Privacy Policy
1. Introduction
We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APPs). This policy applies to information collected by Galvin-Rowley Pty Ltd (“Galvin-Rowley ”).
At Galvin-Rowley, we only collect information that is reasonably necessary for the proper performance of our activities or functions.
We do not collect personal information just because we feel it could be useful at some future stage, and if there is no need for it now. We may decline to collect unsolicited personal information from, or about you, and take steps to purge it from our systems.
By reading below you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs). You will also be able to find out about the information flows associated with that information.
If you have any questions, please contact us www.galvinrowley.com.au
1.1. APP Entity
2. Information Flow
When we collect your personal information:
we check that it is reasonably necessary for our functions or activities as an employment agency and/or firm;
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/CRM database. We retrieve your information when we need to use or disclose it for our functions and activities. 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, particularly 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. Types 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 an employment agency/firm and is likely to differ depending on whether you are:
a Job Seeker;
a Client;
a Referee.
2.1 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; suitability for placements; or to manage the performance in work obtained through us and includes:
general contact and identification details (e.g. name, address, email address and phone number);
information about your education and work history, qualifications and skills;
opinions of others about your work performance (whether true or not), which will only be collected with your consent;
information about your work rights and your eligibility to work within Australia which may include details, copies or presentation of the originals of any applicable visa, passport, birth or citizenship certificate, or other relevant documentation;
sensitive information (e.g. information about your health, medical history or specific condition, criminal record, professional memberships etc.), which will only be collected with your consent;
any results of relevant tests in which you participate;
your tax file number and relevant bank and superannuation account information necessary to facilitate the payment of wages and superannuation contributions and to ensure 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.
2.2 For Clients
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:
general contact and identification details (e.g. name, address, email address and phone number);
details of your current and past employment;
your opinion of prospective of potential and/or successfully placed candidates
your opinion of employees at Galvin-Rowley Pty Ltd and/or services
2.3 For Referees
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 one of our Job Seekers for particular jobs or particular types of work and includes:
general contact, verification and identification details (e.g. name, address, email address and phone number);
details of your current and past employment;
your opinion of prospective of potential and/or successfully placed candidates
3. Purposes
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;
a Referee.
The following sections are also relevant to our use and disclosure of your personal information:
Our Policy on Direct Marketing
Overseas Disclosures
3.1 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;
3.2 For Clients
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;
3.3 For Referees
Personal information that we collect, hold, use and disclose about Referees is typically used for:
to confirm identity and authority to provide references;
Candidate suitability assessment;
recruitment functions.
3.4 Our Policy on Direct Marketing
From time to time your personal information may be used by Galvin-Rowley to inform you about:
job vacancies:
market and industry news:
relevant promotions.
Galvin-Rowley complies with the anti-spam laws of Australia: The Spam Act 2003.
We will include ‘Unsubscribe’ links in all mass email campaigns. Anyone who opts out will not be contacted again. At any time should you wish to change your preference in relation to receiving direct marketing please contact us.
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
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 – see the section in this policy on Electronic Transactions.
See also the section on Photos & Images.
4.1 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 submit an application form or your resume through a third party website;
we interview you either over the phone, video conference, SKYPE (or related) or in person
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 receive any complaint 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; and
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.
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 APPs and our Privacy Policy.
4.2 For Clients
Personal information about you may be collected:
when you provide it to us for business or business related social purposes;
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 APPs and our Privacy Policy.
4.3 For Referees
Personal information about you may be collected when you provide it to us:
in the course of our checking Job Seeker references with you and when we are checking information that we obtain from you about Job Seekers;
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 APPs and our Privacy Policy.
4.4 Photos & Images
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. 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.
4.5 Electronic 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 such as a job notification list;
register as a site user to access facilities on our site such as a job notification board;
make a written online enquiry or email us through our website;
submit a resume by email or through our website;
register as a site user to use our online timesheet and payroll portal
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 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.
We take a range of measures to protect your personal information from:
misuse, interference and loss; and
unauthorised access, modification or disclosure.
5.1 Our Information Record System
Our Information Record System is a recruitment CRM system that stores data electronically. Information is stored on a server in a secure data room in our Hawthorn East office in Australia.
Any physical records of your information are securely stored in on Galvin-Rowley’s premises in Hawthorn East, Australia.
5.2 Information Security
All electronic data is protected by multi layer security systems both physical and online including IPS, authentication and firewalls.
Physical personal information is stored with restricted access and is shred upon disposal.
6. Disclosures
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 and to our related entities
to our Clients
to Referees for suitability and screening purposes.
6.1 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 solutions providers;
I.T. contractors and database designers and Internet service suppliers;
Legal and other professional advisors;
Insurance brokers, loss assessors and underwriters;
Superannuation fund managers;
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.
6.2 Cross-Border Disclosures
At this stage, Galvin-Rowley does not currently store any information, personal or otherwise overseas. Should this change, we acknowledge that 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, before we disclose your information.
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.
For more information about access to your information see our Access Policy.
For more information about applying to correct your information see our Correction Policy.
7.1 Access Policy
If you wish to obtain access to your personal information you should contact our Director, Jennifer Galvin-Rowley at jen@galvinrowley.com.au. Additionally you will need to be in a position to verify your identity.
Requests to access to your personal information will be acknowledged within 5 working days
Where possible such access will be granted within 30 working days. In the event there are circumstances restricting access within this time frame Galvin-Rowley will advise you of these restrictions and communicate the revised timeframe
7.2 Correction Policy
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.
Requests to correct to your personal information will be acknowledged within 5 workings day
Where possible such access will be granted within 30 working days. In the event there are circumstances restricting your information being corrected within this time frame, Galvin-Rowley will advise you of these restrictions and communicate the revised timeframe.
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.
8.1 Complaints procedure
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 Jennifer Galvin-Rowley, Director.
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 (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.
