Privacy Policy

Privacy Policy
​

1.   Introduction

Wallace Street Recruitment Pty. Ltd. (ABN 78 631 632 883) is a registered business in Australia. We provide permanent and locum recruitment and placement services to the health, aged, and disability sectors. This Privacy Policy applies to information collected by Wallace Street Recruitment Pty. Ltd. (“WSR”). References to “Wallace Street Recruitment”, “Wallace Street”, “WSR”, “we”, “us” and “our” in this Privacy Policy refer to Wallace Street Recruitment Pty. Ltd.

1.1  Privacy Act 1988 (Commonwealth) and the Australian Privacy Principles (APPs)

We manage personal information in accordance with the Privacy Act 1988 (Commonwealth) and the Australian Privacy Principles (APPs). The APPs are designed to protect the confidentiality of the information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed.

1.2  Purpose of Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of your personal information and explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about this information and how you may access and correct this information.

1.3  Collection of Reasonably Necessary Information to Perform Functions

Wallace Street Recruitment only collects 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.

1.4  Review and Currency of Privacy Policy

This Privacy Policy will be reviewed and updated from time to time to reflect new laws, technology, changes to our operations and practices and the changing business environment. Please regularly check our Privacy Policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of our Privacy Policy. The current version of this Privacy Policy is available at www.wallacest.com.

1.5  Access, Acceptance and Alternate Forms of Privacy Policy

Please read this Privacy Policy carefully. By providing us with personal information you have indicated that you have had sufficient opportunity to access this Privacy Policy and that you have read and accepted it. If you have any questions or require our Privacy Policy in a particular form, please contact our Privacy Officer Danielle Wallace (Director) at dwallace@wallacest.com.

1.6  Dealing with Us Anonymously

If you do not wish to provide personal information to us, then you do not have to do so, however, it may affect your use of our website/this Site or any products and services offered on it.  If you would like to access any of our services on an anonymous basis, please let us know in writing. 

2.   APP Entity

Wallace Street Recruitment manages personal information as an APP Entity, under the Australian Privacy Principles (APPs).

3.   Personal Information

Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. It includes information regarding your:

• Contact details;
• Employment history;
• Education and qualifications;
• Aptitude test results;
• References;
• Incidents at the workplace; and
• Other information obtained or received by us in connection with your possible and actual work placements.

4.   Sensitive Information

Sensitive information is a special subcategory of personal information. It is information or an opinion about your:

• Racial or ethnic origin;
• Political opinion;
• Membership of a political association or religious beliefs, affiliations or philosophical beliefs;
• Membership of a professional or trade association or membership of a trade union;
• Sexual preferences or practices;
• Criminal record; and
• Health or disability (at any time).

5.   Information Flow

When we collect your personal information, we undertake the following:

• Check it is reasonably necessary for our functions or activities such as the recruitment process as a professional recruitment services provider;
• 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;
• Record and hold your information in our Information Record System/CRM database. Some information may be disclosed to overseas recipients;
• Retrieve your information when we need to use or disclose it for our recruitment process (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;
• Permit you, subject to some exceptions, to access [6: Access & Correction] your personal information in accordance with APP:12  of the APPs;
• Correct or attach associated statements to your personal information in accordance with APP:13  of the APPs; and
• 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.

6.   Kinds of Personal Information Collected and Held

Personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as a recruitment services provider and is likely to differ depending on whether you are a Job Seeker, a Candidate, a Client or a Referee.

6.1  Job Seekers and Candidates

The type of information that we typically collect and hold about Job Seekers and Candidates 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: 

• Contact details and identity information;
• Job preferences, location of desired job/work and salary (for recruitment purposes);
• Education and qualifications including membership or professional registrations, employment history, performance appraisals, information about incidents in the workplace, your health information, personal history, opinions from referees, information in relation to absences from work due to leave, illness or other causes and our assessment of you as a prospective candidate for recruitment purposes;
• Information from third parties including any references about you, psychometric or competency test results or any information about any insurance investigation, litigation, criminal matter, inquest or inquiry in which you are involved; and
• Conversation and communication logs.

6.1.1  Sensitive Information

Depending on the nature of the role applied for we may need to collect and process personal information about you regarded as sensitive information. This includes:

• Health and disability details;
• Criminal records; or
• Membership of professional or trade associations.

With regard to sensitive information:

• You acknowledge that the collection of sensitive information about you may be reasonably necessary to carry out our functions and activities.
• We will only collect sensitive information about you with your prior consent. Your consent is given when you knowingly supply sensitive information to us.
• We will only disclose your sensitive information (for example, your health information) for the purposes for which it was initially collected or purposes to which you otherwise consent. 

6.2  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: 

• Contact details and identity information;
• Company and employee details;
• Job descriptions;
• Billing details and records;
• Recruitment agreements;
• The feedback that you may have provided in relation to a Candidate, or their performance at interview or on placement; and
• Conversation and communication logs.

6.3  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 Candidates for particular jobs or particular types of work and includes:

• Contact details and identity information;
• Referee employment experience and relationship to work-seeker;
• Reference check including feedback that you may have provided in relation to a candidate or their suitability for a position; and
• Conversation and communication logs.

7.   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 Candidate, a Client or a Referee.

7.1  Job Seekers and Candidates

Information that we collect, hold, use and disclose about Job Seekers and Candidates is typically used for:

• Recruitment functions;
• Workplace operations;
• Responding to enquiries or questions from you;
• Statistical purposes and statutory compliance requirements;
• Direct marketing of Candidate to Client (with Candidate permission);
• Client requests for contact details;
• Service standard surveys post-recruitment functions;
• Marketing services to you;
• Informing you about any relevant training, industry developments, including sending you details of any events, promotions and competitions, and to communicate any other relevant information;
• Improving our customer service, including customising our website in order to better suit your requirements; and
• Risk management.

7.2  Clients

Personal information that we collect, hold, use and disclose about Clients is typically used for:

• Recruitment functions;
• Client and business relationship management;
• Marketing services to you;
• Statistical purposes and statutory compliance requirements;
• Service standard surveys post-recruitment functions; and
• Responding to enquiries or questions from you.

7.3  Referees

Personal information that we collect, hold, use and disclose about Referees is typically used for:

• Recruitment functions;
• To confirm identity and authority to provide references;
• Candidate’s suitability assessment and comment; and
• Validation of Candidate’s provided information.

8.   How 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 Candidate, a Client or a Referee. We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking the information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.

8.1  Job Seekers and Candidates

Personal information will be collected from you directly when you forward your resume, 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:

• when we have a face to face meeting or telephone conversation with you;
• you send or receive an email from us;
• we receive or give any reference about you;
• we receive results of enquiries that we might make of your former employers and work colleagues;
• professional associations or registration body;
• we receive results of any competency or medical test;
• we receive performance feedback (whether positive or negative);
• we receive any information about a workplace complaint or accident in which you are involved;
• we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
• you provide us with any additional information about you; and
• electronically through our website.

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. 

8.2  Clients

Personal information about you may be collected:

• when you provide it to us for business or business-related social purposes; and
• 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.

8.3  Referees

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

• in the course of our checking Candidates’ references with you and when we are checking the information that we obtain from you about Candidates; and
• 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.

8.4  Dealing with us anonymously

Job Seekers and Candidates are not obliged to give us their personal information. If you would like to access any of our services on an anonymous basis, please let us know in writing. If this is possible and lawful, we will take reasonable steps to comply with your request. However, if you choose not to provide us with some or all of your personal information we may: 

• not be able to provide a Job Seeker/Candidate with the full range of our recruitment services;
• be more restricted in providing a particular Job Seeker/Candidate with a list of potential employment targets or positions, and
• decline to provide any further assistance to the Job Seeker/Candidate. 

Additionally, the Job Seeker/Candidate’s chances of being properly considered for a position may be reduced. 

8.5  Photos and 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.

We will/may request a photo for our database, which can be accepted or declined by you.

At times video surveillance which operates in or near our premises may capture images of you. 

8.5.1 Uploading Photographs

If you are a Candidate and are interviewed or met with face to face, you may be asked if we can take a photograph and collect and store this on our database. If you verbally accept this, you agree for us to collect and store this photograph purely for our reference.  

8.6  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 website such as a job notification board;
• make a written online enquiry or email us through our website; and
• submit a resume by email or through our website.

It is important that you understand that there are risks associated with the use of the Internet and you should take all appropriate steps to protect your personal information.

You can contact us by telephone or post if you have concerns about making contact via the Internet. 

8.6.1 Email Alerts

You may sign up to receive emails that alert you to new jobs on our website or upcoming events. To subscribe to these, you need to provide your email address, this will be used for the purposes of keeping you informed by email of the latest jobs and/or news in your nominated industry. If you no longer wish to receive these alerts, unsubscribe links are provided in every email alert that you receive. 

8.6.2 Our Website

Whenever a registered member (such as a Job Seeker/Candidate) logs in to our website, they will be identified by their user name and password. The information we collect about members' use of our websites is in aggregate form (that is, the information does not identify any one individual). This information is used by us to measure site performance, assist in resolving any technical difficulties and to improve our online services. We may also publish some of this aggregate (non-identifiable) information on our website.

This site uses Google Analytics, Custom Search and Maps services provided by Google, Inc. (“Google”). Google uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

8.6.3 Cookies

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the site name.

Cookies make the interaction between you and the website faster and easier. If a website doesn’t use cookies, it will think you are a new visitor every time you move to a new page on the site – for example, when you enter your login details and move to another page it will not recognise you and it won’t be able to keep you logged in.

We use ‘analytical’ cookies to help us improve the way our website works, for example, by making sure users are able to find what they need easily.

You can find out more about the use of cookies on http://www.allaboutcookies.org/.

8.6.4 Other Websites

Clicking on links and banner advertisements and Rich Site Summary/Really Simple Syndication (RSS feeds) may result in your transfer to another website, where data privacy practices may be different to that of Wallace Street Recruitment. It is your responsibility to familiarise yourself with these privacy policies as we accept no responsibility for and have no control over them or any information or data collected by or for them.

A link to a third party website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

9.   How 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

9.1.1 Our Information Record System

Your personal information may be stored in hard copy documents, or electronically on Wallace Street Recruitment software or systems. 

9.1.2 Information Security

Wallace Street Recruitment takes reasonable steps to protect the personal information we hold from loss, interference, unauthorised access, modification or disclosure.   Our security procedures include:

• locks and security systems;
• computer passwords and limited access to shared network drives to authorised staff;
• virus checking;
• auditing procedures and data integrity checks;
• recording of file movements; and
• security classification to identify information needing special protection.

The Internet is not always a secure method of transmitting information.  While we seek to protect your personal information by implementing digital security systems in various parts of our website, Wallace Street Recruitment does not accept responsibility for the security of information you send to us or receive from us over the Internet or for any unauthorised access or use of that information. 

10.   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;
• other recruitment companies or intermediaries involved in managing the supply of personnel; and
• to Referees for suitability and screening purposes.

10.1  Related Purpose Disclosures - Contracted Service Suppliers

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;
• Information Technology contractors and database designers and Internet service suppliers;
• Legal and other professional advisors;
• Insurance brokers, loss assessors and underwriters;
• Superannuation fund managers; and
• 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.

10.2  Related Purpose Disclosures - Quality and Improvement Activities, Memberships and Accreditation

We are always striving to improve the quality of our service and exceed industry standards. In doing so, we undertake Quality and Improvement Activities, that includes holding Memberships and attaining Accreditation. The Accreditation process involves auditors accessing our recruitment processes and as a result, so auditors may see some of your personal information.

We take reasonable steps to ensure that external persons involved in such activities 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.

10.3  Cross-Border/Overseas Disclosures

Wallace Street Recruitment is a professional recruitment consultancy aiming to provide you with services worldwide. Our global network is made up of offices, data centres, trusted service providers and trained recruitment consultants.

Some of your personal information is likely to be disclosed to overseas recipients. Where we transfer your personal information to related entities outside Australia, we believe that the recipients of such information are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that is similar in all material respects to the APPs outlined in the Privacy Act.

We may transfer the information we collect about you to countries other than your home country or other than the country in which the information was originally collected: 

• if you are registered as a Job Seeker or a Candidate on our database, your personal information will be accessible by our other offices and potential employers internationally, including but not limited to Ireland, United Kingdom, Middle East and New Zealand;
• to different parts of the Wallace Street Recruitment located outside Australia; and
• to servers located in the United States, Ireland, United Kingdom, Middle East, Singapore, Malaysia and New Zealand in which case we will take reasonable steps to ensure your personal information is treated securely.  

We may, from time to time, use data hosting facilities or enter into contractual arrangements with third party service providers to assist us with the provision of recruitment services to you which may not be based in Australia (Overseas Entities). As a result, personal and sensitive information may be transferred to and stored at, a destination outside Australia. Personal and Sensitive information may also be processed by staff or other third parties operating outside Australia who works for Wallace Street Recruitment or one of our agents or contractors.

You hereby consent to the disclosure of your personal and sensitive information to such Overseas Entities and you acknowledge that as a result of your consent to such disclosure, Principle 8.1 of the APPs does not apply.

11.   Your Acceptance of Our Privacy Policy and Consent

By submitting your personal information to Wallace Street Recruitment through any means, using our services or accessing the Wallace Street Recruitment website, you consent to the use of information as set out in this policy. If you do not agree with any term of this policy, please do not submit any personal information to us or use Wallace Street Recruitment services or our website.

Wallace Street Recruitment operates in a dynamic business environment. Aspects of our business may change as we respond to changing law or market conditions. This may require our policies to be reviewed and revised from time to time. If we make material changes to our Privacy Policy, we will notify you by putting a notice on the “Home” page of our website at www.wallacest.com.

Any information we hold will be governed by the most current version of our privacy policy. Your continued use of our website, services or continued provision of personal information to us once you have been notified of the updated Privacy Policy constitutes your deemed acceptance of the revised Privacy Policy. 

You acknowledge and agree that, by providing your personal and sensitive information to Wallace Street Recruitment either directly or through relevant third party individuals or organisation, that Wallace Street Recruitment, its related bodies corporate and partners and each of their officers, employees, agents, contractors and related third parties are permitted to collect, store, use and disclose your personal information in the manner set out in this Privacy Policy and in accordance with the APPs.

12.   Accessing and Seeking Correction of Personal Information

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

With regard to access to some 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.

12.1  Access Policy

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

It may take us a little time to process your application for access as we may 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.

Where we are legally permitted to do so, we may refuse your request.  If Wallace Street Recruitment denies your request for access, we will provide you with reasons for the refusal.

We may impose a moderate charge to cover the reasonable costs of retrieval and supply of the information to you. Our Privacy Officer will discuss this with you.

If you have a complaint about your access to personal information, please contact us. 

12.2  Correction Policy

Wallace Street Recruitment 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.

We may contact you from time to time to check that the information is still correct. Please advise your Wallace Street Recruitment consultant/s when your personal details change. 

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 generally respond to your request within 10 working days.

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. 

If you request your personal information to be updated and there is a dispute about the facts, we will make a note on your personal information of such dispute. 

13.  Complaints

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

13.1 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 to our Privacy Officer. 

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

Complaints may also be made to Recruitment, Consulting and Staffing Association of Australia and New Zealand (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 Association's 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; and
• 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.

14.  Contact

Wallace Street Recruitment is committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. 

If you would like more information about our privacy practices or have any concerns or questions in relation this Privacy Policy, including a request of this policy in an alternate form or complaints in relation to the information held by Wallace Street Recruitment, or you would like us to cease using your information in the manner described herein, you should contact our Privacy Officer:

Danielle Wallace
Privacy Officer
email: dwallace@wallacest.com

Post: PO BOX 1305, North Sydney, NSW, Australia, 2060

15.  Governing Law

You irrevocably and unconditionally submit to the non-exclusive jurisdiction of the Courts of New South Wales and any Courts of Appeal from them for determining any dispute concerning this Privacy Policy. If any provision of this Privacy Policy is found to be invalid or unenforceable by a Court of law, such invalidity or unenforceability will not affect the remainder of this Privacy Policy which will continue in full force and effect.

Reviewed 10th September 2019