Privacy Policy
anzuk Education Services PTY LTD ABN 19123730521

1. Introduction

We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This condensed policy applies to information collected by anzuk* Education Services PTY LTD. 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 think it could be useful at some future stage if we have no present need for it. We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems. By following the links in this document, 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.

1.1. APP Entity

anzuk* manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs). Because we are a contracted service provider to a range of Commonwealth, State and Territory government agencies, it sometimes becomes necessary for us to collect and manage personal information as an Agency under different privacy arrangements. If you wish to know whether this applies to you, please contact us.

1.2. Information Flow

When we collect your personal information:

we check that it is reasonably necessary for our functions or activities as an employment agency;
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. 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 an employment agency and is likely to differ depending on whether you are:

2.1. For Workseekers

The type of information that we typically collect and hold about Workseekers 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:

Candidate information submitted and obtained from the candidate and other sources in connection with applications for work;
Work performance information;
Information about incidents in the workplace;
Staff information;
Information submitted and obtained in relation to absences from work due to leave, illness or other causes;
Information obtained to assist in managing client and business relationships;
Photo identification;
Identification provided during registration as proof that you are who you say you are

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:

The mobile phone numbers and email addresses of contacts on each client site
Feedback given on selected candidates that have worked on a client site
Booking history of candidates
OHS policies and procedures
Various site details and
Preferred candidate lists

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 Workseekers for particular jobs or particular types of work and includes:

Contact numbers and contact details and
Declarations on the suitability for temporary and contract work of 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:

The following sections are also relevant to our use and disclosure of your personal information:

3.1. For Workseekers

Information that we collect, hold, use and disclose about Workseekers is typically used for:

work placement operations;
recruitment functions;
statistical purposes and statutory compliance requirements;
Staff management;
Training;
Risk management;
Client and business relationship management;
Marketing services to you; but only where this is permitted and whilst you are registered with us;

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;
Workseeker suitability assessment;
recruitment functions;
confirm identity and authority to provide references and;
assess Workseeker suitability

3.4. Our Policy on Direct Marketing

We use your personal details for our own direct marketing purposes to broadcast job vacancies, news and similar company information pertaining to the education profession:

We will never give your personal details to a third party unless it is in relation to a job placement
We will never use marketing lists from a third party provider to market products to you

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:

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 Workseekers

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 alter your availability or location
You change your numbers and contact details
We check your references and
When we gain feedback on your work performance

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;
when you offer it at conferences and recruitment fairs
when you are referred to us by another client

4.3. For Referees

Personal information about you may be collected when you provide it to us:

in the course of our checking Workseeker references with you and when we are checking information that we obtain from you about Workseekers;

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. [If you deploy any workplace surveillance technologies, include a statement or link to your workplace surveillance policy and disclosure notice. In some jurisdictions disclosure is mandated. You should ensure that the disclosure meets workplace surveillance disclosure requirements in a way that does not compromise security, where a purpose of the deployment of the technology is to provide security for staff and visitors]

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;

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.

4.5.1 Access

Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you.

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. We do refuse access if it would breach any confidentiality that attaches to that information or if it would interfere with 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 we make and which the communicator of that information is entitled to expect will be observed.

If you wish to obtain access to your personal information you should contact our Privacy Co-ordinator. You will need to be in a position to verify your identity.

We might impose a moderate charge in providing access. Our Privacy Co-ordinator would discuss these with you.

You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within 20 working days.

4.5.2 Electronic Transactions

This section explains how we handle personal information collected from our website www.anzukteachers.com.au and by other technology in the course of electronic transactions.

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:

Australia: - http://www.privacy.gov.au/topics/technologies

New Zealand: http://privacy.org.nz/you-your-privacy-and-technology/

It is important that you:

Know your rights: read our privacy policy, collection statement and consent to electronic transactions.

Be careful what information you share on the Web.

Use privacy tools on the site - control access to your search listing and profile.

Make sure your anti-virus and data protection software is up-to-date.

Please contact our office by phone or mail if you have concerns about making contact via the internet. For further information see the

How to contact us in this document.

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;
or sign up to our newsletter

4.5.3 Browsing

When an individual looks at our website, our internet service provider (Telstra) makes a record of the visit and logs (in server logs) the following information for statistical purposes:

The individual's server address
The individual's top level domain name (for example .com, .gov, .org, .au, etc)
The pages the individual accessed and documents downloaded
The previous site the individual visited and
The type of browser being used.

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider's server logs.

We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

4.5.4 Cookies

Cookies are uniquely numbered identification numbers like tags which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on our site we will then link your cookie back to your personal information details.

This site uses cookies to monitor usage of the website, to enable purchases, and to create a personal record of when you visit our website and what pages you view. Cookies are necessary to enable us to assess the effectiveness of our page content and SEO strategy on our web site, but if you do not wish us to retain any information about your visit to our site you could delete the cookies on your browser and change the settings on your web browser program.

4.5.5 Web Bugs

If we use web bugs we will display a clearly visible icon on the page. The icon will include the name of the company collecting information and will be labelled as a tracking device. The Web bug will be linked to a page disclosing what data is collected, how it is used, and which companies receive the data. Web visitors will be able to opt out of data collection by Web bugs. Web bugs will not be used to collect sensitive information.

4.5.6 Cloud Computing Services

We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions or against third parties 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.

In cases where we use cloud computing services we will take reasonable steps to ensure that:

Disclosure of your personal information to the cloud service provider is consistent with our disclosure obligations under the Privacy Principles. This may include ensuring that we have obtained your consent, or that the disclosure is for purposes within your reasonable expectations.
Disclosure is consistent with any other legal obligations, such as the restrictions on the disclosure of tax file number information or the disclosure by private employment agencies of workseeker details;
Our Cloud computing services provider's terms of service 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.

4.5.7 Social Networks and Web Searches

In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. It has become common practice in some places for employment service providers to conduct background checking via social network media sites frequented by candidates.

We will not conduct background checking via social network media sites other than those that you identify and authorise us to check. However we do conduct internet searches using search engines and entering your name and relevant identifying details.

4.5.8 Emails

Our techonology systems log emails received and sent and may include voting, and read and receipt notifications to enable tracking.

When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

4.5.9 Call and message logs

Our telephone techonology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display.

When your call number is received by us because you phone us or send us a message, the number will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

4.5.10 Teleconferences and Video conferences

Teleconferences and video conferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

4.5.11 Database

We use recruiting software and databases to log and record recruitment operations.

4.5.12 Paperless Office

Recognising the environmental advantages and efficiencies it provides, we operate a wholly/partially paperless office as a result of which your paper based communications with us may be digitised and retained in digital format, the paper based communications may be culled.

It is therefore important that, except where specifically requested, you do not send us originals of any paper based document and that you retain copies for your own records.

Where we do request original paper based documents we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed

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

We store information internally on an in-house server which is managed by a dedicated in-house IT team

5.2. Information Security

Our information security system is built around data protection and privacy policy. This includes:

Staff training on confidentiality and privacy
"Clean desk" procedures
Need-to-know and authorisation policies
Just-in-time collection policies
Password protection
Policies on laptop, mobile phone and portable storage device security;
Policy on timely culling and
Culling procedures including shredding and secure disposal of confidential documents etc.

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;
Email Newsletter Senders

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.

We may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted.

We may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a contractual or lawful duty of care to disclose information.

We do not share personal information about you with government agencies, organisations or anyone else unless one of the following applies:

You have consented;
You would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies;
It is required or authorised by law;
It will prevent or lessen a serious and imminent threat to somebody's life or health;
The disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.

6.2. Cross-Border Disclosures

Some of your personal information is likely to be disclosed to overseas recipients. 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.

The likely countries, type of information disclosed and recipients are indicated, so far as is practicable, in the following table:

Country	Type of Information	Likely Recipients
Australia	All personal data held by us	Internal use by anzuk staff
New Zealand	All personal data held by us	Internal use by anzuk staff
United Kingdom	All personal data held by us	Internal use by anzuk staff
Ireland	All personal data held by us	Internal use by anzuk staff
Canada	All personal data held by us	Internal use by anzuk staff

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 Privacy Co-ordinator. You will need to be in a position to verify your identity.

Subject to some exceptions that are set out in both the Australian Privacy Principles you can gain access to the personal information that we hold about you. To make a request to access your personal information, you will need to complete a written application form verifying your identity and specifying what information you require. We will respond to your request within a reasonable period after the request is made and provide access to the information in the manner requested, if it is reasonable and practicable to do so. Please ensure you request a specific time and date on when your information is required so we can reasonably inform you of our ability to respond within this time frame.

If we refuse to provide you with access to your personal information, we will notify you in writing of the reasons for the refusal and the process for escalation regarding this refusal.

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.

[Include any other information about your correction policy – e.g. information about:

Timeframes for your response to correction requests
What happens in the event that you refuse to correct
Complaints].

Complaints

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. For more information see our Complaints Procedure.

7.3. 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 to our Privacy Co-ordinator, whose contact details are Daniel Mundy on 03 9249 2444.

You can also make complaints to the Office of the Australian Information Commissioner

Complaints may also be made to RCSA, the industry association of which we are a member.

RCSA administers a Code of Conduct for the professional and ethical conduct of its members.

The RCSA Code is supported by rules for the resolution of disputes involving members.

NOTE: The Association Code and Dispute Resolution Rules do NOT constitute a recognised external dispute resolution scheme for the purposes of the APPs; but are primarily designed to regulate the good conduct of the Associations members.

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.

Future Changes

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.

Privacy Policy anzuk Education Services PTY LTD ABN 19123730521