Last updated 2018
This Privacy Policy is provided by Sterling Healthcare Resourcing PTY. LTD. (the Company) and applies to information about the collection, use and disclosure of personal information by the Company. In this Privacy Policy, “we/our” refers to the Company, and and “you/your” refers to the Candidate or other relevant individuals (such as Emergency Contact Person) connected with the Candidate.
In this Privacy Policy, a reference to the Privacy Act 1988 includes amendments to the Act, including the Privacy Amendment Act 2013 which introduces the Australian Privacy Principles.
Personal information that we collect and hold
Personal information that we collect, hold, use and disclose about Candidates is typically used for work placement operations (such as to assess amenability to work offers, work availability, and suitability for placements), recruitment functions (such as to facilitate payment of wages and superannuation contributions and to ensure appropriate taxation treatment, to manage the performance in work obtained through us), statistical purposes and statutory compliance requirements, and includes (but not limited to):
- general contact and identification details (e.g. name, address, email address and phone number);
- sensitive information (e.g. date of birth, information about your health, medical history or specific condition, criminal record, record of you or your practice with medical authorities in and outside of Australia, etc.), which will be collected with your consent;
- information about education, work history, qualifications, skills, and any professional licenses;
- information about your work rights and your eligibility to work in Australia which may include details, copies or presentation of the originals of any applicable visa, passport, birth or citizenship certificate, or other relevant documentation;
- opinions of others about your work performance (whether true or not), which will only be collected with your consent;
- your tax file number and relevant bank and superannuation account information necessary to provide you with optional value-add services such as facilitating the payment of wages and superannuation contributions, and ensuring appropriate taxation treatment;
- driver’s licence number and relevant information about your driving history or infringements and any other applicable licences and certificates; and
- other information relevant in the circumstances.
When we collect your personal information:
- we check that it is reasonably necessary for our functions or activities as a recruitment agency and, with your consent, for providing value added services for our Candidates;
- 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 systems.
Additional personal information will also be collected, either directly from you or by third parties such as previous employers and nominated referees, during the course of your employment to manage your ongoing employment relationship. Examples may include time attendance, leave requests, medical certificates, performance appraisals, etc.
How we collect your personal information
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, we collect personal information that individuals choose to give us via technology that is used to support communications between us (such as email, telephone, online forms etc.), for example when individuals:
- ask to be on an email list such as a job notification list;
- register as a website user to access facilities on our website such as a job notification board;
- make a written online enquiry or email us through our website;
- submit a CV by email or through our website;
- register as a site user to use our online timesheet and payroll portal.
If you provide us with an email address, you consent to electronic communications being sent to you via that email address, including notices, reminders, and occasional marketing communications. To protect your privacy, we recommend that any email address you provide to us be your personal email address rather than, for example, an email address accessible by your work colleagues or family members. You have the option to opt out of marketing communications at any time.
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, as well as when:
- you submit an application form or your resume through a third party website;
- we interview you either over the phone, video conference or in person;
- we receive results from AHPRA in regards to your current medical registration status;
- we undertake reference checks by inquiring with, or we otherwise receive references or performance feedback (whether negative or positive) from, any of your former or current employers, work colleagues, professional associations or registration bodies (reference checks are only undertaken with your consent);
- we receive results of any medical tests or criminal history checks, (which are only undertaken with your consent);
- we receive results from any competency tests in which you participate;
- we are notified either verbally or in writing any concerns or complaint about performance or conduct that arise from or about you in the workplace;
- we receive information from your employer in relation to your employee benefits including rate or remuneration
- we receive information about a workplace accident in which you were involved;
- we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were or are involved during, or in connection with, a work placement; and
- you provide us with any additional information about you.
We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APP and our Privacy Policy. In the event we retain photos or images of you for use in the recruitment process, they will be retained unless you request they be destroyed.
How we hold your personal information
Personal information is held in our information systems to include software and digital storage, 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 a reasonable range of measures to protect your personal information from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
Our information systems store and process data electronically, and include recruitment CRM system, accounting and invoicing system, telephone and electronic messaging system, emails, and digital file storage. All information is stored electronically on highly secured servers which may be physically located both inside and outside of Australia. We do not store physical records of your information.
All electronic data is protected by robust data protection and security policy by our information systems providers, and proper user access level management further ensure that only authorised members of the Company have the required level of access to the information in these systems.
How we use your personal information
Your personal and sensitive information may be used in connection with:
- informing you of possible work opportunities or other events such as training or information sessions;
- your actual or possible work placement;
- undertaking qualifications assessment, professional reference checks, criminal reference checks, and other background checks that are required in order for us to put forth applications for your potential work placement;
- any test or assessment (including medical tests and assessments) that you might be required to undergo;
- career guidance or management;
- your performance appraisals;
- our assessment of your ongoing performance and prospects;
- our identification of your training needs;
- providing value added services such as management of timesheets and payment of wages, superannuation contribution and tax treatment (only with your consent);
- our management and resolution of any complaint, inquiry or investigation in which you are involved;
- any insurance claim or proposal that requires disclosure of your personal or sensitive information;
- research, development, business systems and infrastructure testing and other business purposes to assist us in providing our services to you;
- our direct marketing to you.
Your personal and sensitive information may be disclosed to:
- Potential and actual employers, our Clients, and trusted third party service providers including our insurers
- Our team members
- Referees as advised and consented by you
- External training providers and background checking agencies
- A professional association or registration body that has a proper interest in the disclosure of your personal and sensitive information
- A Workers Compensation body
- Any person with a lawful entitlement to obtain the information
If you do not give us the information we seek:
- 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; and
- we may be limited in our ability to provide value added services to you.
How we disclose your personal information
We may disclose your personal information for any of the purposes 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 within the Company and to our related entities;
- to our Clients for purposes such as employment records and payment of your services;
- to referees for suitability and screening purposes; and/or
- to any other third parties such as state health authorities or any other authorities that require such information under law.
Where there are needs for the Company to engage third party service providers to support our business operations and functions, your personal information may be visible such as to:
- Software solutions providers
- Internet service providers
- Legal and other professional advisors
- Insurance brokers, loss assessors and underwriters
- Superannuation fund managers
- Background checking and screening agents
- Providers of our online timesheet and payroll portal
We take reasonable steps to ensure that terms of service with our third party service providers 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.
Access to and correction of your personal information
Subject to some exceptions set out in the privacy law, you may request to 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 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.
You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. Complaints will be handled in accordance to our complaint management procedure.
Please contact us on info@sterlingresourcing.com.au if you have any questions about this Privacy Policy.