Privacy

ROWBEN CONSULTING PRIVACY POLICY

1.     Introduction

At Rowben Consulting your privacy is important to us. We are committed to ensuring that your privacy is respected and maintained at all times.  We only collect information that is reasonably necessary for the proper performance of our activities or functions.

We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APP). More information on privacy and the APP can be found at http://www.oaic.gov.au

This privacy policy explains how we collect personal information and how we maintain, use and disclose that information.

If you have any questions please contact us on +61 3 8320 7500 or privacy@rowben.com.au

2.     Information Flow

When we collect your personal information:

  • we check that it is reasonably necessary for our functions or activities as a recruitment agency
  • we check that is current, complete and accurate. This will sometimes mean that we have to cross check information that we collect from you with third parties;
  • we record and hold your information in our Database.
  • we retrieve your information when we need to use or disclose it for our functions. 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 assess your personal information in accordance with APP: 12 of the APPs http://www.oaic.gov.au/privacy/privacy-resources/privacy-fact-sheets/other/privacy-fact-sheet-17-australian-privacy-principles
  • we correct or attach associated statements to your personal information in accordance with APP:13 of the APPs.   http://www.oaic.gov.au/privacy/privacy-resources/privacy-fact-sheets/other/privacy-fact-sheet-17-australian-privacy-principles
  • 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.

3.     Kinds of information that we collect and hold

The type of personal information that we collect and hold is information that is reasonable necessary for the proper performance of our functions and activities as a recruitment agency and is likely to differ depending on whether you are:

  • a Candidate — someone that is looking for work through us; or whom we have identified as a person who might be interested in work through us;
  • a Client is someone  other than a Candidate who is looking to use our services as a recruitment agency or who we have identified as someone who might be interested in using our services;
  • a Referee is a person who we have sought facts or opinions regarding the suitability of one of our Candidates for work through us; and who may be a Referee nominated by the Candidate or Client or us.

3.1   For Candidate

The type of information that we typically collect and hold about Candidates 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:

  • information received from Candidates and other sources (e. g Clients or Referees) in relation to applications for work;
  • information about skills, qualifications, experience, character, personality;
  • information obtained from the Candidate regarding career history and career aspirations;
  • information about work entitlements and the ability to undertake specific types of work;
  • information regarding work performance;
  • information about incidents in the workplace;
  • information including email address, phone numbers, name and home address;
  • information submitted and obtained in relation to absences from work due to leave, illnesses or other causes.

3.2   For Client

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:

  • information about the Clients position, authority levels to engage our services;
  • information about the clients position, team structure, positions within the team, environment;
  • information about incidents in the workplace.

3.3   For Referee

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 or particular types of work and includes:

  • authority to give a reference and preferred contact details;
  • information about position and authority levels of the Referee in relation to the Candidate;
  • opinions of the Referee regarding the candidates performance in relation to their skills, environment and their character based on the Referees own knowledge and experience of having worked with the Candidate.
  1. 4.     Purposes

The purposes, for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:

  • a Candidate
  • a Client
  • a Referee

The following sections are also relevant to our use and disclosure of your personal information on Direct Marketing.

4.1   For Candidate

Information that we collect, hold, use and disclose about Candidates is typically used for:

  • work place options;
  • recruitment functions;
  • payment purposes;

4.2   For Client

Information that we collect, hold, use and disclose about Candidates is typically used for:

  • client and business relationship management;
  • recruitment functions;
  • marketing services to you;
  • statistical purposes and statutory compliance requirements;

4.3   For Referee

Information that we collect, hold, use and disclose about Candidates is typically used for:

  • to confirm and identity and authority to provide references;
  • Candidate suitability assessment;
  • recruitment functions;

4.4   Direct Marketing

We do not disclose any details of Candidates, Clients or Referees to any third party Marketing Providers.

  1. 5.     How your personal information is collected

This means by which we will generally collect your personal information are likely to differ depending on whether you are:

  • a Candidate
  • a Client
  • a Referee

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.

5.1   For Candidate

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;
  • Information is given to us about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were or are involved;
  • information is given to us as a result of inquiries we might make of your former employers, work colleagues, professional associations or registration body;
  • we receive results from any competency, psychometric, or medical tests;
  • we receive feedback on performance;
  • additional information about you is provided by you;

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.

5.2   For Client

Personal information about you may be collected:

  • when you provide it to use 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.

5.3   For Referees

Personal information about you may be collected when you provide it to us:

  • In the course of our checking Candidate references with you and when we are checking information that we obtain from you about Candidates;
  • 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.

5.4   Photos and Images

We will not request that you supply photographs, scan photo ID, or capture and retain video image date of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances.

At times video surveillance which operates in or near our premises may capture images of you.

5.5   Electronic Transactions

Sometimes, we collect personal information that individuals choose to give us via online forms collected through our website www.rowbenconsulting.com.au or by email, for example when individuals:

  • ask to be on a email list such as a job notification list;
  • register as a site user to access facilities on our site such as payroll information;
  • make a written online enquiry or email us through our website;
  • submit a resume by email or through our website

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

It is important to 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.

6.     How your personal information is held

Personal information is held in our Information Record System 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 to protect your personal information. Information can be accessed by our staff and disclosed in accordance with the APPs.

6.1.1    Our Information Record System

Rowben Consulting use the following to record personal information:

  • Database — A Cloud based database use to store and capture candidate and client information
  • Payroll — A Cloud based system used to manage the payroll to contractors, temporary and freelancers.
  • Storage — A Cloud based storage service which we use to store documentation.

All printed information that is no longer required is destroyed in a secured locked up waste bin. For all contractors, temps and freelancers a hard copy of their information is kept in a securely locked cabinet.

6.2   Information Security

We take a range of measures to protect your personal information from:

  • misuse, interference and loss, and
  • unauthorised access, modification or disclosure.

7.     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
  • to our Clients
  • to Referees for suitability and screen purposes

7.1   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 the CSPs would include:

  • Software solutions providers;
  • IT 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.

7.2   Cross Border Disclosures

Rowben Consulting does not disclose your personal information to overseas recipients unless it was necessary for a recruitment assignment. If this was the case, the Candidate permissions would be required.

We cannot guarantee that any recipient of your personal information would protect it to the standard to which t 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.    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:

  • evaluate 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.

8.1   Access

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 identify.

We will endeavour to provide you access within 24-hours. If we are unable to give you access as you have requested, we will provide written documentation outlining:

  • The reason for the refusal and the mechanism available to complain about the refusal.

8.2   Correction

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 read 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 who 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.

We will endeavour to respond to your request within 24-hours.

In some cases we may not agree that the information should be changed. In this case, we will provide to you written documentation outlining:

  • The reason for the refusal and the mechanism available to complain about the refusal.

8.3   Complaints

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

8.4   Complaints Procedures

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 us in writing to: privacy@rowben.com.au or Attention: Privacy Officer — Level 6, 400 — 402 Collins Street, Melbourne VIC 3000

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

Complaints can also be made to ITCRA, the industry association of which we are a member (this membership is for those involved within the Information Technology industry) or complaints can also be made to RCSA, the industry association we are also a member.

Both ITCRA and RCSA administer a Code of Conduct for the professional and ethical conduction of its 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 complain 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 details;
  • We will consider the complaint and may make inquiries of people who can assist us to establish 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 suggestion that solution t o 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 www.oaic.gov.au