We manage personal information in accordance with the Privacy Act 1988 and the Australian Privacy
This Policy applies to information collected by Whipper Recruitment
We only collect information that is reasonably necessary for the proper performance of our activities or functions.
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.
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).
1.1 APP Entity
Whipper Recruitment manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).
Because we are a contracted service provider to a range of Commonwealth, State and Territory government agencies, it sometimes becomes 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 an employment 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.
- We record and hold your information in our Information Record System. Some information may be disclosed to overseas recipients.
- 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 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 functions and activities as an Employment Agency and is likely to differ depending on whether you are:
- a Candidate;
- a Client;
- a Referee
2.1 For Candidates
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:
- Past and current work experience
- Your actual or possible work placement
- Any test or assessment (including medical tests and assessments) that you might be required to undergo
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:
- Relevant contact details
- Agreed rates and terms
- Past and present placements
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 Candidates for particular jobs or particular types of work and includes:
- Company and title of relevant employment
- Contact information
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:
- Our Policy on Direct Marketing
3.1 For Candidates
Information that we collect, hold, use and disclose about Candidates 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
- 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;
- Candidate suitability assessment;
- Recruitment functions.
3.4 Our Policy on Direct Marketing
Whipper Recruitment may sometimes use personal information for marketing purposes but only subject to the following:
- Personal Information is only used for marketing purposes to allow Whipper Recruitment to provide:
- Candidates, whilst they are registered with us, with updates in relation to employment opportunities, market information and promotions from time to time;
- Clients, with whom we have a relationship, with market information and promotions from time to time;
- Subscribers to Whipper Recruitment’s website with news and job alerts they have subscribed for.
- Personal Information is not used by or disclosed to any third party for marketing purposes;
- Client lists are not generally obtained from third parties for marketing purposes;
- In accordance with the anti-spam legislation, individuals to whom marketing communications are sent are:
- Chosen on the basis of having given their express and/or implied consent for such communications to be sent to them since they registered with Whipper Recruitment for the purpose of engaging Whipper Recruitment as their employment agent; and
- Always given on opt-out or unsubscribe option in relation to such communications.
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 Candidate
- 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 the 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. See also the section on Photos & Images.
4.1 For Candidates
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. We may also collect personal information about you from a range of publicly available sources
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
4.3 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 the information that we obtain from you about Candidates.
- 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.
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
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 or other job board. 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.
You can contact us by landline telephone or post if you have concerns about making contact via the Internet.
- Sometimes, Whipper Recruitment collects 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 sites such as a job notification board or news and market updates;
- make a written online enquiry or email us through our website; or
- submit a resume by email or through our website.
Social Media & Web
In order to assess your suitability for positions and to assist you to find work, Whipper Recruitment will need to collect, use and disclose personal information about you. In addition to conducting Internet searches using search engines and entering your name and relevant identifying details,
Whipper Recruitment may look at your social media footprint on sites such as LinkedIn and Twitter to conduct background checking.
Whipper Recruitment’s telephone technology (telephone systems and mobile phones) logs telephone calls and messages received and sent and enable call number display in most offices. When your call number is received by Whipper Recruitment because of your phone or send Whipper
Recruitment 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 are recorded, we will tell you first the purpose for which they are to be used and retained.
Whipper Recruitment uses recruiting software and databases to log and record recruitment operations. Whipper Recruitment uses FastTrack as an applicant tracking system for applications received via Whipper Recruitment’s website or job boards. Using the Broadbean software, Whipper Recruitment can automatically transfer suitable applicant’s resumes and contact information to the respective fields in Whipper Recruitment’s internal secure candidate database. Our internal candidate and client database provide searching and job matching facilities.
Some Whipper Recruitment staff may use laptops, tablets, mobile phones and other portable electronic devices that allow them to access, retrieve and store your personal information. Where Whipper Recruitment staff utilise portable devices, they are subject to Whipper Recruitment’s Internet & Email Policy.
5. How your personal information is held
Personal information is held in our Information Record System [inks to level 2: Information Record System] until it is no longer needed for any purpose for which it may be used or disclosed at which the 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
Information is stored securely on our electronic database.
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.
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.
7.1 Access Policy
If you wish to obtain access to your personal information you should contact our Privacy Coordinator. [Include any other information about your access policy – e.g. information about:
- Any lawful costs or charges that you impose
- Timeframes for your response to access requests
- What happens in the event that you refuse access
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 us 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 have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. For more information see our Complaints Procedure.
7.3 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: Gail Whipper on (02) 4962 1877 or firstname.lastname@example.org.
You can also make complaints to the Office of the Australian Information Commissioner. Complaints may also be made to 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
the good conduct of the Association's 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 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 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.