This page explains how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs) and relates to information collected by Trak Search Pty Ltd (Trak Search). This page also explains the data flows associated with that information.
We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. We only collect information that is reasonably necessary for the proper performance of our recruitment activities. If we have no present need for personal information we do not collect it just because we think it could be useful at some future stage. We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.
If you have any questions please contact us
When we collect your personal information:
- we check that it is reasonably necessary for our functions or activities as a recruitment consultancy;
- we 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;
- we record and hold your information in our Information Record System. Some information may be disclosed to overseas recipients;
- we retrieve your information when we need to use or disclose it for our functions and activities as a recruitment consultancy. 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 APP:12 of the (APPs).
- we correct or attach associated statements to your personal information in accordance with APP:13 of the (APPs).
- 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. We do not destroy or de-identify information that is contained in a Commonwealth Record.
2. Kinds of information that we collect and hold
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 consultancy and is likely to differ depending on whether you are a job seeker; a client; or a referee.
For job seekers
The type of information that we typically collect and hold about job seekers is information that is necessary to assess amenability to work offers and work availability; or suitability for placements and includes:
- Documentation supplied to us directly by the job seeker, such as a resume; submissions and covering letters, such as those to address the selection criteria; applications forms; academic transcripts, qualifications and membership of professional bodies
- References obtained from a third-party after obtaining consent from the job seeker
The type of information that we typically collect and hold about clients is information that is necessary to help us manage the presentation and delivery of our services and includes:
- Documentation supplied to us directly by the client, such as annual reports; position descriptions; strategic plan; conditions of employment and remuneration information
- Information publicly available, such as accessed from the client’s website
The type of information that we typically collect and hold about referees is information that is necessary to help to make determinations about the suitability of a job seeker for particular jobs or particular types of work and includes:
- Referee contact information
- A written report containing information provided to us by the referee about the job seeker
The purposes for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are a job seeker; a client; or a referee.
For Job Seekers
Information that we collect, hold, use and disclose about job seekers is typically used for:
- work placement operations;
- recruitment functions;
- statistical purposes and statutory compliance requirements;
Personal information that we collect, hold, use and disclose about clients is typically used for:
- client and business relationship management;
- recruitment functions;
- marketing services to you;
- statistical purposes and statutory compliance requirements;
Personal information that we collect, hold, use and disclose about referees is typically used:
- to confirm identity and authority to provide references;
- for job seeker suitability assessment;
- for recruitment functions;
Personal information will only be used for marketing purposes in relation to recruitment projects being managed by Trak Search that could be of interest to the job seeker.
Primarily this will be a direct email to the job seeker as approved by the job seeker when registering with us via the ‘Sign Up for Job Alerts’ facility on our website. However it could also include providing email advice to a job seeker in relation to recruitment project being managed by Trak Search for a role which, based upon earlier communication with the job seeker, we believe would be of possible interest to the job seeker.
All such communication provides the job seeker with the option to opt out of such communications and complies with the requirements of the anti-spam legislation.
Personal information is not used for any other marketing purposes either directly by us or by a third party. We do not buy or sell lists of personal information.
4. How your personal information is collected
The means by which we will generally collect your personal information are likely to differ depending on whether you are a job seeker; a client; or a referee
We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.
Sometimes the technology that is used to support communications between us will provide personal information to us.
For Job Seekers
Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work.
Personal information is also collected when you:
- Provide a resume
- Lodge your details with us from our website registration facility;
- Use our ‘sign Up for Job Alerts’
Personal information about you may be collected when you provide it to us for business or business related social purposes.
Personal information about you may be collected when:
- you provide it to us in the course of our checking job seeker references with you;
- when a job seeker provides it to us to allow us to complete a reference with you;
- and when we are checking information that we obtain from you about job seekers.
Photos, Images & Sound Recordings
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. We do not retain any photo images in our Information Records System.
At times we will take a sound recording of a discussion or interview with a job seeker. This is only done with the consent of the job seeker, obtained in advance of the discussion, and is only used for the purposes of the specific recruitment activity for which it was obtained.
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 such as our job alerts system;
- register as a site user to access facilities on our site;
- make a written online enquiry or email us through our website;
- submit a resume by email or through our website;
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 Internet Communications and other Technologies
You can contact us by land line telephone or post if you have concerns about making contact via the Internet.
5. How your personal information is held
Personal information is held in our Information Record System 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.
Trak Search and our third-party providers take a range of measures to protect your personal information from misuse, interference and loss; and unauthorised access, modification or disclosure.
Our Information Record System
Our Information Record System has two core components:
- We use a third-party recruitment software specialist service-provider, based in Australia, to store and manage candidate and client information. They guarantee that they will take reasonable steps to ensure the security of your personal information. Their premises are in a secure building with access restricted to passcard holders. Their IT systems are password protected and they conduct regular audits and data integrity checks. They frequently update their anti-virus software in order to protect their systems (and the data contained in those systems) from computer viruses. In addition, all the service-provider’s employees are required, as a condition of employment, to treat personal information held by them as confidential.
- We use a third-party file hosting service, based overseas (in USA), which offers cloud storage and file synchronization software. A range of Trak Search information is retained in their cloud storage facilities, which is then accessible to us through password protected files and website. This service provider encrypts the files that we store with them using the AES-256 standard, which is the same encryption standard used by banks to secure customer data. This service-provider uses Amazon S3 for their data storage. Amazon stores data over several large-scale data centers using military grade perimeter control berms, video surveillance, and professional security staff to keep their data centers physically secure.
We may disclose your personal information for any of the recruitment activities for which it is primarily held or for a lawful related purpose. We may disclose your personal information where we are under a legal duty to do so.
Disclosure will usually be:
- internally and to our related entities
- to our clients
- to referees for suitability and screening purposes.
Related Purpose Disclosures
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:
- Software and systems solutions providers;
- I.T., technology contractors and database designers and Internet service suppliers;
- Legal and other professional advisors;
- Background checking and screening agents;
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.
Some of your personal information is likely to be disclosed to overseas recipients. Despite assurances given to us, we cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.
7. Access & Correction
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold. Important exceptions include evaluative opinion material obtained confidentially in the course of our performing reference checks; and access that would impact on the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that the person who gave us that information is entitled to expect will be observed. We do refuse access if it would breach confidentiality.
If you wish to obtain access to your personal information you should contact our Privacy Co-ordinator, Cherilyn Turner. You will need to be in a position to verify your identity.
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.
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.
If you are making a complaint about our handling of your personal information, it should first be made to us in writing.
You can make complaints about our handling of your personal information to our Privacy Co-ordinator, Cherilyn Turner.
You can also make complaints to:
- the Office of the Australian Information Commissioner ; and/or
- the RCSA which is the industry association of which we are a member.
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 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 any recognised external dispute resolution scheme to which we belong or to the Office of the Australian Information Commissioner