Privacy Policy – Clinton Recruitment

Privacy Policy

We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APP), the following information applies to information collected by Clinton Recruitment Pty Ltd. The APP’s are available from the Office of the Australian Information Commissioner (OAIC) website.

We only collect personal information that is reasonably necessary for the proper performance of our activities or functions. We do not collect information just because we think it could be useful at some future stage if we have no present need for it.

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly or enter into communication with us that involves the collection of your personal information, it is important that you check this policy to ensure that you are aware of the extent of any consent, authorisation or permission you might give.

We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.

We collect personal or sensitive information about you when:

You complete an online application through our website
You complete one of our application forms
You complete a collection statement
We receive any reference about you
We receive feedback about you from your former employers, work colleagues, professional associations or registration body
We receive any results from medical tests, or any competency tests
We receive performance feedback (whether positive or negative)
We receive any complaint from or about you in the workplace
We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved in any way
We receive any information about a work place accident you were involved in
You provide us with any additional information about you

At Clinton Recruitment Pty Ltd our service is free to candidates (work seekers).

All positions advertised by Clinton Recruitment are genuine roles

We will always endeavour to the best of our ability to keep the information we provide to you about available vacancies to be up to date and as accurate as possible.

At Clinton Recruitment we do not send CV’s out to clients speculatively. We will always consult with candidates before releasing a CV or indeed any personal information about a candidate

We do not send out to a data base of contacts promotional material with ‘snap shots’ of candidates work history.

At Clinton Recruitment we respect people’s privacy and will do everything possible to work in a way that is respectful of any individual’s personal and sensitive information.

Information Flow:

When we collect your information:

We check that it is reasonably necessary for our functions or activities.
We check that 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.
We retrieve your information when we need to use or disclose it for our functions and activities. At the time, we check that it is current, 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 the Australian Privacy Principles (APP) and the Privacy Act 1988.
We correct or attach associated statements to your personal information in accordance with the APP.
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.

Kind of information that we collect and hold

Personal

Personal information that we collect and hold is information that is reasonably 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 (work seeker) – 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.

A 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. A client is identified as someone who might be interested in acquiring our services

A referee – the type of information that we typically collect and hold about referees is information that is necessary to help make determinations about the suitability of one of our candidates for particular jobs or particular types of work. A referee is a person from whom we have sought facts or opinions regarding the suitability of one of our candidates for work or positions through us; and who may be a Referee nominated by the Candidate, a Client or us.

Sensitive information will need to be collected where it relates to a genuine occupational requirement, for the purposes of the right to work in Australia verification or an inherent requirement of the job or work being considered. Our collection of some types of sensitive information is also governed by equal opportunity and anti-discrimination laws.

You may choose not to provide us with personal information but this may result in us being unable to provide you our services in seeking and being placed in work.

Purposes

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

A Candidate / Work seeker

A Client

A Referee

For Candidates / Work seekers

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. It includes:

Information submitted and obtained from candidates and other sources regarding applications for work
Information about personality, character, skills, qualifications and experience
Information about career path and preferences
Information about work entitlement and ability to undertake specific types of work
Information about health status and ability to undertake particular types of work related activities.
Work performance information
Personal information including contact details
Information about incidents in the work place
Information in relation to absences from work due to leave, illness or other causes
Information in relation to criminal history or criminal records
Information in relation to a Candidates right to work in Australia

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. Personal information that we collect, hold, use and disclose about Clients is typically used for

Client and business relationship management – we may collect information about team structures and specific duties in relation to specific job roles.
Recruitment functions – we may collect information about individuals within a business that have the authority to make hiring decisions.
Marketing services
We may collect information for statistical purposes and statutory compliance requirements
We may collect information about incidents in the work place
We may collect information about client facility addresses, ABN, key personnel and contact details and financial information

For referees

The type of information that we typically collect and hold about Referees is information that is necessary to help make determinations about the suitability of one of our Candidates for particular jobs or particular types of work. Personal information that we collect, hold and disclose about Referees is typically used for:

To confirm identity and authority to provide references;
Work seeker suitability assessment;
Recruitment functions
We collect information about a work position, authority to give a reference and preferred contact details
We collect opinions of a referee regarding the candidate’s character and work performance or work environment including factual evidence to support those opinions sometimes influenced by the experience and knowledge of the referee who has worked directly with the candidate.

DIRECT MARKETING

We do not sell on or disclose your information to any third parties for marketing purposes.

We will not send job seekers personal CV’s on to potential employers without their agreement.

We do not obtain customer lists from any third parties for marketing purposes nor do we supply any to anyone.

We protect personal and sensitive information supplied to us and use computer security; password protection processes and firewalls.

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 candidate / job seeker

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.

For Candidates / work seekers

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 obtain work through us.

Personal information is also collected when:

We conduct a face to face interview, speak to a work seeker on the telephone or have any subsequent meetings.
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
We will only collect information that is necessary for the proper performance of our tasks or functions
We do not collect or use personal information for the purposes of unlawful discrimination
We do not use your personal information to carry out reference checks merely for the purposes of establishing network contacts
We do not routinely conduct criminal history checks. A candidate would be notified before such checks were performed by Clinton Recruitment Pty Ltd.

If you only browse our website we do not collect information that identifies you personally, though we may collect information related to your visit to our website.

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.

For Referees

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

In the course of checking work seeker references with you and when we are checking information we obtain from you about work seekers.

Photos & Images

We may request proof of identification from you including copies of your passport, visa, drivers licence or any other relevant licences and will only do so for the performance of our activities or functions as a recruitment agency. We will not request that you supply photographs, 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.

Electronic Transactions

This section explains how we handle personal information collected from our website www.clintonrecruitment.com.au and by other technology in the course of electronic transactions.

It is important to understand that there are risks associated with the use of the internet and you should take all appropriate steps to protect your personal information.

Please ensure that you know your rights, read our privacy policy, collection statement and consent to electronic transactions. Please be careful what information you share on the Web. Make sure that your anti-virus and data protection software is up to date. If you are unsure about making contact with us via the internet please contact our Privacy Officer to discuss your concerns.

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 though our website
you submit your resume via a job board
You apply to a job using a job seekers job site

It is important that you understand that there are risks associated with the use of the internet and you should take all appropriate steps to protect your personal information. It might be helpful to look at http://www.privacy.gov.au

To prevent any unauthorised access to your information we have installed computer security; pass word protection processes and firewalls. Only authorised staff has access to sensitive information.

We do not accept any responsibility or liability for the privacy policies of other internet sites, including those linked through to our site.

We gather information from our website users such as how many visitors we have received, which pages were viewed most often. All such data collected is done so anonymously. This information is useful for Clinton Recruitment to better enhance the web site for its users.

How your personal information is held

Personal information is held in our Information Record System until it is no longer needed for any purposes 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 from:

Misuse, interference and loss: and

Unauthorised access, modification or disclosure.

Our Information Record System

We store information in hard copy and electronic format in a secure environment. This includes electronic devices such as phones and ipads when working outside of the office environment where we will continue to receive emails that may include resumes and other private and personal information.

Computing Services: Google handles our cloud computing email requirements. Please refer to the privacy policy https://cloud.google.com/security/privacy/

Cookies: We do not keep a copy of cookies to our website.

Emails: All email communication is kept for record purposes only if required.

Uploading Photographs: Please do not upload photographs of any individuals who have not given consent to the display of their photograph.

Unsolicited information: If we receive personal information that is unsolicited information that we do not require to perform one or more of our services we will destroy or de-identify the information as soon as possible.

How your Personal Information is held:

Clinton Recruitment Pty Ltd takes all reasonable steps to ensure that the personal information that we collect is up to date and accurate. However we rely on you to tell us when there are changes to your personal information that we hold about you. This may include such things as a change of address or employment status.

Data Retention:

If we deem that you are no longer actively using our services after a 4 year period, then we retain the right to destroy your information or de-identify your information.

Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent inadvertent access to it.

DISCLOSURES

We may disclose your personal information for any of the purposed 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 duty to disclose information.

Disclosures will usually be internally and to our related entities, to our Clients, and to Referees for suitability and screening purposes.
We do not share sensitive 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 or imminent threat to somebody’s life or health
This 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.

Related Purpose Disclosures

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSP’s may see some of your personal information. Typically our CSP’s would include:

Software solutions providers;
IT Contractors and internet service suppliers;
Legal and other professional advisors;
Insurance brokers, loss assessors and underwriters;
Superannuation fund managers;
Background checking and screening agents;
Any individual who is lawfully entitled to gain access

We take reasonable steps to ensure that terms of service with our CSP’s 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.

Other Parties

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 impracticality of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek you consent to disclosure.

Access and Correction

Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold about you.

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.

There are circumstances in which we will deny access to information, such as where providing access would have an unreasonable impact upon the privacy of other individuals or the request for access is frivolous or vexatious. We would also deny access to your personal information where providing access would reveal evaluative information generated with Clinton Recruitment Pty Ltd in connection with a commercially sensitive decision making process. In these circumstances Clinton Recruitment Pty Ltd may give you an explanation for the commercially sensitive decision rather than direct access to the information.

For a full list of the circumstances in which access to your personal and sensitive information may be denied, please refer to the ACT.

If you wish to exercise your rights to access and correct your details please contact our Privacy Co-ordinator. In some cases we may impose a moderate charge for providing access to personal or sensitive information. We will not charge you simply because you lodge a request for information. We will generally respond to your request for access within 20 working days.

Correction

If you find that personal information that we hold about you in inaccurate, out of date, incomplete, irrelevant, or misleading, you can ask us to correct it by contacting us. We encourage individuals to contact us via the telephone or email to update us with changes of address or a new phone number or new email address.

We will take 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.

Please advise us if you wish to be removed from our recruitment records and software system. We will remove all information that we have no present need for or obligation to retain.

Notifiable Data Breaches

In the event that there is a data breach we will take all reasonable steps to contain the suspected or known breach where possible. We will take immediate steps to limit any further access or distribution where possible.

If we have reasonable grounds to suspect that the data breach is likely to result in serious harm to any individuals involved, then we will take all reasonable steps to ensure an assessment is completed within 30 days of the breach.

If remedial action is successful in making serious harm no longer likely, then no notification or statement will be made.

Where we are aware of reasonable grounds to believe serious harm is likely, as soon as practicable, we will provide a statement to each of the individuals whose data was breached or who are at risk. The statement will contain details of the breach and recommendations of the steps each individual should take. We will also provide a copy of the statement to the Office of the Australian Information Commissioner.

We will review the incident and take action to prevent future breaches.

Complaints

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 us in writing.

You can make complaints about our handling of your personal information to our Privacy Co-ordinator whose contact details are The Privacy Co-ordinator, Clinton Recruitment, P0 Box 289, Coogee, Sydney, 2034.

You are always welcome to speak directly to Louise Clinton, Managing Director, Clinton Recruitment. (02) 9664 8653

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

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 complaints;
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 establish what has happened and why;
We will require a reasonable time (maximum of 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 we cannot resolve your complaint to your satisfaction you can contact the Office of the Australian Information Commissioner: T: 1300 363 992 E: [email protected]

If you wish to make an enquiry, request access to your personal and or sensitive information, wish to delete or amend any information we hold or complain about an alleged breach of the APP please do not hesitate to contact:

The Privacy Co-ordinator

Clinton Recruitment, PO Box 289, Coogee, Sydney 2034 Australia.

This policy was last updated in November 2018.