Sirius People and its offices and related companies (“we,” “our” or “us”) is a recruitment consulting service in Australia. The purpose of this policy is to support our compliance with the Australian Privacy Principles, and to encourage positive relationship building with our candidates, customers and clients.
We are strongly committed to protecting your privacy when you interact with us and our services. We will only collect, store and manage information that is directly related to our business and the proper performance of our tasks and functions. We do not collect or use personal information for the purposes of unlawful discrimination.
To meet your expectations about privacy and confidentiality, Sirius People has procedures that comply with the:
- Australian Privacy Principles (APP) under the Privacy Act 1988 (Cth)
- Privacy Amendment (Enhancing Privacy Protection) Act 2012 and any of its amendments
- Privacy Amendment (Notifiable Data Breach) Act 2017 (Cwth) and any of its amendment
- Privacy Regulations 2013
- Australian Privacy Principles (APP)
This policy applies to information collected by Sirius People (ACN: 141 440 208) and all its related entities.
For any further inquiries, please feel free to contact us at: firstname.lastname@example.org.
By submitting your personal information through a phone call, face-to-face meeting, online via email, on our website, or through third party job boards, such as seek.com.au or indeed.com, you consent to the use and disclosure of your information as set out in the policy following.
2. Collection and use of personal information
‘Personal information’ refers to information about you from which your identity is either clear or can be reasonably determined.
We only collect personal information that is reasonably necessary for the proper performance of our activities or functions, including but not limited to the type of services you request or use, and any applicable legal and regulatory obligations. We only collect sensitive information (i.e. medical history, criminal history) that is necessary to fulfil our requirements and with the individual’s consent.
This may include, but is not limited to, collection and use of the following kinds of information:
- Contact information that allows us to communicate with you;
- Identity information that allows us to identify you;
- Professional information to help us understand more about your education, employment history, qualifications, talents, skills and abilities;
- Financial information that allows Sirius People to pay you, should you be engaged as an employee or contractor;
- Criminal record check results, if required by law;
- Any information requested or provided about a candidate from a referee;
- Any information found on a range of publicly available sources, including newspapers, journals, directories, the Internet and social media sites; and
- Immigration information that allows us to verify your working rights in Australia.
When we collect your personal information:
- We check that it is current, complete and accurate. This may include cross checking the information that we collect from you with third parties;
- We record and hold your information in our database;
- We retrieve your information when we need to use or disclose it as part of our services or functions;
- You may request access to your personal information in accordance with APP 12, apart from the exceptions outlined;
- We may correct or attach associated statements to your personal information in accordance to APP 13;
- We require our employees, contractors (some of whom are overseas) and suppliers to respect the confidentiality of any personal information held by Sirius People.
- 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.
While we follow standards to protect personal information, no method of storage or transmission is 100 percent secure.
Please note, if you choose to not give us all or part of the information we require:
- 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;
- We might decline to represent you in your research for work or put you forward for particular positions.
3. Disclosure of personal information
Sirius People may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted. We may disclose your personal information where we are under a legal duty to do, including circumstances where we are under a contractual or lawful duty of care to disclose information.
Generally, we will only use and disclose your personal information for the following purposes:
- To provide our services to you;
- To maintain our business relationship, where you are a user of our website, a client, candidate or supplier;
- To enable you to submit your CV generally, to apply for specific jobs, or to otherwise subscribe to our services (i.e. Job Alerts, Candidate Portal, email sign-up for downloadable assets or for event alerts, etc.);
- To match your candidate profile with job vacancies, to assist us in finding a role that is most suitable for you, and to send your personal information to clients to apply for roles, provided you have first consented to this;
- To answer your query;
- To direct market products and services, advise you of news and industry updates, events, promotions and competitions, reports, APSCo updates and other information.
- To tailor our website when you log on to make it more relevant to you personally;
- To provide to trusted third parties, who can assist with services requested, such as psychometric evaluations or skills tests, and those who provide services to us, such as professional advisers, IT consultants, and offshore contractors. These third parties must comply with privacy and confidentiality, as outlined by our contracts with them;
- If Sirius People merges with or is acquired by another business, we may share personal information with the new owners of the business. If this occurs, you will be sent a notice;
- If required, we may release personal information to regulatory or law enforcement authorities; and
- We may also seek your consent to collect, hold, use and disclose your personal information for any other purpose not listed above.
Sirius People will not sell, assign or rent your personal information.
4. Third Party Suppliers
We outsource a number of services to contracted service suppliers (CSP) from time to time. Our CSPs may see some of your personal information, including:
- IT contractors, database designers, service internet service suppliers, some of whom may be offshore;
- Legal and other professional advisors;
- Insurance brokers, loss assessors, and underwriters;
- Superannuation fund managers;
- Background checking and screening agents;
- Psychometric and aptitude testing providers;
- Pre-employment medical advisors;
- Payroll agencies, for the purpose of making payment to you; and
- Workers Compensations Bodies.
We take reasonable steps to ensure that the 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.
5. Direct Marketing
Sirius People may use your personal information to inform you of services or events that may be of interest you. Personal information may be used to contact you for the purpose of providing recruitment services, either directly or by a third party. This includes via email, SMS, MMS, telephone, or other electronic means, with your express or implied consent.
In the event you do not wish to receive such communications, you can opt-out by contacting Sirius People at email@example.com, by speaking to your recruitment consultant, or through any opt-out mechanism contained in a marketing communication to you.
6. Accessing your personal information
You have the right to request access to the personal information we hold about you. Sirius People will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type(s) of information requested.
Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your access to information request, including but limited to circumstances where:
- Access would pose a serious threat to the life or health of any individual;
- Access would have an unreasonable impact on the privacy of others;
- Access would breach any confidentiality attached to that information;
- The information relates to a commercially-sensitive decision-making process;
- The information relates to existing or anticipated legal proceedings between the entity and the individual, and would not be accessible by the process of discovery in those proceedings; and
- Giving access would be unlawful.
If you wish to obtain access to your personal information, you should contact our Privacy Officer. You will need to verify your identity. You should also anticipate that it will take up to 3 months to process your application for access, as there many be a need to retrieve information from storage and review the information requested. We will generally respond to your request for access within 20 working days.
7. Updating and correcting your personal information
We rely on you to tell us when there are changes to your personal information, such as a change of address or employment status.
If Sirius People holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, the company will take reasonable steps to correct the information.
You may request in writing to correct any personal information to the Privacy Officer, of which Sirius People will respond to within a reasonable period.
There are certain circumstances in which Sirius People may refuse to correct personal information. In these instances, we will give you written notice in accordance with APP 12 that outline:
- The reasons for the refusal; and
- The mechanisms available to you to make a complaint.
If Sirius People has previously supplied personal information to a third party and you request us to notify the third party of the correction, we will take reasonable steps to give that notification, unless impractical or unlawful to do so.
8. Information Security
We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed.
Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent unauthorised or inadvertent access, modification or dissemination.
We will only request that you supply and scan photo ID, where we require proof of identity and workers’ rights for our records.
Some video and images may be captured and retained from any events held at our offices or at offsite locations.
In accordance with the Privacy Amendment (Notifiable Data Breaches) Act 2017 (NBD Act) and the Privacy Act 1988 (Cth), Sirius People will notify any individuals whose personal information has been subject to a data breach likely to result in serious harm, as outlined by the Office of the Australian Information Commission (OAIC). Eligible data breaches are defined by the OAIC as:
- There is unauthorised access to or unauthorised disclosure of personal information, or a loss of personal information, that an entity holds;
- This is likely to result in serious harm to one of more individuals; and
- The entity has not been able to fully prevent the likely risk of serious harm with remedial action.
9. Website Security
When an individual looks at our website, our internet service provider, Google Analytics and content management system makes a record of the visit and logs (in server logs) the following information for statistical purposes:
- The individual’s server address;
- The individual’s top level domain name (i.e. .com, .gov, .org, etc.);
- The pages the individual accessed and documents downloaded;
- The previous site the individual visited; and
- The type of browser being used.
We do not identify users or their browsing activities, except in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s server logs.
Submitting your CV
You may submit your CV to Sirius People via this website, either for general consideration or through specifically advertised roles. Once submitted, your CV will be sent directly to the relevant Sirius People recruitment consultant, who will review your details and will be in contact with you for roles relevant to your skill set. Your CV and relevant details will be stored in our central database, and can be accessed by any of our recruitment consultants working in other offices of Sirius People. You can update your CV at any time through resubmission or by updating it through our Candidate Portal.
Should you choose to sign up to Job Alerts, you will need to provide your email address. If you no longer wish to receive Job Alerts, unsubscribe links are available in every Job Alert email body that you receive.
You may also choose to sign up for our Candidate Portal, which allows you to directly manage any job applications you place, any job alerts you signed up for, and update select information we have on you in our central database. Please note that if you wish to deactivate your Candidate Portal, you will need email our Privacy Officer, who will delete your profile from our database. If you request us to delete your profile, you will no longer be considered for any job applications you may have submitted.
You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. Please notify us immediately if there is any unauthorised use of your account by any other internet user or any other breach of security.
Externally linked sites
Our websites may contain links to other websites, applications and services maintained by third parties. The information practices of such other services are governed by third party privacy statements, which we encourage you to review to better understand those third parties’ privacy practices.
If you have any questions about the security of our websites, please contact our Privacy Officer.
10. Lodging a complaint
You have the right to complain about Sirius People’s handling of your personal information, if you believe the company has breached the APPs. If you wish to make such a complaint to Sirius People, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with the company’s complaints procedure and the company will provide a response within a reasonable period.
If Sirius People takes longer than 30 days to respond to your privacy complaint, or if you are dissatisfied with the outcome, you can make a complaint to the Privacy Commissioner at the OAIC. The OAIC can be contacted at 1300 363 992 or www.oaic.gov.au.
11. Changes to this policy
12. How to contact us
Contact information: firstname.lastname@example.org
Sirius People, Privacy Officer
Level 3, 45 Clarence Street,
Sydney, NSW, 2000
Tel: +61 (0) 2 9270 5200