PURPOSE STATEMENT AND INTRODUCTION
The purpose of this policy is to communicate Impact HR Group’s (Impact) commitment to the Australian Privacy Principles (APP) and how the organisation will comply with these regulations, in relation to organisational, individual and client privacy rights.
We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles.
POLICY STATEMENT
This policy relates to Impact employees, candidates, clients and contractors.
We 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 may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.
CANDIDATES:
The type of information that we typically collect and hold about assignees and or potential candidates is information that is necessary to assess suitability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us.
If you are an employee (assignee), or potential candidate of Impact, you may be required to provide the following information which Impact will use to confirm your suitability for employment:
a) Information submitted or obtained from candidates, and other sources in connection with applications for work
b) Information relating to the personal background of workplace participants such as home address, date of birth, sex, languages spoken, nationality, employment history, contact details, details of emergency contacts, qualifications and licences, education, and literacy and numeracy ability
c) Work performance details (including written warnings or disciplinary action), reference check information, and information about incidents or injuries that have occurred in the workplace or outside the workplace, should it be appropriate
d) Employee information, such as tax file number, letter of appointment, superannuation details, bank account details and records of pay and any pay adjustments
e) Information submitted and obtained in relation to absences from work due to personal leave, illness, injury, compassionate or bereavement leave or other reasons
f) Information gathered to assist in managing client and business relationships
g) Information for government organisations and legal representatives (e.g. Family Assistance Office, Department of Human Services, Medicare, lawyers with subpoenas etc.) including but not limited to Garnishee orders and child support deductions
h) Documentary proof of a candidate’s ability to work in Australia and or citizenship evidence
CLIENTS AND CONTRACTORS:
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
Impact may request the following information, or obtain the following details for a client or contractor who wishes to do business with Impact:
a) Financial information/credit history and banking details
b) Company information such as ABN and address
c) Relevant contact details and personnel names (phone numbers and email addresses)
d) Position descriptions, policies and procedures relevant to the work our candidates may be undertaking
The information collected may be either in electronic or paper-based form.
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 assignees or potential candidates for jobs or types of work and includes:
a) Information submitted or obtained from candidates, and other sources in connection with applications for work
b) Work performance details (including written warnings or disciplinary action), reference check information, and information about incidents or injuries that have occurred in the workplace or outside the workplace, should it be appropriate
COLLECTING PERSONAL INFORMATION
When we collect your personal information:
a) We check that it is reasonably necessary for our functions or activities
b) We check that it is current, complete and accurate. This will sometimes mean that we must cross check the information that we collect from you with third parties;
c) We record and hold your information in our Information Record System (FastTrack)
d) 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 must cross check the information that we collect from you with third parties once again - especially if some time has passed since we last checked.
e) Subject to some exceptions, we permit you to access your personal information in accordance with APP
f) We correct or attach associated statements to your personal information in accordance with APP
g) 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 if it is lawful for us to do so.
HOLDING PERSONAL INFORMATION
We may collect and hold information to assist with assignee placements, employee performance management, training purposes, client and business management, insurance reasons, work health and safety requirements, recruitment, marketing purposes, Government agency requirements and client database management. Only authorised consultants, management personnel and payroll/finance representatives will have access to this information. All personal information will be stored securely.
Personal information is held in our Information Record System (FastTrack) 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 if it is lawful for us to do so.
We take a range of measures to protect your personal information from:
a) misuse, interference and loss; and
b) unauthorised access, modification or disclosure.
DISCLOSURE
Impact may disclose relevant elements of candidate’s personal information to organisations (clients) whom the candidate may be placed with (only relevant information would be disclosed). Information is not disclosed to other parties except for the purposes it was collected for, unless required by law or with your consent. Information held may be disclosed to third parties as a requirement of normal business operation (such as to IT provider or external advisors).
There may be requirements to disclose your information to external parties if we have a legal duty to do so, for example, to Centrelink. If you have a concern about information that has been disclosed and you feel there has been a breach of privacy, please contact the Impact Privacy Officer.
ACCESS
You may request access to information which we hold about you (subject to some exceptions contained in the Australian Privacy Principles). If your request would breach another person’s privacy rights or confidentiality, your request will be refused.Employment records fall outside the disclosure requirements of the Privacy Act. If you had previously been employed by Impact, we will generally provide you with access to information that you have provided to us. Information obtained from third parties or produced by us would be excluded from disclosure.
If you would like to have access to your personal information, you must contact the Privacy Officer. You will need to identify yourself appropriately and the Privacy Officer will assess your request, let you know if it is approved, and if so, a small cost may be associated with the accessing of your required information (handling cost). Any costs associated with your request would be advised at the time your request is granted (or declined).
Some requests for access to information, once approved, may take some time. The Privacy Officer will advise you of an approximate timeframe for any information disclosure.
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold.
Important exceptions include:
a) 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.
For more information about access to your information please contact the Privacy Officer of Impact.
UPDATING INFORMATION
It is important that both client and employee information is always kept up to date. Employees/Assignees/Candidates must contact Impact to update any changes to personal details at their earliest convenience. Impact will request any updates to be in writing.
Client/contractor information may be updated by the client or contractor contacting Impact directly, or Impact may seek information on the update independently in order to maintain accurate details.
CORRECTIONS
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.
PRIVACY OFFICER
The Branch Manager is the nominated Privacy Officer. You must contact this person if you have any enquiries or requests associated with this policy. Please call Impact on 1300 004 672, or email support@impacthrg.com.au with your enquiry.
Impact is committed to the privacy of its employees, clients, contractors and other associated parties, and will aim to ensure relevant privacy laws are always upheld, by the implementation of this policy, and training of authorised staff in relation to their requirements under this policy.
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 Officer, whose contact details are Letizia Stanco, 1300 004 672 or support@impacthrg.com.au.
You can also make complaints to the Office of the Australian Information Commissioner.
Complaints may also be made to Recruitment & Consulting Services Association Limited – (RCSA), the industry association of which we are a member.
RCSA administers a Code of Conduct for the professional and ethical conduct of its members. The RCSA Code is supported by rules for the resolution of disputes involving members.
When we receive your complaint:
a) 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;
b) Upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy.
c) We may ask for clarification of certain aspects of the complaint and for further detail;
d) We will consider the complaint and may make inquiries of people who can assist us to established what has happened and why;
e) We will require a reasonable time (usually 30 days) to respond;
f) If the complaint can be resolved by procedures for access and correction, we will suggest these to you as possible solutions;
g) 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.