We, Harrier Human Capital Pty Ltd ABN 49 123 202 951, recognise that the confidentiality of personal information is fundamentally important to individuals. We believe successful business relationships are founded on trust, mutual respect and openness. Accordingly, we are committed to clear disclosure about the kind of information we gather, how this information is managed and our processes for safeguarding its privacy.
This Policy outlines our practices and procedures regarding the collection, use, storage and disclosure of personal information relating to all Directors, Management, employees, prospective employees, contractors, candidates and clients of Harrier.
By registering with us, including but not limited to submitting a profile or other personal information, you are agreeing to the collection, use and disclosure of your personal information in accordance with this Policy.
What is Personal Information?
Personal information, as defined in the Privacy Act, includes any information or opinion, regardless of its source, which identifies an individual, or from which an individual’s identity can be ascertained, whether the information is;
- true or not; and
- recorded in a material form or not.
Personal information may range from the sensitive (e.g. medical history or condition) to the everyday (e.g. address and phone number). Personal information includes, but is not limited to:
- financial information;
- employee records;
- personal details (e.g. name, address, phone number, date of birth or email address);
- the opinions of others about your work performance;
- information about your work experience and qualifications; and
- other information obtained by us in connection with possible work placements (e.g. aptitude tests or pre-placement medical assessments).
What Is Sensitive Information?
Sensitive information is a special category of personal information under the Privacy Act, and can include, but is not limited to:
- political opinions;
- race or ethnic origin;
- professional memberships;
- criminal history;
- health information;
- genetic information that is not otherwise health information; and
- biometric information.
We collect and disclose sensitive information only where it is directly related to recruitment assignments, or the requirements of your employment with us. We will only collect sensitive information with your consent, unless otherwise permitted by law.
What Are ‘Employee Records’?
Employee records are records of personal information relating to your employment, including, but not limited to;
- health information;
- personal details and emergency contacts;
- terms and conditions of employment (e.g. payroll records and leave accruals); and
- training, discipline, performance and termination details.
Employee records includes personal information of prospective employees if you subsequently become an employee of Harrier, but does not extend to information relating to candidates.
Employee records are exempt from the requirements of the Privacy Act. However, as a matter of best practice, we will maintain the confidentiality of all personal information collected, stored, used or disclosed, in accordance with this Policy.
For What Purposes Do We Collect, Hold, Use And Disclose Personal Information?
We hold, use and disclose personal information for purposes including, but not limited to:
- recruitment, including facilitating recruitment assignments and employment opportunities;
- carry out background checks (to the extent permitted by law) to verify the information a candidate supplies to us;
- client and business relationship management;
- client and candidate marketing;
- keep employee records; and
- to comply with our legal obligations under the Privacy Act 1988 (Cth)(Privacy Act), the Fair Work Act 2009 (Cth) and the Fair Work Regulations 2009 (Cth), as reviewed, amended or replaced from time to time.
Even if a candidate’s application with a particular employer is unsuccessful, we may retain their personal information and use it to provide them with details of other positions that become available in future and which we think might be of interest to them.
How Your Information Will Be Collected
Personal information may be collected directly or indirectly.
We collect personal information directly from you when you:
- create a profile, send a CV or apply for a career opportunity, including employment with us, through Harrier’s website, seek.com, twitter, LinkedIn or any other online or paper-based medium;
- complete any forms related to your employment (e.g. PAYG/TFN information or emergency contact details);
- sign an employment contract;
- are involved in a workplace complaint, accident or incident; or
- provide us with any personal information about yourself
Personal information will also be collected indirectly, through lawful and fair means and not in an unreasonably intrusive way, such as when we search for, or receive information about:
- suitable candidates in connection with recruitment opportunities or information to assist in managing client and business relationships;
- you, from a third party, including but not limited to:
- references or information from former employers, work colleagues, professional associations or registration bodies;
- the results of any competency, aptitude, psychological or medical tests;
- performance feedback (whether positive or negative);
- any complaint about you in the workplace;
- any information about a workplace accident in which you are or were involved;
- any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved; or
- publicly available information including social media profiles or articles.
It is important that any information you provide is true and accurate, and that all relevant information is disclosed.
How Your Information Is Stored And Maintained
Personal information is mainly held in secure electronic databases, paper based files and other records. We use a range of physical and electronic processes in seeking to ensure the security of personal information that we hold. Our staff, contractors and others to whom we choose to disclose personal information are required to maintain confidentiality over personal information we hold.
We will take reasonable steps to store and protect your personal information in a secure manner. This includes protection against accidental or unlawful destruction, accidental loss, interference, improper alteration or modification or unauthorised disclosure.
Except as outlined in this Policy, we will not intentionally disclose (and will take all reasonable steps to prevent the accidental disclosure of) your personal information to third parties, whether for marketing purposes or otherwise, except where there is a lawful duty to do so. However, we cannot guarantee the complete security of data transmissions or communications over the internet, such as through online application processes. You provide your personal information to us over the internet at your own risk.
When personal information is no longer required, it will be destroyed or permanently de-identified, subject to compliance with applicable legislation.
How Your Information Will Be Used
Your personal information will be used for the primary purpose of facilitating recruitment assignments and employment opportunities, as outlined in this Policy.
Personal information may also be used for a related secondary purpose. Where personal information is to be used for any other purpose, it will not be used without your consent, unless otherwise permitted by law.
Disclosure Of Personal Information
Your personal information may be disclosed under the following circumstances:
- Potential and actual employers, referees and clients of Harrier: We generally provide candidates’ personal information to prospective employers only where the candidate has requested or otherwise consented that we do so. However, where we are engaged to conduct confidential searches for management and senior executive positions, candidates’ personal information (such as name and publicly available career details), may be provided to the client without the candidate’s prior consent or knowledge.
- Service providers: We work with third parties who provide services that may include, but are not limited to, data entry and data management, assessment services, website hosting and software testing and upgrades. Some of these third parties are overseas foreign companies situated in the US, India and the Philippines. Where personal information is disclosed to such third parties, it will be done in a manner consistent with the primary purpose for which it was collected, in accordance with this Policy. We will:
- ensure the company in receipt of the information is subject to a law, binding scheme, contract or appropriate confidentiality agreement, which effectively upholds the principles for collection, storage, use and disclosure of personal information required by the Privacy Act, as outlined in this Policy; or
- take reasonable steps to ensure the information which is transferred will not be held, used or disclosed by the third party inconsistently with the Privacy Act obligations.
- Our insurers: In relation to any insurance claim or proposal that requires disclosure of your personal or sensitive information.
- Related entities: We may disclose personal information to related entities or subsidiaries where required to administer our primary functions as set out in this Policy.
- Compliance: Your personal information may be disclosed to any person, in the States or Territories in which we operate, with a lawful entitlement to obtain the information (e.g. workers’ compensation regulators). Your personal information may also be disclosed for use by an enforcement body, for a purpose such as the prevention of a crime or serious misconduct.
- Business transfers: We reserve the right to transfer, without your further consent, any and all information that we collect, to a third party in connection with a strategic alliance with such third party, or in the event of a sale of our company or one of our affiliates, a merger or consolidation involving us or one of our affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.
- Civil obligations: We may lawfully disclose your personal information where we reasonably believe it is necessary to prevent a threat to public health and safety or the safety of an individual, or in the course of investigating or reporting any suspected unlawful activity.
While we choose to conduct recruitment assignments for organisations with appropriate privacy provisions, we take no responsibility for the actions or omissions of those third parties with respect to personal information received by them, including the manner in which they use information received from Harrier.
Gaining Access To And Correcting Your Personal Information
Subject to some exceptions, you have a right to access and correct personal and sensitive information we hold about you.
- we are satisfied, having regard to a purpose for which the information is held, that the information is inaccurate, incomplete, out of date, irrelevant or misleading; or
- you request us to correct the information held by us,
we will take reasonable steps to correct the personal information so that it is accurate, complete, current, relevant and not misleading.
If we refuse your request to access or correct your personal information, we will provide written notice outlining the reasons for the refusal (unless this would be unreasonable). You may ask us to attach a statement noting your claim that particular information is not accurate, complete and current, which will be attached to the personal information.
You should anticipate that gaining access to your personal information may take a little time, as information may be archived and a formal request for retrieval may be required.
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 access.
If you wish to:
- exercise your rights of access or correction;
- have any questions or concerns regarding this Policy; or
- have a complaint regarding your rights under this Policy, a potential breach of this Policy, or the handling of your personal information,
please contact our Privacy Manager whose details are shown below:
Level 1, Newspaper House
129 St Georges Terrace
Ph: 08 6555 4300
Alternatively, you are free to lodge a complaint regarding the handling of your personal information by Harrier, to the Office of the Australian Information Commissioner (OAIC): see www.oaic.gov.au
Accountability to implement and enforce this Policy lies with our Company Directors and Senior Management team.