EXECOM PERSONNEL PRIVACY POLICY 

Execom Personnel Privacy Policy 

 

1.  Introduction

 

Execom Personnel manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This policy applies to information collected by Execom Personnel Group.

 

Only information that is reasonably necessary for the proper performance of our activities or functions is obtained and stored.

 

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. See Dealing with unsolicited information.

 

By following the links in this document, you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs).

 

The Australian Privacy Principles[1][1] and Guidelines[2][2]suggest that there has been a significant shift in the way in which you would use your Privacy Policy.  Under the old National Privacy Principles (which will cease at midnight on 11 March 2014), a privacy policy was something of a background document.  That is to say, you were only required to provide your privacy policy if a request was made for it.  Under the Australian Privacy Principles, which commenced on 12 March 2014 you must make your privacy policy freely and publicly accessible at all times. 

 

1.1  APP Entity

Execom Personnel manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

 

As we are a national service provider, it may become necessary for us to collect and manage personal information as an Agency under different privacy arrangements.  

 

1.2  Information Flow

 

When we collect your personal information:

  • We check that it is reasonably necessary for our functions or activities as a human resource consultancy, specialising in the engineering industry.

  • 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 internal Information Record System.  Some information may be disclosed to overseas recipients (see 6.2 Cross-Border Disclosures for further clarification on this point).

  • 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 correct or attach amendments 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 required 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.  Information Stored

        

Execom Personnel only obtain and store information that is reasonably necessary for the proper performance of our functions and activities as a human resource consultancy. It may differ depending on whether you are:

  • a Work seeker;

  • a Client;

  • a Referee.

 

2.1  For Work seekers

        

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

  • Resume

  • Copy of qualifications / licences / tickets etc.

  • See our website for our Candidate Collection Notification Statement which goes into further detail on this.

 

2.2    For Clients

 

Execom Personnel typically collect and store information about clients that is necessary to help us manage the presentation and delivery of our services and includes:

  • Safety Management Plan

  • WHS Policies / procedures

  • Credit information / credit history

  • Accounts receivable contact details

 

2.3  For Referees

        

We typically collect and hold information about Referees that is necessary to help to make determinations about the suitability of one of our Work seekers for particular jobs or particular types of work and includes:

  • Contact details

  • References provided

 

3.  Purposes

        

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

  • a Work seeker, (please also see our Candidate Collection Notification Statement which can be viewed on our website at http://www.execom.com.au/)

  • a Client;

  • a Referee.

 

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

  • Overseas Disclosures

 

3.1  For Work seekers

 

Information that we collect, hold, use and disclose about Work seekers 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;

  • 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;

  • Work seeker suitability assessment;

  • Recruitment functions;

 

4.  How your personal information is collected

 

Personal information that we collect, hold, use and disclose is likely to differ depending on whether you are:

  • a Work seeker

  • a Client

  • a Referee

 

Execom Personnel 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.

 

4.1  For Work seekers

 

Personal information will be collected from you directly when you complete an Execom Personnel application form;

Personal information is also collected when necessary ie:

  • Banking details etc. for us to pay you if you are placed by Execom Personnel.

  • 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 performing work seeker references with you and when we are checking information that we obtain from you about work seekers;

  • 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 & 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

 

Execom Personnel receive information that individuals provide while completing online forms or by email, for example;

  • 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;

 

Execom Personnel understands that there are risks associated with use of the Internet and take all appropriate steps to protect your personal information.  This includes interviewing and understanding our external party’s policies and procedures in relation to disaster management, data security, backups and server hosting environments.  Internal procedures regarding all forms of electronic transactions are documented in our Information Records System Procedure. 

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

 

4.6  Dealing with unsolicited information

 

Should Execom Personnel receive unsolicited information, for example a CV that we have not requested, we will take the necessary steps to firstly identify you.  We will then follow our procedures as per the Australian Privacy Principles and Collection Notification Statements in handling the information you have provided.

             

5.  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.

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

  • Misuse, interference and loss; and

  • Unauthorised access, modification or disclosure.

  

5.1  Our Information Record System

 

Execom Personnel record system is comprised of information that has been gathered with consent and is reasonably necessary for our staff to perform their duties.  This information is stored both electronically and as hard copies in a secure location in line with our Records Management - Storage and Protection Policy.  Routine deletion of information is done in line with our procedures to ensure that no unnecessary information is retained.  Staff are trained and prompted by our own internal systems, i.e. (TRED), which follow the recommendations set out in the Australian Privacy Principles.

        

All policies and procedures are reviewed annually or when needed in line with standards, therefore processes are under constant review.

 

5.2  Information Security

 

All workers are inducted, the induction deals with worker obligations and responsibilities when it comes to information security.  Further training is done for consultants gathering information from referees and candidates. 

 

For Further information you can always request to see our Records Management - Storage and Protection Policy, which links in with our internal Information Record System Procedure, detailing  our processes in relation to;

  • "Clean desk" policy

  • Processes in place to ensure safety on laptop, mobile phone and portable storage device security

  • Process for  timely deletion

  • Password Protection Policy

  

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 providers (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;

 

Execom Personnel 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 which do not cause us to breach those obligations.

 

6.2  Cross-Border Disclosures

 

We may disclose your personal information to overseas recipients. Many of our clients out sources their accounts payable divisions, thus invoices showing your name and hours worked may be sent to other countries outside of Australia. Although we do everything practicable to ensure safety of information, 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

 

Subject to some exceptions set out in privacy law, you can gain access to your personal information at all reasonable times with prior notice in writing.

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 supply Execom Personnel that information is entitled to expect will be observed.

 

7.1    Access Policy - As detailed in our Information Record System Procedures

 

If you wish to obtain access to your personal information you should contact our Payroll Department.  You will need to be in a position to verify your identity.

  

7.2  Correction Policy - As detailed in our Information Record System Procedures

 

If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we ask that you 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 inaccurate info has been disclosed by Execom Personnel, or is out of date, incomplete, irrelevant or misleading, Execom Personnel will take such steps (if any) as are reasonable in the circumstances to amend that disclosure, unless it is impracticable or unlawful to do so.

 

7.3  Complaints procedure

 

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

 

All complaints should be made in writing to reception@execom.com.au

 

Please complete our Report of Injury or Incident Form which is located on our website.  This will ensure we have all the necessary details to deal with your complaint in a timely manner.

 

You can also make complaints to the Office of the Australian Information Commissioner, or the 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 amending or updating, 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.

ABN 93 009 353 226

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