We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This policy applies to information collected by Quinn Allan Executive Pty Ltd.
We only collect information that is reasonably necessary for the proper performance of our activities or functions.
We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.
By reading this document, you will be able to find out how we manage your personal information as an APP Entity (refer to 1.1) under the Australian Privacy Principles (APPs). You will also be able to find out about the information flows (refer to 1.2) associated with that information.
If you have any questions please contact us on 03 8373 3400 or email email@example.com
1.1. APP Entity
Because 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 on 03 8373 3400 or email firstname.lastname@example.org
1.2. Information Flow
When we collect your personal information:
- We check that it is reasonably necessary for our functions or activities as a talent services and recruitment 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 Customer Record Management Systems (refer to 5.1);
- We retrieve your information when we need to use or disclose it for our functions and activities (refer to 3.0). 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 (refer to 7.0) to your personal information in accordance with APP:12 of the (APPs);
- We correct or attach associated statements to (refer to 7.0) 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 (refer to 3.0) 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 functions and activities as a Talent Services and Recruiment Firm and is likely to differ depending on whether you are:
- Candidate (refer to 2.1)
- Client (refer to 2.2)
- Referee (refer to 2.3)
2.1. For Candidates
The type of information that we typically collect and hold about a Candidate is information that is necessary to assess amenability to work offers and work availability; suitability for placements; identify training needs; education needs, to consult on career transition and management; or to manage the performance in work obtained through us.
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.
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 candidates for particular jobs; particular types of work and training requirements.
The purposes, for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:
- Candidate (refer to 3.1)
- Client (refer to 3.2)
- Referee (refer to 3.3)
The following sections are also relevant to our use and disclosure of your personal information:
- Our Policy on Direct Marketing (refer to 3.4)
- Cross – Boarder Disclosures (refer to 6.2)
3.1. For Candidates
Information that we collect, hold, use and disclose about candidates is typically used for:
- work placement operations;
- recruitment functions;
- training and development;
- skills and psychological assessments;
- career transition and managment consulting/coaching;
- work performance;
- marketing srvices to you;
- workplace incidents;
- 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;
- workplace assessments and incidents;
- consulting services;
- 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;
- candidate suitability assessment;
- recruitment functions;
- marketing services to you
3.4. Direct Marketing Policy
For the purposes of direct marketing business development and promoting our services directly or via a third party we may use candidate information:
- for social networking related to jobseeking and career management activities or;
- for the distribution of relevant news and services updates
Client and Referee information may be used for
- the purposes of marketing, promoting, networking and;
- the distribution of industry news
Quinn Allan ensures compliance with all anti-spaming legislation and individuals are given the option to withdraw from receivieng any marketing communications at any time.
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:
- Candidate (refer to 4.1)
- Client (refer to 4.2)
- Referee (refer to 4.3)
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 – see the section in this policy on Electronic Transactions (refer to 4.5).
See also the section on Photos & Images (refer to 4.4).
4.1. For Candidates
Personal information will be collected from you directly when you fill out and submit any of our application, consent or any other information forms in connection with your application to us for work or career management guidance.
Personal information is also collected when:
- you provide us with a resume or additional information at interview;
- you connect with us on social media platforms;
- a referee provides a reference about you;
- results of any psychometric, competency or medical testing are obtained;
- we receive performance feedback;
- a workplace complaint is lodged about you;
- legal documentation (for example, proof of entitlement to work in Australia) is provided;
- web browsing history;
- uploading photographs and video interviewing;
- telephone call and email message logs.
4.2. For Clients
Personal information about you may be collected:
- when you provide it to us for business or business related social purposes;
4.3. For Referees
Personal information about you may be collected when you provide it to us:
- in the course of our checking candidate and/or applicant references with you and when we are checking information that we obtain from you about them;
4.4. Photos & 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.
Some of our workplace locations have survelliance technologies installed and operated by third parties where the purpose of the deployment of the technology is to provide security for staff and visitors.
4.5. Electronic Transactions
Sometimes, we collect personal information that individuals choose to give us via social media sites, online forms or by email, for example when individuals:
- ask to be on an email list such as a job notification list;
- join our groups on LinkedIn, like us Facebook or follow us on twitter;
- 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
The information provided by electronic transactions is recorded in our customer management systems and used for the purposes it was intended.
Aggregate Information About Website Visitors
We gather information and statistics about all visitors to this website, including the most frequently accessed pages and most frequently used services. We only use such data in aggregate form (that is, the information does not identify any one individual). This information helps us determine the most beneficial parts of our websites and ways in which we can continually improve our online services to create a better overall experience for our users. We may also publish some of this aggregate (non-identifiable) information on the Quinn Allan 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 landline 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 Customer Record Management (CRM) Systems (refer to 5.1) 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.
We take a range of measures (refer to 5.2) to protect your personal information from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
5.1. Our Customer Record Management (CRM) Systems
Quinn Allan may store your information in both hard and electronic format. Our customer record management systems are cloud-based technology that may be accessed via portable devices such as mobile phones, laptops and tablets. Hard copy information may be held in diaries and manual files operated and held by our staff.
5.2 .Information Security
To protect personal information held by our CRM Systems Quinn Allan has the following policies that all staff are trained on:
- Password Protection
- Portable Device Locking and Storage
- Hard Copy Format Storage
In addition all staff are bound by a confidentiality and non-disclosure agreement and access is provided to only those that require it.
Any hard copy format of information that is no longer reasonably necessary for the performance of our functions or activities is disposed of via a securely locked destuction bin and destroyed by an accredited, AAA NAID certified information destruction company that has a complete closed loop service, with security cleared personnel, GPS tracked fully enclosed transport and total destruction at their restricted facility.
We may disclose your personal information for any of the purposes (refer to 3.0) for which it is primarily held or for a lawful related purpose (refer to 6.1 and 6.2 for Cross Border Disclosure)
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;
- T. contractors and database designers and Internet service suppliers;
- Payroll and contractor services suppliers
- Legal and other professional advisors;
- Insurance brokers, loss assessors and underwriters;
- Superannuation fund managers;
- Background checking and screening agents;
- Education and training institutions;
- Professional associations or registration body’s
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
It is not likely your personal information will be to be disclosed to overseas recipients. However if it is via Quinn Allan or one of our third party suppliers 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.
7. Access, Correction and Complaints
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.
For more information about access to your information see our Access Policy (refer to 7.1)
For more information about applying to correct your information see our Correction Policy (refer to 7.2)
For more information about complaints see our Complaints Policy (refer to 7.3)
7.1. Access Policy
If you wish to obtain access to your personal information you should contact our General Manager. You will need to be in a position to verify your identity and provide your request in writing. We may impose a reasonable administration charge to provide access. Our General Manager will discuss any charges with you. You should also anticipate that it might take some time to process your request, as we may need to retrieve information from offsite storage and third parties. We may refuse access if it would interfere with the privacy rights of their persons or if it breaches any confidentiality applicable to that information.
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 Quinn Allan in writing.
Quinn Allan will endeavour to take reasonable steps in the circumstances to correct that information or attach a correction statement 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.
7.3. Complaints Policy
You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.
If you are making a complaint about our handling of your personal information, it should first be made to Quinn Allan in writing.
You can make complaints about our handling of your personal information to our Managing Director whose contact details are email@example.com or PO Box 16157 Collins Street West, Melbourne, 8007.
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 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;
- We will endeavour to resolve the complaint by procedures for access and correction or some other solution we will suggest on a confidential and without prejudice basis in our response