AUSTRALIA & NEW ZEALAND
Your privacy is important to Tenth House
Your privacy is important to us. This statement outlines Tenth House policy on how we collect personal information and how we maintain, use, store and disclose the personal information we hold and reflects our commitment to you. It applies to all operations within Eleventh House Pty Ltd “Tenth House” in Australia and New Zealand, including visitors to our website.
It is the policy of Tenth House to respect the confidentiality of information and the privacy of individuals. Tenth House are bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (as amended) in Australia; and by the Information Privacy Principles (IPP) contained in the Privacy Act 1993 in New Zealand.
We are committed to being open and transparent about how we manage personal information.
We will need to collect personal information about you
Personal information means information or an opinion about you.
Personal information may range from the sensitive (e.g. relevant medical history or criminal history) to everyday (e.g. address and phone number). We may collect the opinions of others about your work performance, your work experience and qualifications, aptitude test results and other information in connection with your possible work placements.
We will only collect information that is necessary for the proper performance of our tasks or functions.
We do not routinely conduct criminal history checks and only do so in order to obtain relevant criminal history with regard to particular jobs you are offered or for which you are shortlisted.
We do not collect or use personal information for the purposes of unlawful discrimination.
We may decline to collect unsolicited personal information from or about you and may take such measures as we think appropriate to purge it from our systems.
Sensitive information (Australia only)
Sensitive information is a special category of personal information under the Australian Privacy Act 1988. It is information or opinion about you, including membership of a professional or trade association or membership of a trade union; criminal record; health information, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, or sexual preferences or practices. As outlined in the Australian Privacy Act, sensitive information can, in most cases, only be disclosed with your consent.
Type of personal or sensitive information held
Personal or sensitive information that we collect and hold usually falls into the following categories:
- Candidate information submitted and obtained from the candidate and other sources in connection with applications for work;
- Results of any inquires that we might make of your former employers, work colleagues, professional associations or registration body;
- 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 gained to assist in managing client and business relationships;
- Photographs used exclusively for database identification by internal consultants.
How your information will be collected
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:
- We receive or give any reference about you;
- We receive results of inquires that we might make of your former employers, work colleagues, professional associations or registration body;
- We receive the results of any competency or medical test;
- We receive any complaint from or about you in the workplace;
- 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;
- Electronically through our telecommunications and technology systems – see section in this policy on electronic transactions.
Purposes for which we hold personal information
We primarily hold personal information for the following:
- Employment placement operations;
- Staff management;
- Risk management;
- Client and business relationship management;
- Marketing services to you; but only where this is permitted and whilst you are registered with us;
- Statistical purposes and statutory compliance requirements;
- Photographs used exclusively for database identification by internal consultants.
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 any one 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 authorized by law;
- It will prevent or lessen a serious and imminent threat to someone’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.
Outsourced Service Suppliers
We outsource a number of services to contracted service providers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically our CSPs would include:
- I.T. contractors, database designers and service internet service suppliers, some of whom may be offshore;
- Legal and other professional advisors;
- Insurance brokers, loss assessors and underwriters;
- Superannuation fund managers;
- Background checking and screening agents.
We take reasonable steps to ensure that the 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 these obligations.
We may have occasion to use your personal information as part of our marketing communications with our clients. The sole purpose of this is to obtain interview for suitable jobs for you. In these instances the information will not include any personal contact information but will be limited to general background information on your skills and experience. Before any personal information is disclosed, including resumes and contact information, you will always be asked for your permission and told who the information is going to.
We may also from time to time send our clients and candidates marketing information. If you do not wish to receive this information, please contact the Privacy Officer and we will remove you from our list, in compliance with anti-spam legislation.
Personal Information Quality
We rely on you to tell us when there are changes to your personal information that we hold about you. An example of this would be a change of address or employment status. We also ask that you warrant that the information provided to us in any documentation is true.
Children, Minors and Persons under Legal Disability
Determining the decision making capabilities of a person who is under a legal disability can be a complex matter, often raising ethical and legal issues.
We endeavor to address each case individually with a view to deciding whether the individual is able to give consent or receive notifications based upon an assessment of whether the individual has sufficient understanding to comprehend the nature and quality of what is being proposed.
In some circumstances, it may be appropriate for a parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom to be contacted in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly to the individual.
Personal Information Security
We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed. However it is not always practicable to destroy or de-identify electronic data. Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent inadvertent access to it.
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.
At times video surveillance which operates in or near our premises may capture an image of you.
We may ask if we can take a photograph of you for internal purposes to be stored in our database for ease of identification only by our internal consultants. This information will not be forwarded to a third party.
Inquiries and Complaints
You can make inquiries, requests to access/delete or correct your information, or complain about alleged breaches of the APP’s or IPP’s to our Privacy Officer:
Karen Galasso, firstname.lastname@example.org, (02) 8222 6200.
You can also make any complaints to the Privacy Authorities:
We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought be protected. The cost 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.
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 communication 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 Officer. You will need to be in a position to verify your identity.
We might impose a moderate charge in providing access. Our Privacy Officer would discuss this 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.
This section explains how we handle personal information collected from our website 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:
It is important that you:
- 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 are up-to-date.
- Please contact our office by phone or mail if you have concerns about making contact via the internet. For further information contact the Privacy Officer.
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 the job notification list or newsletter;
- 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;
- Submit a resume by email or through our website or other job seeker site;
- Submit a portfolio or URL showing their work samples.
When an individual looks at our website, our internet service provider internode 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.
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 may link your cookie back to a database record of when you visit our website and what pages you view. Cookies are necessary to enable Google Analytics on our web site, but is 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.
Cloud Computing Services
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 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 Australian Privacy Principles. This may include ensuring that we have obtained your consent, or that the disclosure is for purposed 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 jobseeker 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.
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.
Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws, and you may be responsible for any legal consequences.
Our technology 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 of which you have provided it and it will not be added to our mailing list or used or disclosed for any other purpose without your consent other than may be permitted or required by law.
Call and message logs
Our telephone technology (systems and mobile phones) logs telephones 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 purposes without your consent other than as may be permitted or required by law.
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.
We use recruiting software and databases to log and record recruitment operations.
Recognising the environmental advantages and efficiencies it provides, we operate a partially paperless office as a result of which your paper based communications with us may be digitized 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.
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.