Curran & Associates

1.Introduction

 

We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This condensed policy applies to information collected by Curran + Associates Pty Ltd.

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.

If you have any questions please contact us

 

1.1 APP Entity

 

APP EntityCurran + Associates Pty Ltd manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

Institutions where we are a contracted service provider to a range of Commonwealth, State and Territory government agencies, it may sometimes become 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.

 

1.2 Information Flow

 

When we collect your personal information:

 

• we check that it is reasonably necessary for our functions or activities as an employment agency 

• 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 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.

 

2. 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 recruitment functions and activities as a and is likely to differ depending on whether you are

 

• a Workseeker

• a Client

• a Referee

 

2.1. 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:

• Remuneration information

• Reference checks

• Letters of recommendation

• Copy of your employment offer letter

• Copy of your employment contract

 

2.2. 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:

• Job briefs

• Position descriptions

• Employment contracts

• Employment offer letters

 

 

2.3. 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:

 

3. 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

 

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

• Our Policy on Direct Marketing

• Overseas Disclosures

 

3.1. 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;

 

3.2. 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;

 

3.3. 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;

 

4. 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.

 

4.1. For Workseekers

 

Personal information will be collected from you directly when you submit any information in connection with your application to us for work.

 

Personal information is also collected when:

• Reference checks and other checks requested by our client are undertaken.

 

This is done with your prior approval.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.

 

4.2. For Clients

 

Personal information about you may be collected:

 

• when you provide it to us for business or business related social purposes;

 

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. 

 

4.3. 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;

 

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.

 

4.4. Photos and 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.

 

4.5. 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 job notification list;

• 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;

 

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

 

5. How your personal information is held

 

Personal information is held in our Information Record System We take measures to protect your personal information from:· misuse, interference and loss; and· unauthorised access, modification or disclosure.

 

5.1. Our record information system

 

Our information record management system is a cloud based system where information is stored in electronic format.· It is presently not stored on portable electronic devices.

 

5.2. Information Security

 

Information SecurityInformation security is managed via the following:

• Staff training

• Need-to-know and authorisation policies

• Just-in-time collection policies

• Password protection for company computers

• Communication with staff regarding the safe storage of portable devices

• Culling or shredding of hard copy information

 

6. 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.

 

6.1. 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.

 

6.2. Cross Border Disclosures

 

Some of your personal information is likely to be disclosed 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.

 

The likely countries, type of information disclosed and recipients are indicated, so far as is practicable:

Country - Philippines

Type of Information - All personal data stored on servers located in Australia or our cloud based recruitment database

Likely recipients - Our clients and work colleagues, IT Personnel and Contractors of our technology providers who may access data for maintenance and software upgrade purposes

 

7. Access and 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.

 

7.1. Access Policy

 

If you wish to obtain access to your personal information you should contact our office at Level 6, 46 Market Street, Sydney. You will need to be in a position to verify your identity.

 

At the time of contact we can advise:

• Any lawful costs or charges that may be incurred

• Timeframes for your response to access requests

• A response on the grounds of refusing access

 

7.2. 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.

 

 

Complaints

 

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

 

7.3. Complaint 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 office at Level 6, 46 Market Street, Sydney.

 

You can also make complaints to the Office of the Australian Information Commissioner.

 

Complaints may also be made to 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.

 

NOTE: The Association 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 the Associations members.

 

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