Last updated: February 2023
1. General
This Privacy Policy applies to all Personal Information collected by Minchin Recruitment Pty Ltd ABN 29 662 207 749 (Minchin, we or us). Minchin Recruitment is committed to complying with its obligations under the Act in respect of that information. In this Privacy Policy, we explain how and why we collect your information, how we use it, and what controls you have over our use of it.
Please read this Privacy Policy carefully. Your use of any part of our Website or Services will constitute your consent to the collection, transfer, processing, storage, disclosure and other uses of your Personal Information in accordance with this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not use our Website or Services.
This Privacy Policy is subject to change at our discretion. The current version will always be available on our website at https://minchinrecruitment.com.au/.
2. Definitions
In this Privacy Policy:
a) Act means the Privacy Act 1988 (Cth);
b) Minchin, we or us means Minchin Recruitment Pty Ltd ACN 662 207 749, a proprietary limited company incorporated in Australia and its associated entities as appropriate;
c) OAIC means the Office of the Australian Information Commissioner;
d) Personal information means information about you which personally identifies you or may reasonably be used to personally identify you and otherwise has the meaning given to that term in the Act;
e) Sensitive information has the meaning given to that term in the Act;
f) Services means the services that are to be provided by Minchin Recruitment, including without limitation the provision of recruitment and candidate placement services which may use our Website or third parties from time to time;
g) Website means https://minchinrecruitment.com.au/ or any other website from time to time from which the Services are promoted and/or delivered, including without limitation any third party websites; and
h) you means you and anyone acting on your behalf or with your implied authority.
3. What types of Personal Information do we collect?
We collect and hold various types of Personal Information, including:
a) personal details, including your name, gender, date of birth, place of birth and, if applicable, your electronic signature and identity verification information and related documents;
b) contact details, including your email address, telephone number, postal address and any other contact details that you provide to us as part of the Services;
c) information necessary for or incidental to the provision of the Services including information about the party requesting the provision of the Services by us to you (if applicable) and any documents or other information shared with us in connection with the Services;
d) information arising from or in connection with your use of the Services including without limitation your IP address, unique device identifiers, information about your information and other transactional data; and
e) any other Personal Information that may be required in order to facilitate your dealings with us.
4. How do we collect Personal Information?
We may collect Personal Information from you when:
a) you access, use or otherwise interact with our Services or our Website including through third party websites connected or integrated with our Services;
b) a person who accesses, uses or otherwise interacts with our Services or our Website including through third party websites connected or integrated with our Services, and provides your personal information to us for the purpose of us performing our Services at their request;
c) you communicate with our staff or representatives during the course of us providing you the Services;
d) we solicit it from, or it is provided to us by, any person connected with our provision of the Services to you; or
e) you otherwise deal with us in the course of our business.
Where we solicit Personal Information, we only collect:
a) non-Sensitive Information, if it is reasonably necessary for the Services we provide; and
b) Sensitive Information, if it is reasonably necessary for or directly related to Services we provide and you have consented to its collection, or its collection is permitted or authorised by law.
If we solicit Personal Information, we will generally solicit it directly from you, unless it is unreasonable or impracticable for us to do so. Where we collect Personal Information about you from a third party without your prior consent, we will take reasonable steps to inform you that we have collected Personal Information.
5. How do we store and protect Personal Information?
We prioritise the security of your Personal Information whilst it is in our possession. We may hold Personal Information in various forms, including without limitation physical documents, electronic records, visual records and audio recordings. Physical files are kept securely inside our access-controlled premises. Electronic files are stored securely on protected information systems and are only accessible through our secure network. We maintain physical security over our paper and electronic data stores, and confidentiality agreements form part of the employment contracts for all of our staff members and contractors.
We take reasonable steps to:
a) ensure that Personal Information we collect is accurate, up-to-date, complete and relevant, other than where it is only collected to provide advice in respect of a particular point in time, in which case we will seek to ensure it is accurate, complete and relevant as at that particular point in time;
b) ensure that Personal Information we use or disclose is accurate, up-to-date, complete and relevant, having regard to the purposes for which Personal Information is used or disclosed;
c) protect Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
d) destroy or de-identify Personal Information which we no longer need for the purposes for which it was collected, except where it is necessary to retain it in order to maintain ongoing records for our clients.
We cannot guarantee the security of information transmitted via the internet. As such, transmission of Personal Information via the internet is at your own risk and we cannot be held responsible for the security of such information. This includes transmission of your Personal Information to us from third parties via the internet.
Your use of, or the supply of your information to, third parties who supply us with information, or who we are required to supply information to, in connection with the Services is entirely at your own risk and we make no representations or warranties regarding third parties’ privacy practices.
6. Why do we collect, hold, use and disclose Personal Information?
We collect, hold, use and disclose Personal Information for the following purposes:
a) for the purpose(s) for which it was disclosed to or collected by us;
i. facilitating interactions with you in the course of operating our business;
ii. responding to your enquiries and information requests;
iii. providing services to our clients if it was validly collected for that purpose;
iv. storing information at third-party data centres;
v. updating your Personal Information;
vi. complying with our legal obligations;
b) for secondary purposes where it would be reasonable to expect us to do so, and that secondary purpose is related (or directly related in the case of Sensitive Information) to the primary purpose for which it was collected; and
c) for any other purposes for which you have consented from time to time.
The above purposes include using and disclosing your Personal Information:
a) to supply the Services to a third party;
b) to facilitate other interactions with you or a third party receiving the Services related to you in the course of operating our business;
c) to share your Personal Information to employees, contractors, subcontractors or other third party service providers of Minchin Recruitment to assist us with providing the Services;
d) to run analytics on the use of our Website and otherwise to improve our Website on an anonymised and de-identified basis;
e) to respond to your enquiries and provide you with relevant information;
f) to update your Personal Information;
g) to collect information required for reporting to relevant regulatory bodies (if required);
h) as permitted or required by law; and
i) for any other uses identified at the time of collecting your Personal Information.
We may disclose your Personal Information to such persons as is necessary to achieve the above purposes. This will often include disclosure to our related bodies corporate and third parties related to the Services, including without limitation:
a) potential and actual employers of you, your referees and other trusted third parties for the purpose of verifying your identity, experience, right to work, qualifications and background checks;
b) a professional association or registration body that has a proper interest in the disclosure of your Personal Information; and
c) prospective employers in the course of seeking to refer you for suitable employment opportunities in connection with the Services.
We may use or disclose Personal Information for secondary purposes where it would be reasonable to expect us to do so, and that secondary purpose is related (or directly related in the case of Sensitive Information) to the primary purpose.
Unless you inform us that you opt out, we may use your Personal Information for the purposes of sending you direct marketing publications, including via telephone, mail, email, SMS or social media. You may opt-out of receiving marking communications from us by contacting us at the details below or by using the opt-out facilities provided in our communications. However, we will not disclose your Personal Information for the purposes of third-party direct marketing without your consent.
7. Overseas disclosure
It is unlikely that we will need to disclose your Personal Information to an overseas recipient or otherwise store your Personal Information overseas. If we do need to do so, this will generally be limited to third party providers of services such as website hosting, data storage, electronic communications and data analysis. Any such disclosure will be done in accordance with the Act.
We will attempt to ensure that persons to whom the disclosed Personal Information relates have comparable rights in relation to that information once disclosed overseas.
8. Using our website and cookies
To improve your experience on our website, we may use ‘cookies’, being small data files that are served by our Website and stored on your device. These are used by us or third parties for a variety of purposes including to operate and personalise the Website. Cookies may be used for recording preferences, conducting internal analytics, conducting research to improve our offering, assisting with marketing and delivering certain Website functionality.
You may refuse to accept cookies by selecting the appropriate setting on your internet browser. However, please note that if you do this, you may not be able to use the full functionality of our Website.
9. Third parties
Minchin Recruitment’s website may contain links to websites of third parties that may be of interest to you. Third party websites are responsible for their own privacy practices, and you should review their respective privacy policies and terms of use. We make no representation as to the accuracy or completeness of the information contained on third party websites.
Minchin Recruitment is not responsible for such third parties or any associated websites or resources that are connected with them. If you access such websites or resources, you do so at your own risk and we make no representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy policies of every such third party, associated website or resource that you use or that your information is provided to.
If our Services are linked to or integrated with a third party or their associated website or resource, this does not automatically imply that Minchin Recruitment endorses that associated website or resource and their contents.
10. Data Retention
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where we anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.
11. How you can access or correct Personal Information
We are committed to maintaining accurate, timely, relevant and appropriate information.
Where requested, we will provide you with a copy of the Personal Information that we hold which relates to you, provided that the request is made in accordance with the APPs (contained in the Act). We will also update any inaccurate information about you if you inform us that the information is inaccurate, out of date, incomplete, irrelevant or misleading.
There are no charges for requesting access to or the correction of your Personal Information, however if the volume of information we hold is excessively large, we reserve our rights to charge you any reasonable administration fees (including fees for photocopying) associated with your request.
You may contact us to access your Personal Information or to correct inaccurate, out-of-date, incomplete, irrelevant or misleading Personal Information by:
- Email: hello@minchinrecruitment.com.au
- Phone: +61 7 3733 3544
We will respond to those requests within a reasonable period in accordance with our obligations under the Act. If we refuse a request to access or correct Personal Information, where reasonable, we will provide our reasons for doing so and information about your ability to complain about such refusal.
In order to protect the confidentiality of your Personal Information, details of your information will only ever be passed on to you where we are satisfied that the information relates to you. Accordingly, we may request documentation from you which confirms your identity before passing on any Personal Information which relates to you.
12. Making a complaint
Complaints about our Privacy Policy or our collection, use, disposal or destruction of your Personal Information should first be directed to us at the details set out above.
We will investigate and attempt to resolve your complaint in accordance with the Act. If you are not satisfied with the outcome of this process, then you may contact the OAIC.
13. Privacy Policy changes
We may change this Privacy Policy at our discretion. If we do so, the latest version of our privacy policy will be available on our Website and it will apply to all your Personal Information held by us at that time.
Further information
If you require any further information or have any queries regarding our Privacy Policy, please contact us at the details set out above.
Should you wish to read more information on the Act, we recommend that you visit the website of the OAIC at www.oaic.gov.au.
