1. INTRODUCTION
Ccentric International takes seriously its commitment to preserve the privacy of the personal information that we collect.
We manage personal information in accordance with our Privacy Policy, the Privacy Act 1988, the Australian Privacy Principles, and any other relevant legislation that applies to Ccentric’s collection, use, disclosure and storage of personal information.
We will only collect information that is reasonably necessary for the proper performance of our activities or functions as a recruitment agency. 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 do not collect, use or disclose personal information for unlawful purposes including discrimination
We acknowledge that an individual has the right to not identify themselves, or to use a pseudonym when dealing with us. However, the nature of the recruitment services which Ccentric provides means that in most cases it will not be possible to preserve anonymity and pseudonymity beyond an initial enquiry.
We will not use government related identifiers for the purpose of identifying you unless required by law.
Ccentric is wholly owned by Wavelength International Pty Ltd. The privacy policy of Wavelength International can be found at https://wave.com.au/privacy-policy/ In the course of any locum/interim work, your details may be provided to Wavelength for the purpose of credentialing and checking other legal requirements.
If you have any questions, wish to request a correction, or to make a complaint, please contact our Privacy Officer via email at privacy@ccentric.com.au or by phone via +61 2 8422 5300.
1.1 Changes to Privacy Policy
This Privacy Policy may change from time to time due to changes in legislation, our activities, technological advances etc. For this reason we recommend reviewing this Policy each time you engage with Ccentric in any way.
1.2 Consent
By accessing Ccentric’s websites and/or submitting your personal information to Ccentric through any means, you consent to the use of your information as set out in this Privacy Policy. Please note, if you do not consent to provide information, or the information provided is insufficient or inaccurate, we may be limited in our ability to provide our services as a recruitment agency to you.
2. INFORMATION COLLECTION
It is necessary for our functions or activities as a recruitment agency to collect personal information about you.
Personal information is information that can render an individual reasonably identifiable and includes name, phone number, email address, social media profile, employment history etc. Ccentric will only collect and store personal information where reasonably necessary for the proper performance of our functions and activities as a recruitment agency, and this information is managed in accordance with this Privacy Policy.
When we collect your personal information we:
- Check that it is reasonably necessary for our business functions and / or activities as a business;
- 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;
- Record and hold your information in our Database (see Clause 5 for specific information on our database). Some information may be disclosed to overseas recipients only as is reasonably necessary for our functions or activities as a recruitment agency.
- Do not share your information with any third parties without your explicit consent to do so for each instance.
- Retrieve your information when we need to use or disclose it for our functions and activities as a recruitment agency. 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 the Australian Privacy Principles (see Clause 7 for more information on accessing your personal information).
- Correct or attach associated statements to your personal information in accordance with the Australian Privacy Principles (see Clause 7 for more information on correction of your personal information).
- Destroy or de-identify any financial information we hold after a period of seven (7) years provided that it is lawful for us to do so.
- Keep your personal information for a minimum of three (3) months, after which we may destroy or de-identify it if it no longer serves our functions or activities as a recruitment agency.
Sensitive information is personal information that is more private in nature, including ethnicity, race, religious beliefs, sexual orientation, health information, etc, and therefore requires a higher level of protection. Sensitive information on any individual will only be collected where it relates to a genuine occupational requirement or an inherent requirement of the job or work being considered. We will only collect sensitive information with your consent.
Unsolicited Information is any personal information that we receive without asking for it. We will take reasonable steps to ensure that any unsolicited information we receive from you or about you is purged from our systems providing it is not required for the proper performance of our functions and activities as a recruitment agency.
2.1 Kinds of Information We Collect and Hold
The type of 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 i.e. a person who is seeking a placement or work through us or career advice from us, or whom we have identified as a person who might be receptive to hearing about potential job opportunities from us;
- A Client i.e. a person other than a candidate who has acquired, or is looking to acquire our services, or whom we have identified as someone who might be interested in acquiring our services;
- A Referee i.e. a person from whom we have sought facts or opinions from to assess the suitability of a Candidate’s qualifications, skills, character, and previous work performance; and who may be a Referee nominated by a Candidate, a Client or by us.
Where an individual fits into more than one category above, all relevant categories will apply.
2.1.1 Candidates
The personal information we typically collect and maintain about Clients may include:
- Personal details including name, address, contact details including phone number and email address, gender, etc;
- Employment information including organisation, position, contact details;
- Information submitted and obtained from you directly e.g. CV, job application; as well as from other sources including Referees or Clients, in connection with applications for work;
- Information about personal attributes, professional responsibilities, work performance, skills, qualifications and experience, generally collected through interviews and reference checks
- Documentation relating to employment history, proof of identity, immigration status, qualifications and Registration.
- Results of various tests, appraisals and background checks undertaken and/or consented to by you.
2.1.2 Clients
The personal information we typically collect and maintain about Candidates may include:
- Personal details including name, position, business address, contact details including phone number and email address, gender; etc;
- Client relationship information disclosed during meetings;
- Organisational information including structure, strategy, etc;
- Banking, payment, and financial details
2.1.3 Referees
The personal information we typically collect and hold about Referees is that which is necessary to help to make determinations about the suitability of one of our Candidates for a particular job, and may include:
- Your name, contact details and position within the organisation;
- Your relationship to the Candidate for whom you are providing a reference; including previous employment details if they differ from your current employment;
- All information you provide as part of a reference including opinions regarding the Candidate’s character, their work responsibilities, performance, and the working environment;
- Facts of evidence in support of those opinions.
2.2 Photos, Images and ID Documents
Ccentric will not request sensitive documents from you that may have a photographic image of yourself, such as copies of your passport, visa and/or driver license. We may request to view such documents via an online meeting / video call and we will only request to site these documents where it is necessary for the proper performance of our functions and activities as a recruitment agency.
Sometimes your communications with us may include images of yourself, such as within your CV. As such, please ensure you read Clause 4 for further information on Electronic Transactions.
2.3 How We Collect Information
Personal Information is generally collected directly from you when you provide it to us for recruitment or recruitment related purposes, in particular in job applications.
We may also collect personal information on you from a range of publicly available sources including newspapers, journals, directories, websites and social media sites. Such publicly available information is sourced for inclusion in our records only as is reasonably necessary for the proper performance of our functions and activities as a recruitment agency, and this information is managed in accordance with this Privacy Policy.
We may also collect personal information on you through various electronic communications with you, as well as through the technology that is used to support this electronic communication – see Clause 4 for more information on electronic transactions.
In addition to the above, other means by which we will collect personal information may likely to differ for depending on whether you are:
- A Candidate
- A Client
- A Referee
Where an individual fits into more than one category above, all relevant categories will apply.
2.3.1 Candidates
In addition to publicly available information and information collected through electronic communication, Personal information about you will generally be collected directly from you when you provide it to us for recruitment or recruitment related purposes, including when:
- You provide information to us via any means including via our website, email, phone, or letter.
- One of your referees provides us with a reference on you
- We receive feedback about your professional performance from Clients or related parties, whether positive or negative
- We receive results of any competency, psychometric or medical test you are required to complete as part of an application
- We receive results of any background checks or verification checks for qualifications and professional memberships
- We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
- You provide us with any additional information about you.
2.3.2 Clients
In addition to publicly available information and information collected through electronic communication, Personal Information will generally be collected directly from you when you provide it to us for business or business related social purposes, in the course of your communications with us.
2.3.3 Referees
In addition to publicly available information and information collected through electronic communication, Personal information about you may be collected when you provide it to us in the course of our obtaining Candidate references from you and when we are checking information that we obtain from you about Candidates.
2.4 Purpose and Use
The purposes for which we collect, hold, use and disclose your personal information are those purposes that are reasonably necessary for the proper performance of our functions and activities as a recruitment agency, and are likely to differ depending on whether you are a:
- A Candidate
- A Client
- A Referee
Where an individual fits into more than one category above, all relevant categories will apply. The following sections are also relevant to our use and disclosure of your personal information:
- Our Policy on Direct Marketing (see Clause 3 below)
- Related Purpose Disclosures and Overseas Disclosures (see Clause 6 below)
2.4.1 Candidates
Personal information that we collect, hold, use and disclose about a Candidate is typically used for the following purposes:
- Recruitment functions including assessment of suitability for placement into particular roles;
- Provision of information to you via various communications channels, including advice regarding positions that may be of potential interest to you;
- Statistical purposes and statutory compliance requirements;
- Staff management and training;
- Audits and risk management;
- Communication via various channels to market our services to you, only where this is permitted and with instructions to opt-out;
- Assessing and improving our various business services;
- Requesting your participation in surveys.
2.4.2 Clients
Personal information that we collect, hold, use and disclose about a Client is typically used for the following purposes:
- Client and business relationship management;
- Recruitment functions;
- Statistical purposes and statutory compliance requirements;
- Staff management and training;
- Audits and risk management;
- Communications via various channels to market our services to you, only where this is permitted and option to opt-out;
- Assessing and improving our various business services;
- Requesting your participation in surveys.
2.4.3 Referees
Personal information that we collect, hold, use and disclose about Referees is typically used for:
- Confirmation of identity and authority to provide references;
- Candidate suitability assessment;
- Recruitment functions;
- Audits and risk management;
- Staff management and training.
3. DIRECT MARKETING
From time to time we may send email, text message or print communication to you as part of various direct marketing campaigns. We may use the personal information we have to include you in these direct marketing campaigns, unless you have specifically requested us not to do so. We generally market our services and job opportunities to Clients and Candidates using email, phone, and print material.
Where it is practicable to do so, we will obtain your consent. Where it is not practicable to obtain consent and you receive marketing related communications from us, you will have a clear option to unsubscribe from distribution lists for similar or all future direct marketing campaigns. Upon receipt of this request your marketing preferences will be updated on our systems.
We value your privacy and are committed to complying with all applicable anti-spam laws. If you feel we have fallen short of this commitment, please let us know by contacting us at privacy@ccentric.com.au so we can address and resolve the issue promptly.
4. ELECTRONIC TRANSACTIONS
This section explains how we handle personal information collected from our website www.ccentric.com.au and by other technology in the course of electronic communication and 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
- Register as a site user by applying for roles on our job page;
- Make a written online enquiry or email us via our website;
- Submit a resume by email or through our website;
- Follow, interact and converse via social networking platforms such as Facebook and LinkedIn.
It is important that you understand that there are risks associated with 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 Online privacy https://www.oaic.gov.au/privacy/your-privacy-rights/social-media-and-online-privacy
Please contact us on +61 2 8422 5300 if you have concerns about making contact via the Internet or email.
4.1 Social Media and Online Searches
In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. We may conduct online due diligence checks to assess your suitability as a Candidate using internet search engines such as Google, Facebook, Instagram, Twitter and other social media sites, public and private organisation websites, regulatory and immigration sites, and medical registration boards such as AHPRA etc.
4.2 Browsing
When you visit our website, we collect your usage data via cookies and other tracking technologies which do not identify you personally. This data includes pages you visit, the time spent on each page, and your IP address. It is collected for reasons including improving the user experience of our website, analysing web traffic and trends, and to detect and prevent fraud.
4.3 Third-Party Websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those third-party websites and recommend you review the privacy policies of such websites before providing any personal information.
4.4 Cookies
Cookies are uniquely numbered identification numbers like tags which are placed on your browser. We use cookies to monitor usage of our website including what pages are viewed and for how long etc, and generate statistics used to improve our website experience. By themselves cookies do not identify you personally, but they may link back to a database record about you. You can set your browser not to accept Cookies, or you can delete cookies from your browser at the end of the session.
4.5 Cloud Computing Services
We take reasonable steps to ensure that our Cloud Computing Service Provider’s terms of service 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.
4.6 Mobile Access
Our staff use laptops, tablets, phones and other portable electronic devices that allow them to access, retrieve and store your personal information. This information is used for recruitment purposes and will only be used or disclosed for the purpose for which you have provided it.
5. HOW YOUR PERSONAL INFORMATION IS HELD AND DISPOSED OF
When your personal information is collected it will be held in our server-based recruiting database, on our website and on our network drive, all of which restrict user access without the use of approved login credentials, and are only accessed as is reasonably necessary for the proper performance of our functions and activities as a recruitment agency.
We use a recruiting database to log and record recruitment operations. This recruiting database is allocated on our cloud server that allows disclosure to cross border recipients, only as is reasonable for the proper performance of our functions and activities as a recruitment agency, or as outlined in Clause 6 Disclosures below. The database will contain personal details and documentation you have provided to us which will only be used or disclosed for the purpose for which you have provided it.
Printed information will be scanned and held electronically as above, with paper copies then shredded or disposed of through secured bins collected by an authorised document destruction organisation.
We take a range of measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. These include:
- Staff training
- Need-to-know and authorisation procedures
- Password protection
- Policies on laptop, mobile phone and portable storage device security;
- Destruction of records, including by shredding and secure disposal;
Personal information will be held in our database and on our systems for 7 years or until it is no longer needed for any purpose associated with our functions or activities as a recruitment agency, whichever is less. At this time personal information will be destroyed or de-identified, provided that it is lawful for us to do so.
6. DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information for any of the purposes for which it is primarily held, being the functions and activities as a recruitment agency, for a related purpose where lawfully permitted, or where we are under a legal duty to do so.
Disclosure will usually be:
- Internally / to our related entities
- to our Clients or Candidates
- to Referees for suitability and screening purposes
6.1 Related Purpose Disclosures
From time to time we outsource a number of services to contracted service suppliers (CSPs) who may see some of your personal information. Typically, our CSPs would include:
Software solutions providers and IT contractors e.g. database, marketing software etc
- Legal and other professional advisors;
- Background checking and screening agents;
- Marketing suppliers;
- Data cleansing partners.
We take reasonable steps to ensure that our CSP’s terms of service recognise 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 disclosed to overseas recipients. This would generally only occur if reasonably necessary for the proper performance of our functions and activities as a recruitment agency e.g. a client may be located outside of Australia, or where a third-party provider for a related purpose is located outside of Australia.
We take reasonable steps to ensure that terms of service with overseas recipients of personal information 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 country or countries to which your data may be transferred is not restricted, and may include: countries within the Americas, Europe or the United Kingdom; Ireland, China; India; Singapore; New Zealand or such other countries as advised from time to time.
7. ACCESS, CORRECTION AND DELETION OF PERSONAL INFORMATION
7.1 Access
Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you. Important exceptions include:
- Where access impacts on the privacy of others e.g. where information has been provided with the expectation of confidentiality
- Where the request for access is frivolous or vexatious
- Where there are existing or anticipated legal proceedings; or
- Where such access can be denied under law or by a law enforcement agency
In these circumstances we will provide a written notice that sets out the reasons for the refusal and the mechanisms available to complain about the refusal. We will generally respond to your request for access within 14 days of your initial request.
If you wish to obtain access to your personal information you should contact our Privacy Officer at privacy@ccentric.com.au. You will need to be in a position to verify your identity and we may impose a moderate charge for providing the information.
7.2 Correction
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 our Privacy Officer. 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.
There is no charge to you for asking us to correct your personal information. You should note that it may take up to 5 days for the relevant information to be corrected in our system
If we are not in a position to correct the information, or do not agree that the information should be changed, we will provide you with written notice of that fact including the reasons for the refusal. You may request a statement to be associated with o9ur personal information, indicating that you contest the accuracy or validity of the information on file. You may raise a formal complaint to us in writing, as per the Complaints procedure below.
7.3 Deletion
You have the right to request deletion of your personal information. Please note however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. You can request deletion by contacting our Privacy Officer.
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. If you are making a complaint about our handling of your personal information, it should first be made to us in writing via our Privacy Officer who can be contacted at privacy@ccentric.com.au.
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 established what has happened and why;
- We will require a reasonable time (usually 30 days) to respond, if at this time a response cannot yet be provided, you will be notified of an updated timeline;
- 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 the Australian and New Zealand IT Contract and Recruitment Industry body (ITCRA), an external dispute resolution scheme to which we belong http://www.itcra.com or to the Office of the Australian Information Commissioner http://www.oaic.gov.au/privacy/privacy-complaints
NOTE: The ITCRA Code and Dispute Resolution Rules do NOT constitute a recognised external dispute resolution scheme for the purposes of the Australian Privacy Policy but are primarily designed to regulate the good conduct of ITCRA members
9. REVIEW OF PRIVACY POLICY
Ccentric is committed to keeping our Privacy Policy up to date, and publishing these updates on all mediums. As such, this policy may change over time in light of changes to privacy laws, technology and business practice. If you regularly conduct transactions with us that involve the collection of your personal information, or regularly use our website it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.