Overview and Objective
This policy is intended to meet the needs of the range of people who come in contact with us, some information may not be seen as relevant by all people.
AKG manages personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APP). This policy applies to information collected by AKG.
AKG is committed to protecting the privacy and personal information of our clients who generally include job seekers seeking employment or training, participants, employers, applicants for positions, training providers, suppliers and government agencies.
Scope
This policy applies to all AKG employees and AKG clients.
Policy
Kinds of information collected and held
Personal information that we collect, and hold is information that is reasonably necessary for the proper performance of our functions and services and may differ for various clients. We do not collect personal information if we have no present need for it. Information may include (but is not limited to) the following:
- contact details such as name, address, telephone number, email address, date of birth, licence details
- education and qualifications
- resume and application information
- work performance information e.g. reference checks
- bank account details
- tax file number
- police and working with children check clearances
- Australian work rights or visa credentials
- Personal identification credentials – drivers’ licence, passport
- Payroll details
- Information about incidents in the workplace
- Information about absences from work due to leave, illness or other causes
- Information obtained to assist in managing client and business relationships
Sensitive information has a particular definition under the Act to which higher privacy standards apply. Sensitive information includes racial or ethnic origin, affiliations or beliefs, criminal record, financial status, health or disability. Generally AKG does not collect sensitive information; the exception being any information that the job seeker or participant thinks will assist AKG in placing a job seeker or participant into employment. We will collect and manage this information in accordance with the APP.
Collection of personal information
The type of information that we typically collect, and hold is information that is necessary to perform our functions and duties which are to:
- Determine eligibility for our employment-related services
- Provide employment-related services
- Recruitment functions
- Manage performance in work obtained through us
- Client and business relationship management
- Marketing services
Information is preferably collected directly from an individual or organisation. This can be done by completing a form, interviews, meetings, phone conversations, business cards, resumes, job applications.
As a provider of services to governments, we may collect personal information from relevant government departments and agencies including:
- Department of Social Services
- Department of Human Services – Centrelink
- Department of Prime Minister and Cabinet
- Department of Employment, Skills, Small and Family Business
We may also collect personal information through other third parties including:
- Educational institutions and training providers
- Medical practitioners
- Previous or current employers
- Nominated referees
- Criminal records check provider
- Publicly available sources including newspapers, journals, directories, the Internet and social media sites
We will manage the information in accordance with the Act and our Privacy Policy.
AKG does not collect personal information via the internet unless you specifically provide it to us.
Where we receive unsolicited personal information, we will assess if the information is reasonably necessary for our functions and activities and treat it in the same way as any other personal information. Where we assess the information is not reasonably necessary for our functions and activities we will either destroy or de-identify the information.
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.
AKG understands that where lawful and practicable, individuals have a right not to identify themselves. If an individual wishes merely to enquire about AKG services, jobs etc. they do not have to identify themselves however, due to the nature of the services being provided to you this will be in very limited cases.
Disclosure of personal information
Your personal information may be disclosed to:
- Potential, current or future employers
- Education and training providers
- Criminal records check provider
- Relevant Australian and State government departments and agencies e.g. Centrelink
- Specialist professionals providing services to AKG
- Other parties that provide support services to AKG where reasonably required
- Any person with a lawful entitlement to obtain the information
Related purpose disclosure – We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically, our CSPs would include:
- I.T. contractors and database designers and internet service suppliers
- Legal and other professional advisors
- Insurance brokers, loss assessors and underwriters
- Superannuation fund managers Direct marketing – We will not disclose any held personal information about an individual for the purpose of direct marketing unless:
- 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.
- The individual has given consent
- The individual has requested not to receive direct marketing material.
We will not disclose personal information held to an overseas recipient.
Data Quality and Security
We are committed to taking reasonable steps to ensure that the personal information we hold is accurate, up-to-date and complete.
Personal information is held in our record systems 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 steps to protect your personal information from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure. Information is archived for the required timeframe and then securely disposed in accordance with our Records Management procedures.
Unique Identifiers
AKG will not use or disclose government related identifiers of an individual unless:
- All personal and sensitive information held by AKG is stored securely and protected from unauthorised use or access. Information is stored in hard copy formats in locked storage facilities and electronic formats in computer systems that are firewalled and password protected.
- The use or disclosure is necessary to verify the identity of the individual for the purpose of our activities and functions
- The use or disclosure of the identifier is reasonably necessary for it to fulfil its obligation to an agency
- It is required or authorised under Australian Law.
Access & Correction
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold to ensure that it is accurate, complete and up to date.
For security purposes, individuals may be asked to put their request in writing and may need to verify their identity before information is released. We will respond to your request for access within 14 days.
We may refuse to provide you access to records if there is a basis for the refusal under other legislation which could include:
- Records containing information about another person
- Medical/psychiatric records (other than if supplied by you or an employer)
- Psychological records
- Information provided by third parties i.e. evaluative opinion material obtained confidentially in the course of our performing reference checks
- That giving access would pose a serious threat to the life, health or safety of any individual
- Deemed frivolous or vexatious
- Information relates to legal proceedings
Giving access would be unlawful. 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.
Enquiries and Complaints
AKG will respond in writing within 30 days of receipt of a complaint. If the complaint remains unresolved you have the option of notifying the Office of the Australian Information Commissioner (OAIC). Contact details can be found at OAIC’s website: www.oaic.gov.au
If you are not satisfied with our response, complaints can be made directly to the relevant government department or the Australian Information Commissioner.
Privacy related enquiries or complaints regarding our compliance with the Privacy Act should be made in writing and directed to:
Privacy Officer
AKG
PO Box 5239, Sydney, NSW 2001
Phone +61 2 9259 5555
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.
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.
Compliance
This policy will be officially monitored for compliance by Site Managers at Site. The Quality and Performance Manager will monitor this policy company-wide. Monitoring of this policy may include random and scheduled inspections. Any exception to this policy must be approved by the General Manager in advance.
Non-Conformance
Any employee or contractor found to have violated this policy may be subject to disciplinary action as outlined in the Performance Management Policy.
