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E: info@peoplebank.com.au

Privacy Policy

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Privacy Policy


Introduction

Peoplebank Australia Ltd (we, our or us), incorporating Ambit Engineering Pty Ltd, Porterallen Pty Ltd, Leaders IT Services Pty Ltd, and Global Talent Services Pty Ltd, takes seriously its commitment to preserve the privacy of your personal information that we collect.

We will only collect information that is reasonably necessary for the proper performance of our activities or functions. We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it. We do not collect or use personal information for the purposes of unlawful discrimination.

We may decline to collect unsolicited personal information from or about you and may take such measures as we think appropriate to purge it from our systems.

By following the links in this document, you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs).

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

If you wish to contact us about your personal information you should contact us:

The Privacy Co-Ordinator

privacy@peoplebank.com.au
Level 17, 15 Blue Street, North Sydney, NSW 2060
Phone: +61 2 9409 4700

Collection Notice

Download a copy of our Personal Information Collection Notification & Consent to Electronic Transactions.

Personal Information Collection Notification & Consent to Electronic Transactions.

APP Entity

We manage personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

As 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

  • we check that it is reasonably necessary for our functions or activities as a recruiting and contracting 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 System. Some information may be disclosed to overseas recipients.
  • 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.

Future Changes

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly or conduct transactions with us that involve to collection of your personal information, it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.

Kinds of information that we collect and hold

The type of personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as recruiting and contracting firm is likely to differ depending on whether you are:

  • a Workseeker – i.e. someone who is looking for a placement or work through or with us; or whom we have identified as a person, who might be receptive to an offer of a placement or work through or with us;
  • a Client – i.e. someone other than a Workseeker, who is looking to acquire our services as a recruiting and contracting firm or whom we have identified as someone, who might be interested in acquiring our services;
  • a Referee – i.e. a person from whom we have sought facts or opinions regarding the suitability of one of our Workseeker for work or positions through us; and who may be a Referee nominated by the Workseeker, a Client or us.

Sensitive information is only collected with consent and where it is necessary for the performance of our functions and activities. Sensitive information will need to be collected where it relates to a genuine occupational requirement or an inherent requirement of the job or work being considered. Our collection of some types of sensitive information is also governed by equal opportunity and anti-discrimination laws.

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. It includes:

  • information submitted and obtained from Workseekers and other sources (e.g. Referees or Clients) in connection with applications for work;
  • information about personality, character, skills, qualifications and experience;
  • information about career path and preferences;
  • information about work entitlement and ability to undertake specific types of work;
  • work performance information;
  • information about incidents in the workplace;
  • personnel information including, but not limited to, contact details;
  • payment information;
  • information submitted and obtained in relation to absences from work due to leave, illness or other causes.

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:

  • client relationship information;
  • information about position, contracting and hiring authority;
  • information about team structures and roles;
  • information about incidents in the workplace.

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 may include:

  • information about work position, authority to give a reference and preferred contact details;
  • opinions of the Referee regarding the Workseeker’s character and work performance or work environment;
  • facts or evidence in support of those opinions, sometimes involving the Referee’s own knowledge and experience of having worked with the Workseeker.

Purposes

The purposes for which we collect, hold, use and disclose your personal information are those purposes that are reasonably necessary for the proper performance of our functions and activities and are likely to differ depending on whether you are:

The following sections are also relevant to our use and disclosure of your personal information:

For Workseekers

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

  • work placement operations;
  • recruitment functions;
  • staff management;
  • payment purposes;
  • training needs assessments;
  • risk management;
  • work health and safety operations;
  • marketing services to you; but only where this is permitted and whilst you are registered with us;
  • 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;
  • work placement operations;
  • recruitment functions;
  • training needs assessments;
  • risk management;
  • work health and safety operations;
  • 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;
  • risk management.

Our Policy on Direct Marketing

We may sometimes use personal information for marketing purposes but only subject to the following:

  • Workseekers, whilst they are registered with us, with updates in relation to employment opportunities, market information and promotions from time to time;
  • Clients, with whom we have a relationship, with market information and promotions from time to time;
  • Subscribers to our website with news and job alerts to which they have subscribed;
  • Personal Information is not used by or disclosed to any third party for marketing purposes;
  • Client lists are not generally obtained from third parties for marketing purposes;

In accordance with the anti-spam legislation, individuals to whom marketing communications are sent are:

  • chosen on the basis of having given their express and/or implied consent for such communications to be sent to them since they registered with Us for the purpose of engaging Us as their employment agent; and
  • always given on opt out or unsubscribe option in relation to such communications.

When sending direct marketing material we will give you the direct option as to whether or not you wish to receive marketing communications and remain compliant with anti-spam legislation.

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:

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.

See also the section on Photos & Images.

For Workseekers

Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work.

Personal information is also collected when:

  • we receive or give any reference about you;
  • we receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body;
  • we receive the results of any competency, psychometric, or medical test;
  • we receive performance feedback (whether positive or negative);
  • we receive any complaint from or about you in the workplace;
  • we receive any information about a workplace accident and/or incident in which you are involved;
  • we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
  • you provide us with any additional information about you;
  • electronically through our telecommunications and technology systems – see the section in this policy on Electronic Transactions.

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;
  • electronically through our telecommunications and technology systems – see the section in this policy on Electronic Transactions.

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 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;
  • for business or business related social purposes;
  • electronically through our telecommunications and technology systems – see the section in this policy on Electronic Transactions.

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.

Photos & Images

At times video surveillance which operates in or near our premises may capture photos or images of you.

You should also read the section about Electronic Transactions because sometimes your communications with us may attach profile images of yourself that you have uploaded to the Internet.

Electronic Transactions

This section explains how we handle personal information collected from our website and by other technology in the course of electronic transactions.

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 resource on Internet Communications and other Technologies.

It is important that you:

  • know your rights: read our privacy policy and collection statement;
  • be careful what information you share on the Web;
  • use privacy tools on the site – control access to your search listing and profile;
  • make sure your anti-virus and data protection software is up-to-date.

Please contact us by land line phone or postal mail if you have concerns about making contact via the Internet.

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 job notification list;
  • register as a site user to access facilities on our site such as a job notification board or rewards program;
  • make a written online enquiry or email us through our website;
  • submit a resume by email or through our website;
  • apply for a job via a third party website hosting a job advertisement.

See also:

Social Networks and Web Searches

In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. We may conduct Internet searches using search engines and entering your name and relevant identifying details.

Resume Harvesting and Job Matching

Our recruitment management system uses software which mass imports resumes from job advertisement applications, email from you to us, PC folders and other storage devices.

The software uses resume parsing technology to extract resumes and information contained in it. The captured resumes and contact info are then automatically transferred to respective fields in our database.

Web Browsing

When you look at our website, our Internet service provider makes a record of the visit and logs (in server logs) the following information for statistical purposes:

  • your server address
  • your top level domain name (for example .com, .gov, .org, .au, etc)
  • the pages you accessed and documents downloaded
  • the previous site you visited and
  • the type of browser being used.

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet service provider’s server logs.

We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work and improve the usability of those sites.

This site uses cookies to monitor usage of our website to create a personal record of when you visit our website and what pages you view. Cookies are necessary to enable us to create a better user experience on our web sites, but if an individual does not wish us to retain any information about their visit to our site the individual could delete the cookies on their browser and change the settings on their web browser program.

Email Tracking and Analytics

We may conduct email tracking for analytics purposes. Such tracking includes open rates, click through rates and which links were clicked but are not used to collect sensitive information.

We use Google analytics to track website traffic such as visits, time spent on site, and search terms. We do not collect personal or sensitive information using this method of tracking, which shows how many people have visited the website, but not who.

Cloud Computing Services

In cases where we use cloud computing services we will take reasonable steps to ensure that:

  • disclosure of your personal information to the cloud service provider is consistent with our disclosure obligations under the APPs. This may include ensuring that we have obtained your consent, or that the disclosure is for purposes within your reasonable expectations.
  • disclosure is consistent with any other legal obligations, such as the restrictions on the disclosure of tax file number information or the disclosure by private employment agencies of Workseeker details;
  • our Cloud computing services providers’ terms of service 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.

Uploading Photographs

Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws, and you may be responsible for any legal consequences.

Emails

Our technology systems log emails received and sent and may include voting, read and receipt notifications to enable tracking.

When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Call & Message Logs

Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display, which may include your profile picture if you have provided it.

When your call number is received by us because you phone us or send us a message, the number (and profile picture) will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Teleconferences & Video Conferences

Teleconferences and video conferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

Database

We use recruiting software and databases to log and record recruitment operations. Our Information Record System is designed to meet requirements that are reasonably necessary for our functions or activities as a recruiting and contracting firm.

Mobile Access

Some staff may use laptops, tablets, phones and other portable electronic devices that allow them to access, retrieve and store your personal information. Where our staff utilise portable devices, they are subject to our remote access and acceptable IT use policies.

Paperless Office

Recognising the environmental advantages and efficiencies it provides, we operate a partially paperless office. As a result, your paper based communications with us may be digitised and retained in digital format. The paper based communications may be securely culled.

It is therefore important that, except where specifically requested, you do not send us originals of any paper based document and that you retain copies for your own records.

Where we do request original paper based documents we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed.

How your personal information is held

When your personal information is collected it will be 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.

Your personal information may be accessed by our staff and disclosed in accordance with the APPs.

We take a range of measures to protect your personal information. There are some inherent risks in the use of the Internet Communications and other Technologies. It is important that you read the section on Electronic Transactions if you are using Internet Communications or other technologies to communicate with us. You should also read the section on Cross-Border Disclosures.

Our Information Record System

Personal information is stored in our secure candidate and client database and payroll system.

Where personal information is received in hard copy form, and the information is to be held, the hard copy is scanned into our internal candidate and client database and uploaded into the relevant client or candidate file, and the hard copies subsequently destroyed. Where personal information is received in electronic form, and the information is to be held, the soft copy/electronic format is uploaded into the relevant client or candidate file in our secure candidate and client database.

Where a workseeker has been offered an assignment by us and the information received includes payroll details (such as bank details, tax file number and superannuation information) this information is entered into the secure payroll system and stored in a secure electronic archiving solution.

Information Security

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

  • misuse, interference and loss; and
  • unauthorised access, modification or disclosure.

See also:

Training

We train our staff to respect the confidentiality of client information and the privacy of individuals.

System Access and Password Protection

Our Information Record Systems have multi-layer permission access which includes password protection and permission level access.

Software Protection

Our software is protected as follows:

  • Our network is protected using a firewall which governs internal and external access rights;
  • Our emails are filtered to determine email rights, spam control and content control;
  • Data is kept virus free by antivirus software which controls virus definition to all machines;
  • Data access is controlled by permissions software; and
  • All data is backed up both onsite and offsite.

Hardware Protection

Our hardware is protected as follows:

  • Our servers are located in dedicated, secure IT facilities. All access to IT equipment is strictly controlled.
  • Our servers are protected from failure by redundant hardware features.
  • All disk systems are redundant using some form of RAID; and
  • Sites contain backup UPS systems to protect against power loss or power anomalies.

Policy on portable electronic devices

In order to protect personal information from misuse, interference and loss, we do not, as a matter of practice, issue their staff with laptops, tablets, mobile phones or other portable electronic devices. Where our staff utilise their own portable devices, they are subject to our remote access and acceptable IT use policies.

Retention and disposal

We adopt record management practices in accordance with legislative requirements and policies and guidelines on recordkeeping and management of electronic communications.

Where information is lawfully destroyed this is done by secure means of disposal.

Clients and 3rd Parties

All client and third party information accessed and used by our on-hired personnel during the course of their assignments with our clients is protected from disclosure or unauthorised use by:

  • The confidentiality and privacy obligations that are contained in our contracts signed by such on-hired personnel; and
  • The obligations to comply with all client policies and procedures, including those in relation to confidentiality and privacy that are contained in our contracts signed by such on-hired personnel.

General Disclosures

This section deals with our disclosure policies. Personal Information that we hold about you is only disclosed for the primary and related purposes for which it was collected. In this section you will find out about our policies dealing with:

General Disclosures

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

In addition to disclosures for general purposes, we may also disclose your personal information for a range of related 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;
  • Accredited Auditors;
  • Insurance brokers, loss assessors and underwriters;
  • Superannuation fund managers; and
  • 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.

Cross-Border Disclosures

Some or all of your personal information may be disclosed to overseas recipients. The likely countries, type of information disclosed and likely recipients are indicated, so far as is practicable, in the following table:

Country Type of Information Likely Recipients
Canada All personal data Our recruitment Management system vendors for maintenance of our database
Hong Kong All personal data Our subsidiary company – Peoplebank Hong Kong; Our recruitment Management system vendors for maintenance of our database
New Zealand All personal data Our recruitment Management system vendors for maintenance of the database
Singapore All personal data Our subsidiary companies – Peoplebank Singapore; Confero Pte Lte
United States of America All personal data Our recruitment Management system vendors for maintenance of the database
United Kingdom All personal data Our recruitment Management system vendors for maintenance of the database

We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles.

However, 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. See also Electronic Transactions.

Access & Correction

You have a right to access and correct personal information under the Australian Privacy Principles (APPs).

This section sets out our policy dealing with:

See also: Complaints.

Access

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

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. We do refuse access if it would breach any confidentiality that attaches to that information or if it would interfere with 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 we make and which the communicator of that information is entitled to expect will be observed.

If you wish to obtain access to your personal information you should contact our Privacy Co-ordinator. You will need to be in a position to verify your identity and this may be in person. We may impose a moderate charge in providing access. Our Privacy Co-ordinator would discuss these with you.

You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within 30 days.

If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice that sets out:

  • the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
  • the mechanisms available to escalate the refusal decision.

Correction

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 re 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.

You should also anticipate that it may take a little time to process your application for correction as there may be a need to retrieve information from storage and review information in order to determine what information may be corrected. We will generally respond to your request for access within 30 days. There is no charge to correct information.

In some cases we may not agree that the information should be changed. If we refuse to correct your personal information as requested by you, we will give you a written notice that sets out:

  • the reasons for the refusal except to the extent that it would be unreasonable to do so; and
  • the mechanisms available to escalate the refusal decision.

You may also ask us to associate a statement that the information is contested as being inaccurate, out of date, incomplete, irrelevant or misleading and we will take such steps as are reasonable to do so.

Complaints

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. See also the section dealing with Access & Correction.

How to complain

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.

You can also make complaints to the Office of the Australian Information Commissioner. Complaints may also be made to ITCRA the industry association of which we are a member. ITCRA administers a Code of Conduct for the professional and ethical conduct of its members.

NOTE: The ITCRA Code and Dispute Resolution Rules do not constitute a recognised external dispute resolution scheme for the purposes of the APPs; but are primarily designed to regulate the good conduct of ITCRA members.

How your complaint will be handled

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 any recognised external dispute resolution scheme to which we belong or to the Office of the Australian Information Commissioner.