1. INTRODUCTION

Souter Search Pty Ltd manages personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. We are committed to protecting the privacy of all individuals and do not collect personal or sensitive information unless it is necessary for the performance of our duties, tasks or functions.

‍

1.1. APP ENTITY

Souter Search Pty Ltd manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

1.2 INFORMATION FLOW

When we collect your personal information:

• we check that it is reasonably necessary for our duties, functions or activities as a recruitment agency
• 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, which we won’t do without your consent;
• we record and hold your information in our Information Record System. Some information may be accessible to our third-party suppliers, refer to section 6. Disclosures
• we retrieve your information when we need to use or disclose it for our duties, 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 (not without your consent) 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 associated statements 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 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 duties, functions and activities as a recruitment agency and is likely to differ depending on whether you are:

• a Jobseeker;
• a Client or
• a Referee.

2.1. FOR JOBSEEKERS

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

• your resume or any registration paperwork;
• information recorded when you attend our office for an interview or participate in a telephone, Google Hangout, Skype, FaceTime or any other form of video interview with us;
• any references about you we receive;
• results of enquiries that we might make of your former employers, work colleagues, professional associations or registration body;
• 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 we receive;
• any additional information about yourself you provide us with.

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 and includes:

• information on a role you provide us with;
• information in relation to a candidate you have met that you provide us with;
• information on a business, structure, contact details etc.

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 Jobseekers for particular jobs or particular types of work and includes:

• information you provide us with about a candidate, company and contact information

3. PURPOSES

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

• a Jobseeker;
• a Client;
• a Referee.

3.1. FOR JOBSEEKERS

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

• work placement operations;
• recruitment functions;
• answering your enquiries;
• keeping you informed of new developments that may be of interest to you;
• statistical purposes and statutory compliance requirements;
• communicating and marketing our services, advising you of news and industry updates, events, promotions, resources and other information. Where we do so, you will be able to unsubscribe from such communications;
• psychometric evaluations or skills tests;
• administrative tasks by third party providers who provide services to us, such as IT consultants and administration providers. Some third-party suppliers may be located across international borders. These third parties comply with similar undertakings of privacy and confidentiality as Souter Search.

Souter Search Pty Ltd may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above.

If you do not give us the information we seek:

• we may be limited in our ability to locate suitable work for you;
• we may be limited in our ability to place you in work.

‍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 tasks, duties and functions;
• marketing services to you;
• 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;
• Jobseeker suitability assessment;
• recruitment tasks, duties and functions.

3.4. OUR POLICY ON DIRECT MARKETING

Souter Search will advise you of news and industry updates, events, promotions, reports, resources and other information. Where we do so, you will be able to unsubscribe from such communications. These communications will be delivered by Souter Search executive and no information will be provided to a third party for marketing purposes. Souter Search do not obtain customer lists from third parties for marketing purposes.

Souter Search complies with The Spam Act 2003

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:

• a Jobseeker;
• a Client;
• a Referee.

We collect information from third parties and publicly available sources, such as LinkedIn, 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.

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.

4.1. FOR JOBSEEKERS

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:

• you attend our office for an interview or participate in a telephone, Skype or other video interview with us;
• via referees
• results of any competency or medical test we receive;
• you provide us with any additional information about yourself

4.2. FOR CLIENTS

Personal information about you may be collected:

• when you provide it to us for business or business-related and/or social purposes;
• when you fill out and submit one of our online enquiry/survey forms.

4.3. FOR REFEREES

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

• in the course of our references with you or when we are checking information that we obtain from you about Jobseekers;

‍4.4. ELECTRONIC TRANSACTIONS

You can visit our website and browse without the need to disclose any personal information. When you visit our website, we record anonymous information such as the date and time of your visit, the server/IP address, which page was visited and the information viewed and/or downloaded.

We collect personal information that individuals choose to give us via online forms or 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 CV or resume by email or through our website;
• submit a vacancy description by email or through our website
• submit a timesheet via our website

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 help you to look at the OAIC’s resource on Internet Communications and other Technologies.

External sites that are linked to or from the Souter Search website are not under our control and you are advised to review their respective Privacy Statement(s). Users should note there are inherent risks associated with the transmission of information via the internet and you should, therefore, make your own assessment of the potential risk to the security of your information.

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 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 from:

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

‍5.1. OUR INFORMATION RECORD SYSTEM

All data is stored electronically on the hard drives of the servers and uploaded to the cloud each night, we retain twelve months of data in the cloud.

‍5.2. INFORMATION SECURITY

There are a number of measures used to keep your information secure.

• Personal information is stored in secured offices on a computerised database which requires a login and password to gain access
• Access to the database is only available to those who require such access.
• All staff and third-party suppliers are bound by confidentiality agreements regarding company and customer information.
• Visitors to our premises are always accompanied by a member of staff for the duration of the visit.
• Passwords are changed frequently.
• Hard copy information is disposed of in secure bins and shredded.
• There is a mandatory password policy for laptops, mobile phones and portable storage devices.

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 suppliers (CSPs) or third-party suppliers 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;
• Administration facilitators.

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

Some of your personal information may be accessible to overseas third-party suppliers, such as software maintenance in the UK or US and administration facilitators in South East Asia. To the best of our ability the Souter Search will do everything possible to ensure that suppliers comply with their own countries Privacy Policy, the Australian Privacy Act 1988 and Privacy Principle as well as the Souter Search Pty Ltd Privacy Policy. These suppliers only have access to information, they do not use any personal information.

‍7. ACCESS & CORRECTION

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.

We aim to acknowledge access and correction requests as soon as possible and commit to resolve all complaints no later than 30 days. However, there may be instances where this is not possible due to the contents of the complaint. In such circumstances, we will respond to your complaint in a reasonable and practical time

7.1. ACCESS POLICY

You may request to see and have a copy of your personal information unless we are legally authorised to refuse your request. If you wish to obtain access to your personal information you should contact our Privacy Coordinator on enquiries@soutersearch.com or on (02) 8916 6228.

You will need to be in a position to verify your identity.

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 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 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.

You may also request that Souter Search stops using your information and contacting you and we will comply with your request. However, if this involves a request for deletion of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information about our clients.

8. COMPLAINTS

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

8.1. COMPLAINTS PROCEDURE

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 Coordinator, whose contact details are enquiries@soutersearch.com or (02) 8916 6228.

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