Privacy Policy - Stafflink Pty Ltd

Last updated: March 2024

Stafflink Pty Ltd (ACN 626 030 742) and its Related Bodies Corporate (having the meaning given in Australia’s Corporations Act 2001 (Cth)) (Stafflink, we, us and our) respects your privacy and is committed to protecting it. We comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep secure and disclose Personal Information.

The Privacy Act defines “Personal Information” to mean any information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can be reasonably ascertained, from the information or an opinion.

If you have any concerns or complaints about the manner in which your Personal Information has been collected, used or disclosed by us, please contact us via the information set out in Section 11 and will resolve your concern or answer your question.

1. Kinds of Personal Information collected, used and disclosed by Stafflink

1.1 General

In this policy, we distinguish between Personal Information which:

our customers upload or transfer into our platforms, support software, workflow framework, or digital marketing services; and
Stafflink collects and handles for its internal business purposes, such as for hiring and employment purposes, or that which we collect from our direct customers.

1.2 Personal Information that we receive from Stafflink customers

In providing our services to our business customers, we may receive your Personal Information on a customer’s behalf, or they may disclose or transfer your Personal Information to us for processing in accordance with their instructions.

Each Stafflink customer collects personal information according to its own Privacy Policy. You should read and understand the customer’s privacy policy to learn more about how they collect and handle your Personal Information.

The table below sets out the types of your Personal Information that we may receive from Stafflink customers.

Purpose	Collections	Uses	Disclosures
Providing our Services to Stafflink customers	Personal information uploaded or transferred by our customers into Stafflink online services or platforms Full name, email address; residential or mailing address; bank account particulars; government identification number or copy as applicable (driver license, passport, etc); salary and employment details; date of birth;	We may use or process your Personal Information from Stafflink customers for reasons including, without limitation: To assist our customers to process and perform their real estate or property management and sales tasks, such as your tenancy application or property application, or their customer service functions	Through their use of our services, our customers may direct us to share your Personal Information to: Property owners/ landlords or property managers; Third parties connected with the processing of your tenancy or property application, or delivery of real estate or property management services, including platform integrations or other intermediate services that our Stafflink customers may turn on, payment gateway providers and financial institutions. Service providers (including our IT service providers and consultants) who assist us in providing our services. As required or authorised by law.

Purpose

Collections

Uses

Disclosures

Providing our Services to Stafflink customers

Personal information uploaded or transferred by our customers into Stafflink online services or platforms

Full name, email address; residential or mailing address; bank account particulars; government identification number or copy as applicable (driver license, passport, etc); salary and employment details; date of birth;

We may use or process your Personal Information from Stafflink customers for reasons including, without limitation:

To assist our customers to process and perform their real estate or property management and sales tasks, such as your tenancy application or property application, or their customer service functions

Through their use of our services, our customers may direct us to share your Personal Information to:

Property owners/ landlords or property managers;
Third parties connected with the processing of your tenancy or property application, or delivery of real estate or property management services, including platform integrations or other intermediate services that our Stafflink customers may turn on, payment gateway providers and financial institutions.
Service providers (including our IT service providers and consultants) who assist us in providing our services.
As required or authorised by law.

1.3 Personal Information that Stafflink collects itself

Separate from the types of Personal Information we may process for Stafflink customers, we may collect Personal Information from prospective customers, our customers’ representatives or affiliates, our careers applicants and our team members.

We collect, use and disclose this Personal Information for the primary purposes (and any reasonably expected secondary purposes) for which it was collected or as consented to by you.

At or as soon as possible after the time when we collect Personal Information from you, we will give you a notice which outlines how and why we collect, use and disclose that specific information.

The table below sets out general circumstances in which we collect, use or disclose your Personal Information.

Purpose	Type of Information	Uses	Disclosures
Provision of Stafflink services, including The Hub subscriptions, Online enquiries, and Customer service	The Hub subscribers or end users: Subscribers: Name; email address; job title/position; phone number/s; payment card (debit/credit) or account particulars for subscription payment End users: Name; email address; job title/position; phone number/s; any other personal information (if any) voluntarily provided by a user in their profile. Online enquiries: Name, email address; username and password; any other personal information (if any) voluntarily provided in an enquiry Marketing: Name, work email address or work phone number details, from direct marketing lists.Customer service: Information collected in connection with technical support or service requests. Name, email address; and any other personal information (if any) voluntarily provided in a support enquiry.	The types of uses we will make of Personal Information collected for this type of purpose include: Services: the provision of our services including: Providing access to, and use of, The Hub or other online services offered by Stafflink. Verification of identity, if required. Payment processing, including charging, payment authorisation, verification and debt collection. Checks for financial standing and credit-worthiness (as detailed in our Credit Reporting Policy). To provide customer service functions, including handling Stafflink customer enquiries and complaints. Direct Marketing and analytics: using your Personal Information. in to aggregate with other information and to then use it for marketing and consumer analytics. to offer you updates on services, events or information that may be of interest to you. for Marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts, product awareness information and newsletters. General administrative and security use: To protect Stafflink’s website from security threats, fraud or other criminal activities. The use for the administration and management of Stafflink. The maintenance and development of our services, business systems and infrastructure. In connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink entity. To communicate any announcements and updates, updated terms, conditions and policies, security alters, technical notices, support and administrative messages associated with Stafflink’s goods and services.	The types of disclosures we will make of Personal Information collected for the type of purposes listed include, without limitation, to: Directors, employees, officers and contractors of Stafflink. Third parties connected with the sales process including ecommerce, payment gateway providers and financial institutions. Service providers (including IT service providers and consultants) who assist Stafflink in providing our services. Related bodies corporate of Stafflink (including related entities). Third parties in connection with the sale of all or any part of Stafflink’s business or a company owned by a Stafflink entity. As required or authorised by law.
Human resources (careers applicants or Stafflink team members)	Contact information: Such as full name, e-mail address, current postal and residential address, phone numbers, country of residence, and name and phone number of your nominated emergency contact person. Employee record information Identifying information: Such as your photo, driver licence or passport; residency details; and date of birth. CV, resume or application related information: Such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications. Tax, superannuation and payroll information: Such as your Tax File Number and TFN Declaration, superannuation account and salary account details. Background check information: Information obtained from you or third parties, such as your name and government identification document particulars for the purpose of performing background checks. Fingerprint mask or hash: A computed hash of your fingerprint or handprint data. Information collected from referees. Security recording information: such as CCTV footage and photographs taken on our premises. Online call/ conference recordings: your name, likeness and voice, and any other personal information you may disclose during online audio or video calls (such as on Zoom).	Background checks: Utilising the information collected for the purpose of assessing candidate suitability for role, including by obtaining: Verification of your identity and age. If required, criminal history background checks. Confirmation of eligibility to work in Australia. Confirmation of education and qualifications. Confirmation of previous employment. Consideration regarding medical leave. Administration and performance monitoring use: Utilising the information collected for the purpose of: Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be). Use of such information whether or not the employment or contractor relationship is prospective, current or past. Use of such information to monitor systems, performance and time usage and internet usage. Physical security controls such as controlled access to Stafflink’s place/s of business. The use of your Personal Information collected in the administration and management of Stafflink. In connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink entity.	We may disclose your Personal Information to: Relevant superannuation company. Government agencies, including but not limited to the Australian Taxation Office, Centrelink and Child Support Agency. Relevant Worker’s Compensation organisation (e.g. WorkCover etc). Third party referees provided by you in connection with an application made to Stafflink. Service providers (including IT service providers and payroll providers), if any. Recruitment agents used in connection with your application with us. Third parties in connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink’s entity. Third party parties in connection with obtaining any background checks, pre-employment screening. Financial institutions for payroll purposes. As required or authorised by law.

Purpose

Type of Information

Uses

Disclosures

Provision of Stafflink services, including The Hub subscriptions, Online enquiries, and Customer service

The Hub subscribers or end users:

Subscribers: Name; email address; job title/position; phone number/s; payment card (debit/credit) or account particulars for subscription payment
End users: Name; email address; job title/position; phone number/s; any other personal information (if any) voluntarily provided by a user in their profile.

Online enquiries:

Name, email address; username and password; any other personal information (if any) voluntarily provided in an enquiry

Marketing: Name, work email address or work phone number details, from direct marketing lists.Customer service: Information collected in connection with technical support or service requests.

Name, email address; and any other personal information (if any) voluntarily provided in a support enquiry.

The types of uses we will make of Personal Information collected for this type of purpose include:

Services: the provision of our services including:

Providing access to, and use of, The Hub or other online services offered by Stafflink.
Verification of identity, if required.
Payment processing, including charging, payment authorisation, verification and debt collection.
Checks for financial standing and credit-worthiness (as detailed in our Credit Reporting Policy).
To provide customer service functions, including handling Stafflink customer enquiries and complaints.

Direct Marketing and analytics: using your Personal Information.

in to aggregate with other information and to then use it for marketing and consumer analytics.
to offer you updates on services, events or information that may be of interest to you.
for Marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts, product awareness information and newsletters.

General administrative and security use:

To protect Stafflink’s website from security threats, fraud or other criminal activities.
The use for the administration and management of Stafflink.
The maintenance and development of our services, business systems and infrastructure.
In connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink entity.
To communicate any announcements and updates, updated terms, conditions and policies, security alters, technical notices, support and administrative messages associated with Stafflink’s goods and services.

The types of disclosures we will make of Personal Information collected for the type of purposes listed include, without limitation, to:

Directors, employees, officers and contractors of Stafflink.
Third parties connected with the sales process including ecommerce, payment gateway providers and financial institutions.
Service providers (including IT service providers and consultants) who assist Stafflink in providing our services.
Related bodies corporate of Stafflink (including related entities).
Third parties in connection with the sale of all or any part of Stafflink’s business or a company owned by a Stafflink entity.
As required or authorised by law.

Human resources (careers applicants or Stafflink team members)

Contact information: Such as full name, e-mail address, current postal and residential address, phone numbers, country of residence, and name and phone number of your nominated emergency contact person.

Employee record information

Identifying information: Such as your photo, driver licence or passport; residency details; and date of birth.

CV, resume or application related information: Such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications.

Tax, superannuation and payroll information: Such as your Tax File Number and TFN Declaration, superannuation account and salary account details.

Background check information: Information obtained from you or third parties, such as your name and government identification document particulars for the purpose of performing background checks.

Fingerprint mask or hash: A computed hash of your fingerprint or handprint data.

Information collected from referees.

Security recording information: such as CCTV footage and photographs taken on our premises.

Online call/ conference recordings: your name, likeness and voice, and any other personal information you may disclose during online audio or video calls (such as on Zoom).

Background checks: Utilising the information collected for the purpose of assessing candidate suitability for role, including by obtaining:

Verification of your identity and age.
If required, criminal history background checks.
Confirmation of eligibility to work in Australia.
Confirmation of education and qualifications.
Confirmation of previous employment.
Consideration regarding medical leave.

Administration and performance monitoring use: Utilising the information collected for the purpose of:

Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
Use of such information whether or not the employment or contractor relationship is prospective, current or past.
Use of such information to monitor systems, performance and time usage and internet usage.
Physical security controls such as controlled access to Stafflink’s place/s of business.
The use of your Personal Information collected in the administration and management of Stafflink.
In connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink entity.

We may disclose your Personal Information to:

Relevant superannuation company.
Government agencies, including but not limited to the Australian Taxation Office, Centrelink and Child Support Agency.
Relevant Worker’s Compensation organisation (e.g. WorkCover etc).
Third party referees provided by you in connection with an application made to Stafflink.
Service providers (including IT service providers and payroll providers), if any.
Recruitment agents used in connection with your application with us.
Third parties in connection with the sale of any part of Stafflink’s business or a company owned by a Stafflink’s entity.
Third party parties in connection with obtaining any background checks, pre-employment screening.
Financial institutions for payroll purposes.
As required or authorised by law.

2. How Stafflink collects and holds Personal Information

2.1 Collection generally

As noted in Section 1.1, Stafflink may receive your Personal Information from or on behalf of our customers who use our services, which in those circumstances, is the customer who has collected your Personal Information. Accordingly, we simply process your Personal Information in accordance with the customer’s instructions. This affects our legal obligations towards your Personal Information, and also how you can exercise the rights described in Section 10 further below.

This Section 2 describes how Stafflink collects the limited types of Personal Information (as described in Section 1.3) from our customer’s representatives or affiliates, our careers applicants and team members.

As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your Personal Information in Stafflink data directly from you. When you engage in certain activities, such as filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we may be unable to provide our services, respond to your enquiry, or process your careers application, whether in an effective manner, or at all.

2.2 Other collection types

We may also collect Personal Information about you from other sources and third parties. Some examples of these alternative collection events are:

when we collect Personal Information about you from third parties; or
when we collect Personal Information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram, etc).

2.3 Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause 2.3(a) to 2.3(c) below.

Generally speaking, we will not tell you when we collect Personal Information about you in the following circumstances:

where information is collected from any personal referee you have listed on any application form (including any employment application) with Stafflink;
where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or
as otherwise required or authorised by law.

2.4 Unsolicited Personal Information

In the event we collect Personal Information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Stafflink (in its absolute discretion) that the Personal Information is not required, we will destroy the information or ensure that the information is de-identified.

In the event that the unsolicited Personal Information collected is in relation to potential future employment with Stafflink, such as your CV, resume or candidacy related information, and it is determined by Stafflink (in its absolute discretion) that it may consider you for potential future employment, Stafflink may keep the Personal Information on its human resource records.

2.5 How we hold your Personal Information

Once we collect your Personal Information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act. We provide some more general information on our security measures in Section 9 (Data security and quality).

2.6 Cookies and IP addresses

If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.

We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our systems or services. This information does not identify you personally.

However, in some cases, cookies may enable us to aggregate certain information with other Personal Information we collect and hold about you. Stafflink extends the same privacy protection to your Personal Information, whether gathered via cookies or from other sources, as detailed in this Privacy Policy.

You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer.

2.7 Links to third-party websites

Our website or services may contain links to websites which are owned or operated by third parties. Stafflink has no control over, makes no representation about, and will not be responsible or liable for, the information privacy practices or content of these third party websites. You remain responsible for checking the privacy policy of any such websites and applications so that you can be informed of how they will handle your Personal Information.

3. Uses and disclosures of Personal Information

3.1 Use and disclosure details

We provide a detailed list at Section 1 of some common uses and disclosures we make regarding the Personal Information we collect.

3.2 Other uses and disclosures

We may also use or disclose your Personal Information and in doing so we are not required to seek your additional consent:

when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your Personal Information to be used or disclosed for such a purpose;
if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
if it is required or authorised by law.

3.3 Use and disclosure procedures

In the event we propose to use or disclose such Personal Information other than for reasons set out in the above table at Section 1 or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your Personal Information is disclosed to these organisations or parties only in relation to the services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your Personal Information.

3.4 Communications opt-out

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out in Section 11 of this document and we will ensure the relevant communication ceases.

Any other use or disclosure we make of your Personal Information will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

4. Sensitive information

4.1 Sensitive information generally

Sensitive information is a subset of Personal Information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

4.2 Collection and use of sensitive information

In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our services this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.

The type of sensitive information we may collect about you is dependent on the services provided to you by Stafflink will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the “Human resources” section of the table at Section 1 above.

We do not use sensitive information to send you Direct Marketing Communications (as set out in Section 5 below) without your express consent.

4.3 Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

5. Direct Marketing

5.1 Application

This section 5 applies to information collected directly by Stafflink from prospective customers or customers, career applicants or team members.

It does not apply where we receive your personal information from or on behalf of a Stafflink customer. In such cases, we may (as a service provider to our customer) assist our customer to transmit their direct marketing messages to you, in which case the provisions in our customer’s privacy policy apply to their direct marketing to you (even where we may assist the customer in the delivery of messages to you.)

5.2 Express informed consent

You give your express and informed consent to us using your Personal Information set out in:

the “Sales and Enquiries” section of the table at Section 1.3 of this document above; and
the “Marketing Services” section of the table at Section 1.3 of this document above;

to provide you with information and to tell you about our services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

5.3 Inferred consent and reasonable expectations of direct marketing

Without limitation to paragraph 5.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your Personal Information the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

5.4 Opt-out

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 5, you may ask us not to send you any further information about services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out in Section 11 of this document.

6. Credit Information and our Credit Reporting Policy

6.1 Credit information generally

The Privacy Act 1988 (Cth) contains provisions regarding the use and disclosure of credit information, which applies in relation to the provision of both consumer credit and commercial credit.

6.2 Credit information and Stafflink

As we provide terms of payment of accounts which are greater than 7 days, we are considered a credit provider under the Privacy Act in relation to any credit we may provide you (in relation to the payment of your account with us).

We use credit related information for the purposes set out in the “Credit information” section of the table at Section 1 above and our Credit Reporting Policy which includes but is not limited to using the information for our own internal assessment of your credit worthiness.

6.3 Storage and access

We will store any credit information you provide us, or which we obtain about you, with any other Personal Information we may hold about you.

You may request to access or correct your credit information in accordance with the provisions of Section 10 and the provisions of our Credit Reporting Policy.

6.4 Complaints

Please see Section 11 and the provisions of our Credit Reporting Policy if you wish to make a complaint in relation to our handling of your credit information.

6.5 Our Credit Reporting Policy

Please see our Credit Reporting Policy for further information as to the manner in which we collect, use, store and disclosure credit information.

7. Anonymity and pseudo-anonymity

To the extent practicable and reasonable, we will endeavour to provide you with the option of dealing with Stafflink on an anonymous basis or through the use of a pseudonym. However, there may be circumstances in which it is no longer practicable for Stafflink to correspond with you in this manner and your Personal Information may be required in order to provide you with our services or to resolve any issue you may have.

8. Cross Border Disclosure

8.1 Application

Personal information uploaded or transferred by our customers into Stafflink’s online services or platforms as described in the table in section 1.2, is processed by Stafflink on our customers’ behalf and according to their directions. As such personal information is stored on servers in Australia, this section 8 does not apply to those types of personal information.

This section does apply to types of personal information collected, used and disclosed for the purposes described in the table in section 1.3, being personal information collected by Stafflink itself.

8.2 Cross border disclosures

Personal Information collected and held by Stafflink itself (and excluding Personal Information provided to us by or on behalf of Stafflink customers or their end users) as described in the table at section 1.3 may be disclosed to, and held at, a destination outside Australia, including but not limited to countries in the European Union or the United States, where we utilise third party service providers to assist Stafflink with supporting our careers applicants or employees, or providing our services to our customers. Personal Information collected by Stafflink itself may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.

As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed above.

In addition we may use overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist Stafflink with providing our services to you.

8.3 Provision of informed consent

By submitting your Personal Information to Stafflink, you expressly agree and consent to the disclosure, transfer, storage or processing of your Personal Information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to Personal Information. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

The Privacy Act requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your Personal Information outside of Australia do not breach the privacy principles contained within the Privacy Act. By providing your consent, under the Privacy Act, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting Personal Information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

8.4 If you do not consent

If you do not agree to the disclosure of your Personal Information outside Australia by Stafflink, you should (after being informed of the cross border disclosure) tell Stafflink that you do not consent. To do this, either elect not to submit the Personal Information to Stafflink after being reasonably informed in a collection notification or please contact us via the details set out in Section 11 of this document.

9. Data security and quality

9.1 Data security

We have taken steps to help secure and protect your Personal Information from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or Personal Information, especially where human error is involved or malicious activity by a third party.

Notwithstanding the above, we will take reasonable steps to:

make sure that the Personal Information we collect, use or disclose is accurate, complete and up to date;
protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
destroy or permanently de-identify Personal Information if it is no longer needed for its purpose of collection.

9.2 Accuracy

The accuracy of Personal Information depends largely on the information you provide to us, so we recommend that you:

let us know if there are any errors in your Personal Information; and
keep us up-to-date with changes to your Personal Information (such as your name or address).

We provide information about how you can access and correct your information in Section 10.

10. Access to and correction of your Personal Information

10.1 Your rights

You are entitled to have access to any Personal Information relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to or correct any records of Personal Information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out in Section 11 of this document.

10.2 Exercising your rights of access or correction

The ways in which you can exercise your rights as described in Section 10.1 will depend on whether a Stafflink customer, or Stafflink itself, has collected your personal information.

in respect of your Personal Information collected by a Stafflink customer and shared to Stafflink, please contact the relevant Stafflink customer directly and do not contact us. If you contact Stafflink to make your request, we will be required to redirect your request to the Stafflink customer and await their instructions before we take any other action, and this will likely mean a delay in responding to you.

If Stafflink is the data controller or collector of your Personal Information and you wish to exercise any of your rights described in Section 10.1 in respect of your Personal Information, then please send your request in writing to Stafflink at the details in Section 11 below. We will process your request promptly within receipt of receiving it.

10.3 Resolving privacy complaints

We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

11. Key contacts

11.1 Contacting Stafflink

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your Personal Information, please contact us:

Telephone: +61 7 3778 6267

Email: [email protected]

Post: Level 4, 2 King Street, Bowen Hills, Queensland 4006

Please mark your correspondence to the attention of the Privacy Officer.

Important: If you have any concerns or complaints about the manner in which a Stafflink customer may have handled or processed your Personal Information, please direct your request directly to the relevant Stafflink customer. If you make your request to Stafflink, we will need to re-direct it to the Stafflink customer so that they may respond to you.

11.2 Steps we take to resolve a complaint

To resolve a complaint, we:

request that you provide the details of the complaint in writing;
will liaise with you to identify and define the nature and cause of the complaint;
will keep you informed of the likely time within which we will respond to your complaint; and
will inform you of the legislative basis (if any) of our decision in resolving such complaint.

11.3 Register of complaints

We will keep a record of the complaint and any action taken in a Register of Complaints.

To resolve a complaint, we:

request that you provide the details of the complaint in writing;
will liaise with you to identify and define the nature and cause of the complaint;
will keep you informed of the likely time within which we will respond to your complaint; and
will inform you of the legislative basis (if any) of our decision in resolving such complaint.

11.3 Register of complaints

We will keep a record of the complaint and any action taken in a Register of Complaints.

12. Consent, modifications and updates

12.1 Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, Stafflink may incorporate the terms of this policy such that:

certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Stafflink, but do create contractual obligations on the other party to the contract; and
the consents provided in this policy become contractual terms provided by the other party to the contract.

12.2 Acknowledgement

By using our website, or purchasing a service from Stafflink, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

to provide the consents given by you in this Privacy Policy; and
that you have been informed of all of the matters in this Privacy Policy.

12.3 Modifications and updates

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information due to the changes in our Privacy Policy, please cease providing us with your Personal Information and contact us via the details set out in Section 11 of this document.

Privacy Policy – Stafflink Pty Ltd

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