Sirius People, ACN: 141 440 208
● The kind of information Sirius People may collect about you, how we collect it, and how we use it
● How we may disclose that information
● How you can access the information we hold about you
● When we may use your information to contact you
● The protection of your personal information
To meet your expectations about privacy and confidentiality Sirius People has procedures that comply with the:
● Australian Privacy Principles (APPs) contained in the Privacy Amendment (Enhancing Privacy Protection) ACT 2012
● Australian Direct Marketing Association (ADMA) Code of Practice
● Spam Act 2003
● Do Not Call Register Act 2006
If you have any questions not addressed in this policy, please feel free to contact us using the methods at the bottom of this policy under the heading "How to Contact Us".
2. Collection and Use of Personal Information
'Personal information' means information we hold about you from which your identity is either clear or can be reasonably determined. When you give us your personal information, it imposes a serious responsibility on us. Protecting your privacy when handling your personal information is very important to us and is fundamental to the way we interact with you.
Types of Personal Information Held
Personal information that we collect and hold usually falls into the following categories:
● Candidate: If you are a candidate seeking employment with Sirius People, the company may collect and hold information including your name, address, email address, contact telephone number, gender, age, employment history, references, resume, medical history, emergency contact, taxation details, qualifications and payment details. If the candidate is employed through Sirius People as a contractor or a temporary worker, the company may also hold information relating to work performance, information about incidents in the workplace, staff information, and information submitted and obtained in relation to absences from work due to leave, illness or other causes.
● Customer: If you are a customer of Sirius People, the company may collect and hold information including your name, address, email address, contact telephone number, gender and age, business requirements, organisational structure, billing information about services supplied to you.
● Supplier: If you are a supplier of Sirius People, the company may collect and hold information including your name, address, email address, contact telephone number, business records, billing information, information about goods and services supplied by you.
● Referee: if you are a referee of a candidate being considered for employment by Sirius People, the company may collect and hold information including your name, contact details, current employment information and professional opinion of candidate.
Sirius People will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Sirius People’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.
Unsolicited personal information is personal information that Sirius People receives which it did not solicit. Unless the company determines that it could have collected the personal information in line with the APPs or the information is contained within a Commonwealth record, the company destroy the information to ensure it is de-identified.
How your Personal Information will be Collected
Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work. Personal information is also collected when:
● We receive or give any reference about you
● We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
● We receive the results of any competency or medical test
● We receive performance feedback (whether positive or negative)
● We receive any complaint from or about you in the workplace
● We receive any information about a workplace accident in which you are involved
● We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved
● You provide us with any additional information about yourself
● Electronically through our telecommunications and technology systems – see the section in this policy on electronic transactions
Purposes for which we hold Personal Information
Sirius People will collect personal information if it is reasonably necessary for one or more of its functions or activities. The main purposes for which the company may collect, hold, use and/or disclose personal information may include but are not limited to:
● Recruitment functions
● Customer service management
● Training and events
● Surveys and general research
● Business relationship management
● Risk management and statutory compliance requirements
● Marketing services to you; but only where this is permitted and you are registered with us
3. Disclosure of Personal Information
Disclosure of Receipt of Personal Information
At or before the time or, if it is not reasonably practicable, as soon as practicable after, Sirius People collects personal information, the company must take such steps as are reasonable in the circumstances to either notify you or otherwise ensure that you are made aware of the following:
● The identity and contact details of Sirius People
● That Sirius People has collected personal information from someone other than you or if you are unaware that such information has been collected
● That collection of personal information is required by Australian law, if it is the purpose for which Sirius People collects the personal information
● The consequences if Sirius People does not collect some or all of the personal information
● Any other third party to which Sirius People may disclose the personal information
● Whether Sirius People is likely to disclose personal information to overseas recipients, and the countries in which those recipients are likely to be located
Disclosure of Personal Information
We may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted. We may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a contractual or lawful duty of care to disclose information. We do not share personal information about you with government agencies, organisations or anyone else unless one of the following applies:
● You have consented
● You would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies
● It is required or authorised by law
● It will prevent or lessen a serious and imminent threat to somebody's life or health
● The disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue
4. Third Party Suppliers
Outsourced Service Suppliers
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:
● IT contractors and database designers and service internet service suppliers, some of whom may be off shore
● Legal and other professional advisors
● Insurance brokers, loss assessors and underwriters
● Superannuation fund managers
● Background checking and screening agents
● Payroll agencies for the purpose of making payment to you
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
5. Direct Marketing
From time to time we may use the personal information we collect from you to identify particular services which we believe may be of interest to you. We will generally only do this with your prior consent (where practical) and we will always give you a choice to opt out of receiving such information in future.
Direct Marketing from Sirius People generally takes the form of electronic marketing (email) or via the telephone. Personal information may be used to contact you for the purpose of providing recruitment services, either directly or by a third party. Where we use your personal information to send you marketing information by e-mail, SMS, MMS or other electronic means we may do so with your express or implied consent. You may give us your express consent by, for example, ticking a box on an electronic or paper form where we seek your permission to send you electronic or other marketing information. Consent may be implied from our existing business relationship or where you have a reasonable expectation of receiving an electronic marketing communication.
Sirius People may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new services being offered by the company). Sirius People may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. You can opt out of receiving direct marketing communications from the company by contacting the Privacy Officer in writing or if permissible accessing the company’s website and unsubscribing appropriately.
6. Accessing your Personal Information
Access to your Personal Information
You have the right to request access to the personal information we hold about you. Sirius People will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type (or types) of information requested.
Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information, including but not limited to such as circumstances where:
● Access would pose a serious threat to the life or health of any individual
● Access would have an unreasonable impact on the privacy of others
● Access would breach any confidentiality attached to that information
● The information relates to a commercially-sensitive decision-making process
● The information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings
● Giving access would be unlawful
If you wish to obtain access to your personal information you should contact our Privacy Officer. You will need to be in a position to verify your identity. You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within 20 working days.
7. Updating and Correcting your Personal Information
Personal Information Quality
We rely on you to tell us when there are changes to your personal information that we hold about you. This could be e.g. a change of address or employment status.
Correction of Personal Information
If Sirius People holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, the company will take steps as are reasonable to correct the information. If Sirius People holds personal information and you make a request in writing addressed to the Privacy Officer to correct the information, Sirius People will take steps as are reasonable to correct the information and the company will respond to any request within a reasonable period.
There are certain circumstances in which Sirius People may refuse to correct the personal information. In such situations the company will give you written notice that sets out:
● The reasons for the refusal; and
● The mechanisms available to you to make a complaint
If Sirius People corrects personal information that it has previously supplied to a third party and you request us to notify the third party of the correction, the company will take such steps as are reasonable to give that notification unless impracticable or unlawful to do so.
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.
8. Information Security
Personal Information Security
We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed. However it is not always practicable to destroy or de-identify electronic data. Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent unauthorised or inadvertent access, modification or dissemination.
Photos and Images
We will only request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where we require proof of identity and workers’ rights for our records.
9. Website Security
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. 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
Please contact our office by phone or mail if you have concerns about making contact via the internet.
When an individual looks at our website, our internet service provider makes a record of the visit and logs (in server logs) the following information for statistical purposes:
● The individual’s server address
● The individual’s top level domain name (for example .com, .gov, .org, .au, etc)
● The pages the individual accessed and documents downloaded
● The previous site the individual visited
● The type of browser being used.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Most browsers accept cookies by default. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
Social Networks and Web Searches
In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. It has become common practice in some places for employment service providers to conduct background checking via social network media sites frequented by candidates.
We will not conduct background checking via social network media sites other than those that you identify and authorise us to check. However we do conduct internet searches using search engines and entering your name and relevant identifying details, and will view and assess any public information you have provided on those sites.
Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws, and you may be responsible for any legal consequences.
Our technology systems log emails received and sent and may include voting, and read and receipt notifications to enable tracking. When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.
Call and Message Logs
Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display. When your call number is received by us because you phone us or send us a message, the number will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.
Teleconferences and Video conferences
Teleconferences and video conferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.
We use recruiting software and databases to log and record recruitment operations.
10. Children’s Privacy
Children, Minors and Persons under a Legal Disability
Determining the decision-making capabilities of a person who is under a legal disability can be a complex matter, often raising ethical and legal issues. We endeavour to address each case individually with a view to deciding whether the individual is able to give consent or receive notifications based upon an assessment of whether the individual has sufficient understanding to comprehend the nature and quality of what is being proposed. In some circumstances, it may be appropriate for a parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom to be contacted in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly from the individual.
11. Making a Complaint
How to Make a Complaint
You have a right to complain about Sirius People’s handling of your personal information if you believe the company has breached the APPs. If you wish to make such a complaint to Sirius People, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with the company’s complaints procedure and the company will provide a response within a reasonable period.
If Sirius People takes more than 30 days to respond to your privacy complaint, or if you are dissatisfied with the outcome, you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner. The OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au
12. How to Contact Us
02 9270 5200
Sirius People, Privacy Officer
Level 4, 50 Margaret St, Sydney, NSW, 2000
13. Updates to this Policy
This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.