2. What is Personal Information?
2.1 ) Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable (Personal Information). In general terms, it is any information that can be used to personally identify you (for example your name, address, telephone number, email address and profession or occupation), but information can also include your internet protocol address, unique device identifiers, voice print and facial recognition biometrics or location information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.
3. Personal Information we collect
3.1 ) The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Suremploy will only collect Personal Information about you by lawful and fair means and not in an unreasonably intrusive manner. Personal Information that we collect may include (but is not limited to) your name and contact details (telephone and email), your age or age band, date of birth, gender and ethnic background, your address and country of residence, details about your employment history including current occupation such as job title, company and industry and any previous work experience, health information relevant to your medical care, including but not limited to your previous and current medical history and your family medical history and information provided on your behalf with your consent or from your employer or prospective employer.
4. How and when we collect Personal Information
4.1 ) We collect your Personal Information to allow us to provide the best quality of service to you and to conduct our business for the purposes set out in paragraph 6. In general, Suremploy collects Personal Information:
- to provide physical and mental health assessments of Candidates (including pre, post and during employment) for employers or prospective employers (Services);
- to interpret results and provide candidate reports and advice to employers or prospective employers, their authorised representatives and their insurer (if relevant);
- to answer enquiries and provide information or advice about existing and new Services;
- to manage our relationship with you including to contact you for follow up purposes, respond to your queries via telephone, online or by post, and send you correspondence in relation to Services;
- to review, develop and improve our Services and undertake quality improvements and assurance exercises, including research;
- to customise Services and provide educational resources for employers or prospective employers;
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country;
- when you contact us by telephone, fax, email, social media, post or in person to request information about us or our services, to provide feedback to us or to verify and update Personal Information held by us;
- for administrative and billing purposes; and
- where we are otherwise required or authorised by Privacy Act Laws to do so or for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
4.2 ) If you are a Candidate, collection of Personal Information may occur when you register for or use an account on our Website, at the time an employer or prospective employer contacts Suremploy to refer you to us, by you completing one of our registration, online questionnaires or consent forms, on first contact with a Suremploy staff member providing Services, during and after consultations have been provided and to process and respond to any complaint made by you.
4.3 ) If you are an employer or prospective employer, Suremploy typically collects your personal information directly from you.
4.4 ) Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
4.5 ) If we receive unsolicited Personal Information and this information is not relevant to us providing a service to you, we will destroy or de-identify the information.
5. What if Personal Information is not provided?
5.2 ) Due to the nature of our Services it is not possible to deal with Suremploy anonymously because the Services, candidate reports and advice Suremploy provides, may be seriously and negatively affected or it may result in mismatching of Candidates’ information and results or it may negatively impact on communication between Suremploy, the employer or prospective employer and Candidates.
6. How do we use your Personal Information?
6.1 ) We use the Personal Information we collect about you in order to operate our business and to market our Services for the benefit of our customers. We may use your personal information:
- to identify and communicate with customers to enable us to provide the requested Services or information and support;
- to invoice, collect and process payments from customers or to carry out credit checks and credit reporting or debt recovery functions;
- to personalise and customise your experiences on our Website and to manage and administer any account you may hold with us for the provision of Services;
- to provide customers with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us and our business partners (subject to your prior approval if required by Privacy Act Laws);
- to conduct research for the purposes of developing insights, improving our Services or creating new services or academic pursuits;
- to respond to any queries or complaints you may have and to comply with our statutory and legal obligations.
6.2 ) We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.
7. How does Suremploy hold personal information?
7.1 ) Suremploy will hold your Personal Information securely in accordance with the requirements under the Privacy Act Laws. Personal information may be held in hard copy onsite or in secure storage facilities, electronically in a secure format and environment.
7.2 ) To the extent required by the Privacy Act Laws, Suremploy takes reasonable measures to ensure that your Personal Information is protected from misuse, interference, loss and from unauthorised access, modification and disclosure. This includes having appropriate policies, procedures and training in place for staff and implementing security procedures for business premises and IT.
7.3 ) Unless Suremploy is required to retain your Personal Information in accordance with legislative and regulatory requirements, Suremploy will take reasonable steps to destroy and/or de-identify your Personal Information in secure manner once it is no longer necessary to hold the information for the provision of services to you.
8. When do we disclose your Personal Information?
8.1 ) We may disclose your Personal Information for the purposes described in paragraph 6, including to:
- our related entities, our staff members and/or health professionals who provide Services to you;
- contractors or service providers for the purposes of operation of our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
- your employer or prospective employer, their authorised representatives and their insurer (if relevant) or any organisation or person for any authorised purpose with your express consent;
- third parties where there is a serious threat to life, health and/or safety;
- government, regulatory authorities and other organisations as required or authorised by Privacy Act Laws.
8.2 ) We may combine or share any information that we collect from you with information collected by any of our related entitie
9. International disclosures
9.1 ) Some of your Personal Information may be accessed, disclosed, transferred, stored, processed or used outside of Australia or your country of residence by us, or by third party service providers if our offices or related entities are located in those countries, if we outsource certain activities to those countries, if you request a service offered through the Website which is provided by a company which is located in such a country, if transactions, information, services or products have an international connection and/or if our computer systems including servers are located in those countries.
10. Other uses and disclosures
11. Information collected via our Website
11.1 ) Personal information may be collected by us and by our third-party service providers who assist us in operating our website at www.suremploy.com.au, including its subdomains, the password protected portal ‘Suremploy Connect’ and any other website we operate from time to time (collectively the Website).
11.2 ) We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the following Google analytics, click stream data and cookies.
12. Direct Marketing
12.1 ) You consent to us using your Personal Information to send you information, including promotional material, about us or our services, as well as the services of our related entities and third parties, now and in the future.
12.2 )We may also send you, from time to time, such information by means of direct mail, telemarketing, email, SMS and MMS messages in accordance with all applicable marketing laws, such as the Spam Act 2003 (Cth).
12.3 ) If you do not want to receive marketing information from us or if you want to stop receiving telemarketing, you can unsubscribe by clicking on the ‘Unsubscribe’ or subscription preferences link in a direct marketing email that you have received from us, editing your communication preferences via our Website, or contacting us using the contact details specified in paragraph 16.
13. Storage and security of Personal Information
13.1 ) We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.
13.2 ) If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.
14. Accessing your Personal Information
14.1 ) You are entitled to access Personal Information that we hold about you, subject to some limited exceptions permitted by law. If you request access to your Personal Information, in ordinary circumstances we will give you access.
14.2 ) Depending on the nature of the request, Suremploy may charge for providing access to this information, however such charge will be nominal. However, we may refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal.
14.3 ) If you are a registered user, you can access and correct some of your Personal Information through the Website by logging into your account and updating or editing your profile at any time. In all other cases, a request for access can be made by contacting our Privacy Officer in any of the ways specified in paragraph 16.
14.4 ) We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
14.5 ) Please contact us in any of the ways specified in paragraph 16 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.
15. Access to Suremploy Connect
15.1 ) On its Website Suremploy uses a secure web-based password protected web portal ‘Suremploy Connect’ to allow customers to nominate Candidates and to access reports prepared on each Candidate by Suremploy as part of its Services. Candidates do not have access to Candidate Reports.
15.2 ) Customers are able to access this web-based portal with a unique provider number, subject to agreeing to comply with terms and conditions relating to access, privacy and confidentiality.
15.3 ) Our systems track, record and store all access activities on every referred candidate file. Suremploy monitors the use of this service and takes all reasonable steps to ensure that the system is being used appropriately for its intended purpose.
16. Contact us
16.2 ) We treat all complaints about how we handle your Personal Information seriously and will investigate your privacy complaints within a reasonable period of time depending on the complexity of the complaint.
16.3 ) We will notify you of the outcome of our investigation. If you are unhappy with our response, you can contact the Office of the Australian Information Commissioner (i.e. the Privacy Commissioner) on telephone number: 1300 363 992, or through the website at www.privacy.gov.au/complaints.