APPROACH TO PRIVACY
The Company collects personal information in order to conduct its business and comply with a range of legislative requirements.
Personal information is information relating to an individual which personally identifies an individual or makes the person's identity reasonably apparent.
Personal information may also include ‘sensitive information’. Sensitive information is information or an opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record, health and biometric information or similar such information.
Sensitive information may be required to be collected in some circumstances. the Company will only collect sensitive information if it is necessary for business purposes. The Company will generally only collect sensitive information with your consent (unless otherwise permitted or required by law).
All information collected will be used and disclosed by the Company only in accordance with this policy and the law. The Company will take reasonable steps to ensure that all personal information is held securely.
COLLECTION OF PERSONAL INFORMATION
The Company will only collect personal information from individuals if it is reasonably necessary for the Company’s functions or activities.
INFORMATION PROVIDED BY AN INDIVIDUAL
It is the Company’s usual practice to collect personal information from those who work with and for the Company. In addition, as part of the recruitment process, the Company may obtain information directly from a candidate as a result of their application to a job advertisement.
Furthermore, if a candidate’s application is successful, as a condition of employment with the Company, the successful candidate will likely be asked to provide evidence of their identity and legal entitlement to work in Australia. It is likely a successful candidate will also be asked to provide personal information, such as emergency contact details, tax file number, superannuation and bank account details, which will form part of an employee file.
Specifically, the Company may collect personal information directly from an individual including:
• recruitment and on-boarding information such as an application form and resume, emergency contact details, and details of previous employment;
• contact details, including address, email address and phone number;
• date of birth;
• details of next of kin and emergency contact details;
• identification documents including passport and drivers’ licence;
• marital status and family details, including in relation to personal leave;
• bank details (including bank name and location, BSB and account number) and information in relation to tax status; and
• details of share and option plans.
INFORMATION PROVIDED BY A THIRD-PARTY
As part of the recruitment process, where relevant, and with the candidate’s consent, the Company may seek information about a candidate through a third-party such as a recruitment service provider or a former employer. With the candidate’s consent, the Company may also seek information regarding:
• prior employment history through reference checks;
• eligibility to work in Australia through a visa status check;
• educational qualifications by requesting confirmation of qualifications or results from an academic institution;
• interview records and details of any pre-employment assessments, including aptitude or other psychometric testing; and
• ability to perform the inherent requirements of the role, through medical and other allied health professionals, or criminal history check and/or working with children check.
The Company may also access personal information through publicly available networking sites such as Facebook or LinkedIn.
INFORMATION COLLECTED DURING THE COURSE OF EMPLOYMENT
The Company may also collect information about an individual and their work over the course of their employment with the Company, (or for contractors during the performance of a contract with the Company). Such information may include:
• details of any contract of employment (or contract for services) including start and end dates, department, role and location, reporting lines, title (including details of previous titles), working days and hours, details of promotions, details of bonuses, remuneration and salary (including details of previous remuneration), benefits and entitlements;
• any information relating to disciplinary or grievance investigations and proceedings, including any warnings and related correspondence;
• information relating to performance and behaviour at work, including appraisals, ratings, performance reviews, objectives, goals, and performance improvement plans;
• details of attendance at work and absences, including annual and personal leave;
• training records including training needs;
• details of any expenses claimed; and
• details of the use of Company property and equipment (including computers, swipe cards and telephone systems), emails and software.
The Company may also collect other personal information if required or authorised to do so by law.
USE OF PERSONAL INFORMATION
The purposes for which the Company may collect, use, and disclose personal information include (but are not limited):
• to establish, maintain and manage relationships, including to serve functions such as recruitment, payroll, appraisals, and any disciplinary action (including any termination of any employment or engagement) and managing employees’ work and any claim in relation to any injuries or illnesses;
• to assess or respond to claims, complaints, or conduct, or co-operate with investigations when required;
• to obtain professional services as required including legal, human resources, industrial relations, accounting and insurance services;
• work-related administrative purposes;
• to finalise the terms of a contract, including pay rates;
• to confirm eligibility to work in Australia;
• to carry out a contract including, where relevant, its termination;
• to pay and provide other benefits in accordance with a contract;
• to make travel bookings on an individual’s behalf;
• to allow you access to the Company’s buildings, and to ensure the security of Company buildings, confidential information and other Company property;
• to reimburse expenses claimed;
• to operate any share scheme including the granting of share options;
• to operate schemes relating to sick leave, maternity leave, paternity leave, adoption leave, and parental leave;
• deducting and paying appropriate tax and superannuation contributions;
• to monitor and protect workplace health and safety;
• to provide a reference upon request from another employer;
• monitoring compliance with Company policies and The Company’s contractual obligations;
• to comply with all applicable law;
• to liaise with any insurers in respect of any insurance policies that relate to you;
• running the Company business and planning for the future;
• the prevention and detection of fraud or other criminal offences;
• to defend the Company in respect of any investigation or litigation and to comply with any court or tribunal orders for disclosure;
• otherwise as permitted or required by law; or
• otherwise with your consent.
USE OF YOUR PERSONAL INFORMATION ON THE COMPANY WEBSITE, FOR MARKETING PURPOSES ETC.
The Company may use your personal information (for example, your name, image, job title and work contact details) on its website or in other publicly available resources where this is necessary for legitimate business purposes.
The Company may also use this personal information for other marketing purposes, such as for displaying photos of staff on its website and in other marketing materials. In some circumstances it will be necessary to continue to use certain personal information (such as photos of you) on the Company website or in other marketing materials even after your employment has come to an end.
The Company will always only use such personal information in a reasonable manner, taking into account your position within the Company and the nature of your role. If you have any concerns about such use of your personal information, you should discuss this with your manager. The Company will consider any such points raised.
DISCLOSURE OF PERSONAL INFORMATION
The Company may disclose personal information to third parties including:
• other companies within the Company’s group;
• employees and contractors working for the Company, to the extent this is necessary for the operation of the Company’s business;
• technology service providers, including, internet service providers, cloud hosting service providers, software suppliers, maintenance and support service providers, and security services on a confidential basis so that they can provide services to the Company;
• service providers such as banks;
• external consultants such as legal, human resources, industrial relations, accounting, and insurance;
• travel agents and suppliers of accommodation and travel services;
• government agencies such as the ATO, Fair Work Ombudsman, WorkCover, etc;
• superannuation funds;
• to other third parties as authorised by law or with your consent.
PERSONAL INFORMATION OUTSIDE OF AUSTRALIA
If personal information is going to be sent outside of Australia insert details.
ACCURACY AND STORAGE OF PERSONAL INFORMATION
The Company will always endeavour to maintain an accurate record of all personal information it holds. Individuals should ensure that all personal information provided to the Company is accurate and up to date and notify the Company of any changes where required.
In addition, in order to ensure personal information is handled appropriately, individuals should:
• only access personal data if they need to do so for the proper performance of their role;
• not share personal data unless this is necessary for the proper performance of their role;
• keep personal data secure and protected;
• regularly review and update personal data as necessary;
• not make unnecessary copies of personal data and keep and dispose of any copies securely;
• consider using strong passwords and when protecting documents with personal data on them;
• lock unattended computer screens and devices;
• never leave computers, devices, electronic storage systems, files, paperwork or other things containing personal data in a manner that risks there unauthorised access or theft;
• where appropriate, ensure that highly sensitive personal data is encrypted before being transferred electronically to authorised external contacts. Where necessary, please speak to your manager or the IT department for more information on how to do this;
• consider anonymising data or using separate keys/codes so that the data subject cannot be identified;
• not save personal data to personal computers or other devices;
• not take personal data away from Company’s premises unless required to do so for the proper performance of your role;
• shred and/or securely dispose of personal data when finished with;
• ask for help from your manger if unsure about data protection, or if any areas of data protection or security can be improved; and
• immediately report any loss, unauthorised access, security risk or other issue that arises in respect of personal information to your manager.
ACCESS TO PERSONAL INFORMATION
Personal information held by the Company in respect of employees is subject to the “employee records exemption” under the Privacy Act and does not have to be disclosed on request.
Other persons, such as job applicants can request copies of their personal information by contacting us.
The Company may make reasonable charges for access to personal information and may refuse to provide access to, or delete, information where this is required or authorised by the Privacy Act or another law.
If personal information is incorrect, individuals may request that the Company amend its records and the Company will take reasonable steps to do so. Employees can do this by contacting their manager, other persons, such as job applicants should use the contact details referred to above.
RAISING A CONCERN OR A COMPLAINT
If you have any concerns about the use of your personal information (or of any other person’s personal information) you should discuss this with your manager. Other persons, such as job applicants should use the contact details on our website.
The Company will generally ask for your concern or complaint to be put in writing and it will endeavour to provide a reply within 21 days.