1. Introduction:

At Pinnacle People, safeguarding your personal information holds significant importance. We are wholeheartedly dedicated to upholding your privacy with the utmost respect and vigilance.

Our Privacy Collection Statement explains how we collect personal information and how we maintain, use and disclose that information. It also provides some details about your privacy rights, along with our general rights and obligations in relation to the personal information we collect.

1.1 From time to time Pinnacle People (ABN: 813 790 665 06) ("the Company") is required to collect, hold, use and/or disclose personal information relating to individuals (including, but not limited to, candidates, clients, suppliers, referees, contractors and employees) in the performance of its business activities.

1.2 This document sets out the Company’s policy in relation to the protection of personal information, as required under the Privacy Act 1998 (Cth) (“the Act”) and the Australian Privacy Principles (“APP”).

1.3 The APPs regulate the handling of personal information and will guide the Company’s collection, holding, use and disclosure of personal information.

1.4 Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from that information or opinion.

2. Who we collect information from:

The type of information that we typically collect and hold will vary depending on our relationship with you. These relationships are generally categorised as:

2.1 Candidates: include all individuals who approach us, or who are engaged by us in the process of seeking or performing work with us or our clients.

2.2 Clients: include all individuals/companies who we deal with for the purpose of providing recruitment solutions and services for their business.

2.3 Referees: include all individuals who we contact in evaluating our candidates’ capabilities and suitability for employment.

2.4 Suppliers: if you are a supplier of the company, we may collect and hold information including your name, address, email address, contact telephone number, business records, billing information, information about goods and services supplied by you.

2.5 Participants: include all individuals to whom career transition services, career management services, change programs, coaching, human resources and/or other services are provided to by our consulting companies.

2.6 Employee Records: This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record. An employee record is a record of personal information relating to the employment of an employee. Examples of personal information relating to the employment of the employee include, but are not limited to, health information and information about the engagement, training, disciplining, resignation, termination, terms and conditions of employment of the
employee.

3. What type of information we collect:

3.1 Candidates

If you are a candidate we collect your personal information as reasonably necessary for us to determine your suitability for work with us or for our clients. The main types of personal information we collect about you as a candidate are:

a) your name and contact details, including your address, email address and phone numbers;
b) your date of birth;
c) your gender;
d) your nationality;
e) information in your cover letter, resume and application forms including your skills, qualifications, certificates, licenses, work history, references, goals and interests;
f) details of your work rights in Australia and other countries;
g) your tax file number and tax declaration and superannuation details;
h) information documenting your work history with or through us (including bank account details, salary, work performance information and salary sacrifice documents);
i) aptitude and psychological assessment results;
j) the results of police checks, working with children checks or other background checks;
k) medical history, reviews or assessments of you;
l) emergency contact;
m) other information that you, your referees or our clients provide to us, including personal feedback and notes of our interactions with you and/or others in relation to your suitability for work with us or for our Client.

3.2 Clients

If you are our client we collect and/or hold information that is reasonably necessary for us to provide the best recruitment solutions and/or services for you and your business needs. The main types of information we collect and/or hold about you as our client are:

a) contact details including your name, address, email address, and telephone numbers; gender, date of birth;
b) details of your job title/description and organisational needs;
c) records of our interaction with you and any confidential and - non confidential feedback you may give us regarding our candidates, employees and/or services.

3.3 Referees

If you are a referee we collect information that is reasonably necessary for us to determine a candidate’s suitability for work with us or for our client. The main types of information we collect about referees are:

a) your contact details including your name, address and telephone numbers; email address;
b) details of your job title/description, where you knew/know the candidate from;
c) your current employment information and any professional opinion you have about the candidate.

3.4 Participants

If you are a participant we collect information that is reasonably necessary for us to provide you career transition services, career management services, change programs, coaching or other services provided by our consulting companies. The main types of personal information we collect about you are similar to the information we collect about candidates outlined in clause 3.1 of this statement.

3.5 Sensitive information is a special category of personal information. We do not actively seek to collect sensitive information unless it is necessary for our business purposes. If we do have to collect sensitive information, we will do so in accordance with the APPs. Sensitive information will, in most cases, only be disclosed with your consent .It includes information or an opinion about your:

a) racial or ethnic origin;
b) political opinion;
c) membership of a political association or religious beliefs, affiliations or philosophical beliefs;
d) membership of a professional or trade association or membership of a trade union;
e) sexual preferences  or practices;
f) criminal record
g) health or disability (at any time);
h) expressed wishes about future provisions of health services.

3.6 Unsolicited personal information is personal information that the company receives which it did not solicit.

3.7 Anonymity and Pseudonymity: You have the option of not identifying yourself, or using a pseudonym, when dealing with the company in relation to a particular matter. This does not apply:

a) where the company is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves;
b) where it is impracticable for the company to deal with individuals who have not identified themselves or who have used a pseudonym. However, in some cases if you do not provide the company with your personal information when requested, the company may not be able to respond to your request or provide you with the goods or services that you are requesting.

4. How your information will be collected

4.1 Candidates

If you are a candidate the ways in which we will be collecting information about you are when; [including personal and sensitive information]:

a) directly from you if it is reasonable or practicable to do so;
b) from third parties, including but not limited to: from past and present employers and referees when conducting reference checks, candidates after completing an interview, clients of the company and contract management services in relation to assignments;
c) when you attend an interview with one of our staff members. At this time you will complete our application paperwork or any other information in connection with your application to us;
d) we receive any reference about you;
e) we receive results of inquiries that we might make with your former employers, work colleagues, professional associations or registration body;
f) we receive the results of your work rights status;
g) we receive the results of any competency or medical test;
h) we receive performance feedback (whether positive or negative);
i) we receive any complaint from or about you in the workplace;
j) we receive any information about a workplace accident, injury, near miss, and/or illness in which you are involved;
k) we receive a response from a job advertisement – either written, verbal or email; we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
l) you provide us with any additional information about you.

4.2 Clients

If you are a client the ways in which we collect information about you are when:

a) we meet you or communicate with you in any way.
b) when you provide your opinion or feedback regarding one of our candidates.

4.3 Referees

If you are a referee the ways in which we collect personal information about you are when:

a) a candidate provides us with your contact details and informs us that you have consented to such collection.
b) when we take notes of our dealings with you including your opinions of the suitability of a candidate for work with or through us.

4.4 Participants

If you are a participant the ways in which we collect personal information about you are when you:

a) complete a survey or form requesting information from us.
b) either apply or are put forward for career transition services, career management services, change programs, coaching or other services provided by our Consulting Companies.
c) otherwise provide us with personal information in person or via telephone, email, fax, post or other means, whether at our request or at your own initiative.

4.5 General – Applicable to all categorises outlined in clause 2 of this statement.

a) through Associates and industry connections of the Company.
b) through publically available information sources (which may include telephone directories, the internet and social media sites).
c) direct marketing database providers.
d) by email or other written mechanisms;
e) telephone calls;
f) through transactions;
g) through our website and surveillance cameras;
h) by technology that is used to support communications between us.

4.6 Visiting our web site & online

a) You can visit our web site and browse without the need to disclose any personal information. Each time you visit our web site statistical data is collected. This data is not linked to a particular person and does not provide us with any personal information.
b) When you visit the Pinnacle People web site, we record anonymous information such as the date and time of your visit, the server/IP address, which site was visited and the information viewed and/or downloaded.
c) The information gathered cannot be directly matched to an individual and is only used for administration and statistical purposes such as error logging; it can only tell us about how you used our web site. This information can help us determine what areas of our web site are most beneficial to our visitors. No attempt is made by Pinnacle People to identify users or their browsing activities.
d) If you visit the candidate section of the web site and register on-line for employment opportunities or visit the client resources site to register a vacancy, we do collect some personal information about you which you volunteer by filling in your details. The information required may include providing basic personal details such as your name, address, phone number and email address etc. You may also submit your resume or a position description. The information gathered at this point is stored in our database for retrieval and use by Pinnacle People staff only for the purposes for which it was intended. By submitting your personal information in this way, you acknowledge and accept our Privacy Collection Statement.
e) When submitting a time sheet via our web site, the information is transmitted directly to our payroll division, where it is only used for the intended purpose and is not disclosed to anyone outside the organisation except maybe for an applicable Host Employer. There is no collection of personal information until you have completed the time sheet and submitted it to Pinnacle People for processing.
f) We do not disclose any information gathered about your visit to our web site, or personal information that you provide through the candidate registration process, such as your name, address etc. to any other organisation outside Pinnacle People unless you give your express consent, or if we are required to do so by law.
g) At times you may forward an email to us via the email link in our web site. The information collected through this email will only be used for the purpose for which you have provided it. Your details will not be added to our database, unless specified by you, nor will we disclose or use your information for any other purpose, than the intended purpose.

5. Who will be collecting your personal and sensitive information?

Your personal and sensitive information will be collected by Pinnacle People for its own use and on behalf of other members of Pinnacle People, who might require access to your personal and sensitive information in connection with its recruitment services.

6. Use of your personal information

6.1 Candidates

Your information, including personal and sensitive information may be used in connection with:

a) recruitment functions;
b) your actual or possible work placement;
c) checking your work rights status with any government department or body (or their agents);
d) to undertake directly or through agent criminal reference checking with relevant government agencies;
e) payment for work completed on a temporary/contract /perm assignment;
f) follow up with you to offer you work or ascertain your availability for work;
g) your performance appraisals;
h) our assessment of your ongoing performance and prospects;
i) any test or assessment (including medical tests and assessments) that you might be required to undergo;
j) our identification of your training needs;
k) any workplace rehabilitation;
l) our management of any complaint, investigation or inquiry in which you are involved;
m) any insurance claim or proposal that requires disclosure of your personal or sensitive information;
n) to tell you about the other services that we may provide;
o) ensuring our internal business processes are running smoothly which may include quality assurance audits, quality and services evaluations, fulfilling legal requirements and conducting confidential systems maintenance and testing.

6.2 Clients

Personal information that we collect, hold, use and disclose about clients is typically used for:

a) client and business relationship management;
b) recruitment functions;
c) marketing services to you;
d) statistical purposes and statutory compliance requirements;
e) risk management.

6.3 Referees

Personal information that we collect, hold, use and disclose about referees is typically used for:

a) to confirm identity and authority to provide references;
b) candidate suitability assessment;
c) recruitment functions.

6.4 Participants

Your personal and sensitive information may be used in connection with (as relevant):

a) communicate with  and provide information requested by you 
b) outplacement or redeployment                                                     
c) provision of career management programs and associated services;
d) provision with services in connection with change programs;
e) executive coaching and associated services

6.5 Direct marketing

We may sometimes use personal information for marketing purposes but only in the following ways:

a) the company may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new goods and/or services being offered by the company).
b) we will contact you (where relevant) while you are registered with us with updates in relation to employment opportunities, market information and promotions from time to time;
c) we will contact clients with whom we have a relationship with market information and promotions from time to time.

When sending direct marketing material we will give you the option as to whether or not you wish to receive further marketing communications and we will remain compliant with anti-spam legislation. Personal information is not used by or disclosed to any third party for marketing purposes.

6.6 General – Applicable to all categories as outlined in clause 2 of this statement.

 a) customer service management.
 b) training and events.
 c) surveys and general research.
 d) business relationship management.

6.7 The company may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under law. For example, the company may be required or authorised to collect your Tax File Number, if you choose to provide it, by the Income Tax Assessment Act 1936 (Cth).

6.8 If you do not allow the company to collect all or some of the personal information we request, the company may not be able to achieve its purposes. For example, if you are a candidate the company may not be able to locate suitable work for you, or if you are a client the company may not be able to provide you with the product or service you are seeking.

6.9 Given the primary purpose of the company, if all or some of the personal information held is in relation to a candidate seeking employment for a specified role, task or function, it is taken that the candidate authorises the company to retain that personal information for the purposes of all possible future recruitment and ancillary purposes.If a candidate does not authorise the company to hold and utilise personal information for this purposes notification in writing should be provided to the company’s Privacy Officer whose details are outlined in clause 13 of this statement.

7. Disclosure of your information

7.1 Candidates

Your personal and sensitive information may be disclosed to;

• potential and actual employers and clients of Pinnacle People
• referees;
• other members of Pinnacle People, clients and third party service providers and suppliers located in Pinnacle Peoples nationwide locations. A list of these locations is available at: http://www.pinnaclepeople.com.au;
• a professional association or registration body that has a proper interest in the disclosure of your personal and sensitive information;
• our insurers;
• any government department or body (or their agents) to verify your work rights status;
  
• a designated, registered training provider in relation to training and personal development opportunities;
• any person with a lawful entitlement to obtain the information.

We will advise you of our intentions and gain consent before we refer your personal information to our clients for possible work opportunities.

7.2 Participants

Your personal information may be disclosed for the purpose for which it is collected. That is, generally, our consulting companies will only disclose your personal information for a purpose related to the provision of career transition services, career management service, coaching, change programs or other services. This may include disclosing your personal information to clients who may be your potential or actual employer. Our consulting companies may also disclose your personal information to the parties outlined in clause 6 of this statement.

7.3 Related purpose disclosures - Applicable to all categories as outlined in clause 2 of this statement.

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Such CSPs may be located overseas. As part of the outsourcing arrangement with a CSP, they may need access to some of your personal information

Typically our CSPs would include:

• software solutions providers;
• I.T. contractors and database designers and Internet service suppliers;
• legal and other professional advisors;
• financial institutions for payment processing, insurance brokers, loss assessors and underwriters;
• background checking and screening agents;
• talent marketplace platforms.
• marketing and communications agencies.
• Printers and distributers of direct marketing material.
• External advisors.

We take reasonable steps to ensure that terms of service with our CSPs recognise that we are bound by obligations under the Privacy Act to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligation

Once we establish and maintain an employment, staffing, client, participant or placement relationship with you, we use the data you provided to us, to comply with laws and regulations, including but not limited to employment law, tax and social security and national and international sanctions regulation compliance. For the purposes mentioned above Pinnacle People may transfer your personal data to other Pinnacle People entities that provide services on behalf of Pinnacle People. Personal data is information which can be used to identify you such as name, date of birth, identification number or other factors specific to your identity.

We may disclose your personal information for any of the purposes for which it is was collected, as outlined in clause 6 of this statement, or where it is under a legal duty to do so.

Disclosure will usually be internally, to related entities, candidates, referees, potential and actual employers and clients of the company, including overseas recipients.

8. If you do not give us the information we seek

You can refuse to provide us with your personal (including sensitive information). However if you do not give us this information, we may not be able to provide our services to you. For example, if you are a candidate we may be limited in our ability to locate suitable work for you.

9. How does Pinnace People protect the security of your information?

We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure.

We have a number of safety measures in place to protect your information. For example;

a) your personal information is stored in secured offices and in robust computerised databases which require a log in and password with two factor authentication to gain access. Pinnacle People use measures like firewalls, two factor authentication and anti-virus software Access to the database is only available to those who require such access.
b) Much of the personal information that the company holds is stored in the company’s information record system comprising of hard copy files and/or electronic files in the company’s ordinary IT systems. These may include cloud servers or servers of third parties.
c) Visitors to our premises are always accompanied by a member of staff for the duration of the visit.
d) All staff are bound by our privacy and confidentiality agreement/policy regarding company and customer information.
e) We use secure methods to destroy or de-identify personal information as soon as the law permits and provided that the information is no longer needed by us. When you advise us that you are no longer looking for work opportunities and therefore do not wish to be registered with us, we will de-identify your data base record and destroy your personal information, unless you advise us otherwise or unless it is a requirement by law such as retained tax/wages information.
f) Unsolicited personal information unless the company determines that it could have collected the personal information in line with the APP’s, or the information is contained within a commonwealth record, it will destroy the information to ensure it is de-identified.

10. You can gain access to your information to correct it if it is wrong

10.1 General

Subject to some exceptions which are set out in the APPs (APP 12 – Access and APP 13 - Correction), you have a right to see and have a copy of personal and sensitive information about you that we hold.

If you are able to establish that personal or sensitive information that we hold about you is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date.

If we are unable to agree that personal or sensitive information that we hold about you is accurate, complete and up-to-date, you may ask us to place with the information a statement by you that claims that particular information is not accurate, complete and up-to-date

If you wish to exercise your rights of access and correction you should contact our Privacy Officer, whose details are outlined in clause 14 of this statement.

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.

10.2 Candidates and referee opinions

If you are a candidate, information provided by referees or from clients about you is often given on a confidential basis. Accordingly, disclosing the opinions given by a referee or client may have an unreasonable impact on the privacy of those individuals. If referees or clients provide information about you on a confidential basis, you may not access this information, and we will not be able to share it with you without the consent of the referee or client (as applicable).

11. External sites

External sites that are linked to or from the Pinnacle People web site are not under our control and you are advised to review their Privacy Statement. Users should note there are inherent risks associated with the transmission of information via the Internet and you should therefore make your own assessment of the potential risk to the security of your information.

12. Changes to our privacy policy

If at any time our privacy policy changes, the updated details will always be available on our web site for your perusal. If at any time you have a question or concern regarding Pinnacle People and privacy, please contact our Privacy Officer.

13. How to contact us

If you have any questions in relation to privacy or wish to make an access request or a privacy complaint, please contact the Pinnacle People Privacy Officer on the details below during normal office hours 9.00am to 5.30pm Monday to Friday.

• Pinnacle People Privacy Officer
• Phone: 03 8624 1777
• Postal address: 390 Flinders Street Melbourne Victoria 3000
• Email: execsupport@pinnaclepeople.com.au

Our Privacy Officer will contact you within a reasonable time (not exceeding 30 days) after receipt of your
request or complaint to discuss your concerns and to outline options regarding how they may be resolved.

General information about privacy may be found at:
http://www.privacy.gov.au/ and http://www.oaic.gov.au/