notices to students, parents, guardians, and staff. Invigila remains responsible for its own handling of information and for taking reasonable steps to operate and secure the service. Responsibility cannot be transferred entirely to the institution by this policy.

Depending on the institution, the individual, and the information involved, relevant laws may include the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Health Records and Information Privacy Act 2002 (NSW) (HRIP Act), and other State, Territory, education, records, and contractual requirements. Not every law applies to every institution in the same way.

3. Information Handled Through Invigila

Depending on how the service is used, information may include:

• Administrator account information, including an email address and authentication information managed through Firebase Authentication.
• Examination and session information, including exam periods, subjects, papers, dates, timings, rooms, notices, entry codes, session status, layouts, and related configuration.
• Student and special-provision information, where entered by an institution, including a student name, rest-break entitlement, extra-time entitlement, and student-specific notices.
• Institution information, including settings, subjects, custom formats, branding, uploaded school logos, and display preferences.
• Feedback and contact information, including names, email addresses, school names, and message content.
• Technical and usage information, which may include device and browser information, identifiers, analytics events, authentication records, diagnostic information, IP addresses in provider logs, and locally cached session information.

Invigilators normally use an entry code rather than an administrator account. Entry codes must be treated as confidential access credentials and shared only with people who need them.

4. Student Special-Provision and Health Information

A special-provision label is not automatically health information in every circumstance. However, when information identifies or can reasonably identify a student and reveals or permits an inference about that student’s health, disability, or health-related adjustments, it may be “health information” under the HRIP Act and the Privacy Act. Health information is also “sensitive information” under the Privacy Act and receives additional protection.

Institutions must not enter diagnostic details or other medical information unless it is genuinely necessary and lawful. Use the minimum information required to administer the adjustment. Before, or as soon as practicable after, collecting applicable information, the responsible institution must provide any notice required by law. Depending on the law that applies, this may need to explain the institution’s identity and contact details, what is collected, why it is collected, who usually receives it, whether collection is required, the consequences of not providing it, how the individual may request access or correction, the use of Invigila and Firebase, and any likely transfer or disclosure outside New South Wales or Australia. Where information is collected from someone other than the student, additional notification steps may apply.

5. How Information Is Used

Information is used to:

• provide, administer, and support Invigila for institutions and authorised users;
• authenticate administrators and manage access to accounts and sessions;
• plan examinations and display relevant session information in the examination room;
• support special-provision arrangements entered by the institution;
• cache session information temporarily for offline invigilation and synchronise queued status changes when connectivity returns;
• respond to feedback, support requests, and enquiries;
• measure, maintain, secure, troubleshoot, and improve the service; and
• comply with legal obligations and enforce applicable agreements.

6. Disclosure and Service Providers

Invigila does not sell personal information. Information may be made available to authorised institution users and invigilators, including through session entry codes, and to suppliers where reasonably necessary to provide the service. Invigila currently uses Google Firebase services, including Cloud Firestore, Firebase Authentication, Cloud Storage, Hosting, and Google Analytics. Google processes information under its applicable service terms and privacy and security documentation. Information may also be disclosed where required or permitted by law.

Institutions must ensure that session codes and administrator credentials are disclosed only to authorised recipients. Invigila may suspend or restrict access where needed to protect users, institutions, or the service.

7. Data Location and Overseas Processing

Cloud Firestore can be provisioned in an Australian region, and Invigila intends its production examination database to use an Australian location. The precise deployed database location must be confirmed from the relevant Firebase project configuration before an institution relies on a representation of domestic database hosting; it cannot be established from the public website code alone.

Domestic database hosting does not mean that every service, backup, support operation, log, or processing activity remains in Australia. Firebase Authentication, Hosting, Analytics, and other Google or supplier services may operate on global infrastructure and may process information in countries where Google or its subprocessors maintain facilities. Where required, Invigila and the institution must address cross-border handling under APP 8, section 16C of the Privacy Act, HPP 14 of the HRIP Act, and any other applicable requirements.

8. Encryption and Security

Firebase states that relevant services encrypt information in transit and that Cloud Firestore, Firebase Authentication, and Cloud Storage encrypt information at rest. This is server-side and transport encryption, not end-to-end encryption. Information is transparently decrypted when accessed by an authorised user or service. It is therefore not accurate to say that encryption makes the information unreadable to Invigila, Google, or every person with sufficiently privileged administrative access.

Invigila uses access controls and other safeguards intended to protect information against loss, misuse, interference, and unauthorised access, use, modification, or disclosure. No system is completely secure. Institutions must use strong account practices, promptly remove unnecessary access, protect entry codes, and avoid entering information that is not needed.

9. Cookies and Browser Storage

It would not currently be accurate to state that Invigila stores no cookies. The website initializes Google Analytics where supported; Google Analytics ordinarily uses first-party cookies such as _ga and _ga_<container-id> to distinguish users and maintain session state. Firebase Authentication and Invigila features may also use browser mechanisms such as IndexedDB, local storage, and session storage to maintain authentication, remember settings, cache invigilation sessions for offline use, and queue limited status changes for synchronisation.

Browser controls can clear or block these technologies, but doing so may affect sign-in, analytics, offline operation, preferences, or other functionality. If Invigila later disables Analytics or introduces consent controls, this section will be updated to reflect that change.

10. Retention and Deletion

Personal and health information should be retained only for as long as it is lawfully needed for the purpose for which it was collected, applicable records obligations, security, dispute resolution, and service operation. Institutions control much of the examination content they enter and are responsible for applying their retention schedule. Browser caches may remain until the browser session ends, queued offline changes are synchronised, or local site data is cleared. Provider logs and backups may follow separate documented retention cycles.

11. Access, Correction, and Complaints

Individuals seeking student or examination information should normally contact the institution that entered it, because that institution controls the record and can verify identity and authority. Requests concerning information controlled directly by Invigila, or questions about this policy, can be submitted through Contact Us. Access or correction may be limited where an applicable law permits or requires refusal.

Privacy complaints should first be raised with the responsible institution or Invigila, depending on who handled the information. A person may also have a right to contact the Office of the Australian Information Commissioner, the Information and Privacy Commission NSW, or another relevant regulator.

12. Institution Names and Marketing

Invigila will not publish a student’s, staff member’s, or other individual’s personal information as a customer reference. An institution’s name, logo, testimonial, or status as a customer may be used in Invigila marketing only where that use is authorised by the applicable licence or order form, or the institution has otherwise given written permission. Merely using or licensing Invigila does not, by itself, grant a marketing endorsement unless the governing agreement expressly says so.

13. Changes and Related Policies

We may update this policy as the service, suppliers, or legal requirements change. The “Last updated” date will identify the latest revision. Material changes should be communicated where required. Please also read our Acceptable Use statement.