Privacy Policy

We manage personal information in Australia in accordance with the Privacy Act 1988 and Australian Privacy Principles. We manage personal information in Europe in accordance with European standards including GDPR.

This policy applies to information collected by The Recruitment Company Pty Ltd and our subsidiaries in Europe.

We only collect information that is reasonably necessary for the proper performance of our activities or functions as a recruitment agency.

We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.

By reading this policy, you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs) or as a data subject under GDPR in Europe.

You will also be able to find out about the information flows associated with that information.

If you have any questions please contact us

Simon Moss, Managing Director,

Level 15, 1 Castlereagh Street,
Sydney, NSW, 2000

[email protected]
02 8346 6700

GDPR

Our European operations, based in Dublin, will treat your personal data in accordance with the standards set out in GDPR. In particular:

In our normal course of business we will collect data about you. We will ensure that data we collect about you is safe, accurate and only collected

with your permission
Because we need to for legal or tax purposes
Because we need to for contractual purposes (such as that we need to protect our self if we have represented you to a client and need a trail of evidence to support this)

With your consent we will keep your data for a period of 2 years after which time we will ask again for consent to keep your information for a further 2 years
If we need to hold your data for legal or tax purposes we will hold your data for a period required by law for that particular reason
If we hold your information to protect us contractually, then we will hold your data for a period of 2 years
If we ask you for consent and this consent is not received within 30 days then, unless conditions b or c don’t apply then we will take that as non-consent and will remove your personal information from our system.
We will tell you specifically where we store your data
We will endeavour to ensure the security of that data at all times
If we suspect that a security breach has occurred and that your data may have been compromised then we will notify you as soon as possible.

Right to removal

Should you wish to have your details removed at any time then you can contact our data protection officer who will arrange to have your personal information removed from our systems (unless conditions b or c apply)

Data Protection Officer

Simon Moss - [email protected]

APP ENTITY

The Recruitment Company manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

Because we are a contracted service provider to a range of Commonwealth, State and Territory government agencies, it sometimes becomes necessary for us to collect and manage personal information as an Agency under different privacy arrangements.

If you wish to know whether this applies to you, please contact us.

INFORMATION FLOW

When we collect your personal information:

we check that it is reasonably necessary for our functions or activities as an employment agency and onhire firm.
we check that it is current, complete and accurate. This will sometimes mean that we have to cross check the information that we collect from you with third parties;
we record and hold your information in our Information Record. Some information may be disclosed to overseas recipients although this is unlikely.
we retrieve your information when we need to use or disclose it for our functions and activities at that time, we check that it is current, complete, accurate and relevant. This will sometimes mean that we have to cross check the information that we collect from you with third parties once again - especially if some time has passed since we last checked.

subject to some exceptions, we permit you to access your personal information in accordance with APP:12 of the (APPs). We correct or attach associated statements to your personal information in accordance with APP:13 of the (APPs). We destroy or de-identify your personal information when it is no longer needed for any purpose for which it may be used or disclosed provided that it is lawful for us to do so. We do not destroy or de-identify information that is contained in a Commonwealth Record.

KINDS OF INFORMATION THAT WE COLLECT AND HOLD

Personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as an employment agency and on-hire firm and is likely to differ depending on whether you are:

a Workseeker
a Client
a Referee

For Workseekers

The type of information that we typically collect and hold about Workseekers is information that is necessary to assess amenability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us and includes:

Contact details
Career history
Reference checks
Interview feedback notes
Email communications from you
Banking details
Insurance details

For Clients

The type of information that we typically collect and hold about Clients is information that is necessary to help us manage the presentation and delivery of our services and includes:

Contact details
Job descriptions
Job titles
Organisational charts
Banking details
Purchase orders
Names of team members and related parties

For Referees

The type of information that we typically collect and hold about Referees is information that is necessary to help to make determinations about the suitability of one of our Workseekers for particular jobs or particular types of work and includes:

Contact details
Feedback on specific candidates
Job titles
Project information

PURPOSES

The purposes for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:

a Workseeker
a Client
a Referee

For Workseekers

Information that we collect, hold, use and disclose about Workseekers is typically used for:

work placement operations;
recruitment functions;
statistical purposes and statutory compliance requirements;

For Clients

Personal information that we collect, hold, use and disclose about Clients is typically used for:

client and business relationship management;
recruitment functions;
marketing services to you;
statistical purposes and statutory compliance requirements;

For Referees

Personal information that we collect, hold, use and disclose about Referees is typically used for:

to confirm identity and authority to provide references;
Workseeker suitability assessment;
recruitment functions;

HOW YOUR PERSONAL INFORMATION IS COLLECTED

The means by which we will generally collect your personal information are likely to differ depending on whether you are:

a Workseeker
a Client
a Referee

We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.

Sometimes the technology that is used to support communications between us will provide personal information to us - see the section in this policy on Electronic Transactions

For Workseekers

Personal information will be collected from you directly when you apply for an advertised role or any other information in connection with your application to us for work.

Personal information is also collected when:

You email us
During telephone or face to face interviews
Through the recruitment process

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APPs and our Privacy Policy.

For Clients

Personal information about you may be collected:

when you provide it to us for business or business related social purposes;
when you email us
Through the recruitment process

For Referees

Personal information about you may be collected when you provide it to us:

in the course of our checking Workseeker references with you and when we are checking information that we obtain from you about Workseekers;
Whilst speaking to workseekers about potential referees

PHOTOS & IMAGES

We will not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances. We will expect to scan and retain photo ID should you secure a contract position via us. This will be retained for WHS compliance purposes.

ELECTRONIC TRANSACTIONS

Sometimes, we collect personal information that individuals choose to give us via online forms or by email, for example when individuals:

ask to be on an email list such as a subscription list to our company blog;
register as a site user to access facilities on our site such as a job notification board;
make a written online enquiry or email us through our website;
submit a resume by email or through our website;
contact us by email

It is important that you understand that there are risks associated with use of the Internet and you should take all appropriate steps to protect your personal information. It might help you to look at the OAIC's resources on Internet Communications and other Technologies

You can contact us by telephone or post if you have concerns about making contact via the Internet.

All electronic transactions are protected, wherever possible, by our internet security processes and systems

HOW YOUR PERSONAL INFORMATION IS HELD

Personal information is held in our Information Record System until it is no longer needed for any purpose for which it may be used or disclosed at which time it will be de-identified or destroyed provided that it is lawful for us to do so.

We take a range of measures to protect your personal information from:

misuse, interference and loss; and
Unauthorised access, modification or disclosure.

OUR INFORMATION RECORD SYSTEM

Our Information Record System is recruitment CRM system called TRIS which is produced by a company called Recruitment Systems based in Canberra. Information is stored in electronic format on our server which is located in a data centre in NSW.

IPROFILE

In order to manage the personal information and CVs of candidates that we receive, The Recruitment Company uses the services of iProfile Pty Ltd, trading as iProfile. The Recruitment Company is an iProfile Compatible Organisation;
An iProfile Compatible Organisation means an organisation that has been granted a licence by iProfile to use its products and services;
The Recruitment Company also collects candidate’s personal information for the purpose of creating an iProfile for the candidate. Occasionally, in addition to the parties set out in this Privacy Policy above, we may also collect a candidate’s personal information from iProfile in order to obtain a candidate’s most current information;
The Recruitment Company may also disclose the candidate’s personal information to iProfile for the purpose of creating an iProfile or for the purpose of updating or managing a candidate’s iProfile;
The candidate’s personal information contained in the iProfile may also be shared with other iProfile Compatible Organisations that the candidate has previously provided his/her CV to; and
By providing its personal information to The Recruitment Company, to iProfile, or to any other iProfile Compatible Organisation, the candidate consents to the collection, use and disclosure of its personal information in this manner.

INFORMATION SECURITY

Information stored on our server is protected by several layers of physical and online security. All paper based information is protected by physical security in our office.

DISCLOSURES

We may disclose your personal information for any of the purposes for which it is primarily held or for a lawful related purpose

We may disclose your personal information where we are under a legal duty to do so.

Disclosure will usually be:

internally and to our related entities
to our Clients
to Referees for suitability and screening purposes.

Related Purpose Disclosures

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically our CSPs would include:

Software solutions providers;
I.T. contractors and database designers and Internet service suppliers;
Legal and other professional advisors;
Insurance brokers, loss assessors and underwriters;
Superannuation fund managers;
Background checking and screening agents;

We take reasonable steps to ensure that terms of service with our CSPs recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations. You have the right to request to see details of which CSP's have seen your personal information.

Cross-Border Disclosures

Some of your personal information could possibly (although we don’t consider it to be likely) be sent to overseas recipients. We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.

ACCESS & CORRECTION

Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold.

Important exceptions include:

evaluative opinion material obtained confidentially in the course of our performing reference checks; and access that would impact on the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that the person who gave us that information is entitled to expect will be observed. We do refuse access if it would breach confidentiality.
Evaluative opinion material obtained confidentially in the course of us receiving feedback from involved parties in the recruitment process
Evaluative opinion material created by us in the course of us assessing suitability during the recruitment process

For more information about access to your information see our Access Policy For more information about applying to correct your information see our Correction Policy

ACCESS POLICY

If you wish to obtain access to your personal information you should contact us. You will need to be in a position to verify your identity. We will provide you access to this information within 30 days.

CORRECTION POLICY

If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us.

We will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third parties to whom we made the disclosure and we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so. We will endeavour to correct any information within 30 days

COMPLAINTS

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.

Complaints procedure

If you are making a complaint about our handling of your personal information, it should first be made to us in writing.

You can make complaints about our handling of your personal information to our Privacy Co-ordinator, whose contact details are:

Simon Moss, Managing Director,

Level 15, 1 Castlereagh Street,

Sydney, NSW, 2000

[email protected]
02 83466700

When we receive your complaint:

We will take steps to confirm the authenticity of the complaint and the contact details provided to us to ensure that we are responding to you or to a person whom you have authorised to receive information about your complaint;
Upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy.
We may ask for clarification of certain aspects of the complaint and for further detail;
We will consider the complaint and may make inquiries of people who can assist us to established what has happened and why;
We will require a reasonable time (usually 30 days) to respond;

If the complaint can be resolved by procedures for access and correction we will suggest these to you as possible solutions;If we believe that your complaint may be capable of some other solution we will suggest that solution to you, on a confidential and without prejudice basis in our response;If the complaint cannot be resolved by means that we propose in our response, we will suggest that you take your complaint to an independent panel. The cost of such seeking advice from this panel shall be met by you. If the complaint cannot be resolved by the independent panel, we will suggest that you take your complaint to the Office of the Australian Information Commissioner