Who does this policy apply to and what does it cover?
This policy describes how we, Command Group Pty Ltd (ABN 67 110 774 019), handle “personal information” collected from individuals.
Command Group is an Australian owned and managed recruitment agency with offices in Australia, Singapore & PNG.
Personal information means information or an opinion about an individual (who can reasonably be identified), whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
What is our privacy commitment to you?
We are committed to complying with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) by protecting the privacy and confidentiality of your personal information. When we collect, use, disclose, store, access or correct your personal information, our actions will comply with the Privacy Act and the Australian Privacy Principles.
Where appropriate, we will handle personal information relying on the employee records exemption and the related bodies corporate exemption in the Privacy Act.
What kinds of personal information do we collect and hold?
The kinds of personal information that we collect from you will vary depending on our relationship with you. These relationships have been categorised as:
• “Candidates” which include all individuals who approach us, or are referred to us, seeking work with us or our Clients.
• “Clients” which include all individuals who we deal with for the purpose of providing recruitment solutions and services for their business.
• “Referees” which include all individuals who we deal with in assessing our Candidates’ capabilities and suitability for employment.
Of course, we may also collect personal information from you if you contact us, for example by phone or email, and do not fall into one of the above categories.
If you are a Candidate we collect personal information about you that is reasonably necessary for us to determine your suitability for work with us or through us. The main types of personal information we collect about you as a Candidates are:
• your name and contact details including your address and telephone numbers;
• your date of birth;
• your gender;
• information in your cover letter, resume and application forms including your skills, qualifications, work history, references, goals and interests;
• details of your work rights in Australia and other countries;
• your tax file number and superannuation details;
• information documenting your work history placement with or through us (including letters of appointment, bank account details, records of salary adjustments, work performance information, salary sacrifice documents and sick leave taken);
• test or assessment results conducted by us or other parties;
• the results of police checks, working with children checks or other background checks;
• medical reviews or assessments of you;
• salary/hourly rate expectations held by you;
• current job options that you may have;
• your availability to commence work with or through us;
• sensitive information that you consent to providing to us including health information, criminal convictions and union membership that you or your Referee provide to us; and
• other information that you, your Referees or our Clients provide to us, including opinions about you and notes of our interactions with you and/or others in relation to your suitability for work with or through us.
If you are our Client we collect personal information that is reasonably necessary for us to provide the best recruitment solutions for you and your business needs. The main types of personal information we collect about you as our Client are:
• your contact details including your address and telephone numbers;
• details of your job title/description and organizational needs; and
• records of our interaction with you and confidential feedback you may give us regarding our Candidates. Referees
If you are a Referee we collect personal information that is reasonably necessary for us to determine a Candidate’s suitability for work with us or through us. The main types of personal information we collect about Referees are:
• your contact details including your address and telephone numbers;
• details of your job title/description; and
• your confidential opinions about a candidate and their suitability for work with or through us. How do we collect your personal information?
Your personal information (including sensitive information) is collected as a result of your dealings with us. We only collect personal information by lawful and fair means.
We collect personal information from you directly unless it is unreasonable or impracticable to do so.
If you are a Candidate the ways in which we collect personal information about you are when:
• you provide your resume, complete an application form or undergo an aptitude test or other testing with us;
• you voluntarily undertake, and we receive the results of, a medical review or assessment;
• you voluntarily undertake, and we receive the results of, a police check, working with children check or other background check;
• you voluntarily undertake, and we receive the results of, a skill assessment or training by a third party;
• a Referee gives his or her confidential opinion about a Candidates’ work history or suitability for work with or through us; and
• we receive confidential feedback (negative or positive) about a Candidate from a Client;
• we receive a complaint or report related to a Candidate conduct by a Client or others;
If you are a Client the ways in which we collect personal information about you are when:
• we meet you or interact with you and you express an interest in our services; and
• when you provide your opinion or feedback regarding one of our Candidates.
If you are a Referee the ways in which we collect personal information about you are when:
• a Candidate provides us with your details and informs us that you have consented to such collection; and
• when we take notes of our dealings with you including your opinions of a the suitability of a Candidate for work with or through us.
In general, if you contact us, we may keep a record of that correspondence. Personal information is collected with the consent of all workplace participants. All Candidates registering for work through will be asked to sign a verification and consent clause.
Candidates should talk to their Referees to ensure they consent to their contact details being provided to us.
Can I refuse to give Command my personal information (including sensitive information)?
You can refuse to provide us with your personal (including sensitive) information. However if you refuse to provide us with this information, we may not be able to provide our services to you. For example, if you are Candidate we may not be able to consider your application for work with or through us.
You have the option of not identifying yourself or using a synonym when dealing with us. However, this will be limited to enquiries of a very general nature only. It is impracticable for us to deal with individuals who have not identified themselves or who have used a synonym when providing our services.
If you are successful in obtaining employment with us we will collect further personal information from and about you. However, any act or practice by us as an employer that is directly related to a current or former employment relationship between us and you and any employee record held by us relating to you is exempt from our obligations under the Privacy Act and this Policy.
For what purposes do we collect, hold, use and disclose your personal information?
We collect, hold, use and disclose personal information to provide a range of co-ordinated value driven recruitment services for our Candidates and Clients and comply with our legal obligations.
The purpose of collecting personal information is to:
• consider and potentially offer Candidates work with our Clients;
• contact a Candidates Referee;
• create an iProfile for Candidates;
• facilitate contracts and arrangements between our Candidates, Clients and us;
• facilitate workplace rehabilitation or assessment and comply with any obligations we may have under the Work Health Safety Act 2011;
• improve our services that we offer our Clients and Candidates;
• better understand the needs of our Clients and potential Clients;
• offer our Clients and potential Clients recruitment solutions and news updates by direct marketing;
• carry out administrative functions such as billing;
• ensure that we, our Clients and our Candidates are meeting their obligations under relevant legislation as well as under our Candidates contract of employment;
• properly train and manage Candidates;
• ensure the health, safety and welfare of our Candidates at times when they are performing work for us;
• ensure appropriate insurance cover for Candidates who work with or through us.
Is Command required or authorized by law to collect my personal information?
Command must comply with a number of Australian laws that require the collection of personal information from individuals that we deal with. These particular laws may vary from state to state.
The broad areas of these laws include tax laws, immigration laws, working with children laws, aged care laws and other laws that require candidates to hold certain qualifications and licences.
How do we use your personal information?
We use your personal information primarily to allow us to carry out the activities and functions listed above.
We also use your personal information for secondary purposes related to those activities or when allowed under the Privacy Act.
Do we disclose your personal information to others?
If you are a Candidate, and you consent, we may disclose your personal information to:
• Clients and potential Clients to help you obtain work;
• Referees to assess your suitability for work with or through us;
• Various bodies to conduct background or other checks; and
• iProfile and the world at large to assist you obtaining work.
If you are a Referee we may disclose your personal information to our Clients or potential Clients. We may also be required to provide some of your personal information to the Candidate that you provide a reference for. However, we understand that personal information including your opinions about a Candidate is often provided on a confidential basis by you as a Referee and we will endeavour to only provide information that will not breach this confidentiality.
If you are a Client we may disclose your personal information including your opinions of a Candidate by way of feedback to Candidates for coaching purposes.
There may be times when we need to disclose your personal information to third parties for the purpose of allowing us to carry out the activities listed above. For example, from time to time, we engage external companies to carry out mail services, IT storage services and software related services. These external companies only have access to the information necessary to provide services to us. They are required to comply with the Privacy Act and must offer privacy standards comparable to those offered by us.
We will disclose your personal information if we are required or authorised to do so by law enforcement agencies, the Australian Electoral Office, the Department of Family Services, the Australian Taxation Office, Centrelink or other statutory bodies.
We may also disclose your personal information to our insurers, professional legal or financial advisers.
Personal information will only be disclosed for a purpose permitted by the Privacy Act and/or this Policy and your consent will first be obtained where appropriate.
We may also use and disclose personal information about you for the other purposes related to reviewing our services, marketing our services or improving our services.
How do we hold and protect your personal information?
Personal information is held by us both electronically and by hard copy. We take reasonable steps to ensure that your personal information is safe and secure from unauthorised use and disclosure whether such information is stored electronically or in hard copy.
We enter your personal information into our secure online portal and your information is separately stored on our electronic server. All information stored electronically is password protected, encrypted and very limited access is granted to that information.
All current Candidate hard copy files are kept in the filing room or in our consultant’s work in progress files. All Candidates who receive placements through us will have their files archived in a secured storage area.
Your personal information is securely destroyed by shredder when it is no longer needed or when it is out of date.
Are we likely to disclose personal information overseas?
We are likely to disclose your information overseas. This includes to our other locations including Hong Kong and Singapore.
We are an iProfile Compatible Organisation. This means that one of the reasons we collect personal information is to create an iProfile for our Candidates. This involves disclosing a Candidate’s personal information to iProfile which may be disclosed to other recruitment agencies that a Candidate has previously provided personal information to and Clients or potential Clients.
Your profile on iProfile may be accessed anywhere in the world.
We may also provide your information to numerous other countries where you may be considered for work with or through us.
We use secure cloud storage services. This involves the use of servers that may be located in other countries and constitutes a disclosure under the Privacy Act.
Using our website (s)
The websites operated by us may contain hyperlinks to other websites including those operated by third parties.
The links are provided for reference only. We do not have any control over these external websites. We are not responsible for the content on these sites or the privacy practices adopted by these sites.
What does this policy mean?
By using our services you consent to the terms of this policy.
From time to time, your additional consent will be sought for the collection, use or disclosure of information for purposes other than as set out in this policy.
If you do not agree to any part of this policy please contact the privacy officer listed below.
How do I access, update or correct the personal information held by us about me?
You can request to access the personal information we hold about you by contacting our Privacy Officer.
We will not charge you for making the request. However, we may need to charge you for our time to answer your request. We will advise you in advance if there are to be any charges associated with complying with your request.
We will respond to your request in a reasonable time frame (usually not more than 30 days).
When you request access we may need further information from you to verify your identity.
There are a number of reasons we may be unable to give you access to your information. If we are not able to provide access to your information we will provide you with our written reasons.
Importantly, if you are a Candidate, information provided by Referees or from Clients about you are often given on a confidential basis. Accordingly, disclosing the opinions given by a Client or Referee is likely to have an unreasonable impact on the privacy of those individuals. When determining whether to provide access to such information we will consider the nature of the personal information about the other individuals and the reasonable expectation of those other individuals.
We may also refuse access to personal information if to do so would reveal evaluative information generated by us in connection with a commercially sensitive decision making process. If we refuse access on this ground we may give you an explanation for the commercially sensitive decision rather than direct access to the information.
If you believe any of the personal information that we hold about you is incorrect you can ask us to correct it.
If asked to correct your personal information we will take reasonable steps to correct the information to ensure that it is accurate, up to date, relevant and not misleading.
If we refuse to correct your personal information we will give you written reasons.
How do I make a complaint about privacy at Command?
If you believe we have breached the Privacy Act or any of the Australian Privacy Principles or if you want to raise any issues you may have about privacy please our Privacy Officer.
In making a complaint to us about privacy, please give us enough details to be able to identify your concerns and response appropriately. You must provide us with your name and contact details and a description of your complaint. We will respond to you in a reasonable time frame (usually not more than 30 days). If you are unhappy with how we handle the complaint you have a right to take the complaint to the Information Commissioner.
You can contact the privacy officer, by:
Phone: (02) 9262 5656
9 Barrack Street,
Sydney NSW 2000