The policy explains how Transition Recruitment & Labour Hire Pty Ltd (TRLA) handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APP).
All TRLH employees and stakeholders are required to adhere to this policy when the work they perform falls within the policy's scope
Personal information is defined under the Privacy Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable. For example, personal information may include:
- an individual's name, signature, address, phone number or date of birth
- sensitive information
- credit information
- employee record information
- internet protocol (IP) addresses
- voice print and facial recognition biometrics (because they collect characteristics that make an individual's voice or face unique)
- location information from a mobile device (because it can reveal user activity patterns and habits)
NOTE: The definition of personal information only relates to 'natural' persons. It does not extend to other 'legal' persons, such as companies.
Privacy Act 1988 (Privacy Act) is an Australian law that regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information.
The Privacy Amendment (Enhancing Privacy Protection) Act 2012 introduced many significant changes to the Privacy Act, including 13 Australian Privacy Principles (APPs) that apply to the handling of personal information.
Australian Privacy Principles (APPs) are a set of rules based on principles. This allows a company or government body to customise their personal data handling procedures to their business models and the various demands of individuals. They are also technology agnostic, allowing them to adapt to new developments.
Sensitive Information - Under the Privacy Act, sensitive information is defined as personal information that includes information or an opinion about an individual's:
- racial or ethnic origin
- political opinions or associations
- religious or philosophical beliefs
- trade union membership or associations
- sexual orientation or practices
- criminal record
- health or genetic information
- some aspects of biometric information
USI - Unique Student Identifier is an individual's education identifier for life. It also creates an online record of their training attainments in Australia. When undertaking either nationally recognised training, or a higher education qualification, students need a USI in order to receive commonwealth financial assistance, as well as to obtain their qualification or statement of attainment.
Clients, customers, workers, contractors, and other individuals provide TRLH with personal information. This data is gathered only when it is required for our operations. It may only be collected in a fair and lawful manner, without becoming excessively intrusive. When it is acceptable and practicable, personal information must be gathered directly from an individual.
Individuals may contribute personal information to us through forms, face-to-face interactions, email messages, telephone calls, or third-party sources. When an individual contacts TRLH, a record of that contact may be retained.
TRLH will only gather sensitive personal information with the consent of the individual, such as his or her racial or ethnic origin, political opinions, religious beliefs, trade union participation, and criminal background, unless
- collection of such information is required by law, or
- information is needed to prevent or lessen a serious and imminent threat to life or health of any person.
Use of personal information
The main purposes in collecting personal information about individuals are:
- to provide our services
- to respond to an individual's request
- to maintain contact with clients, staff, employees and students
- to keep contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings and other events we are holding
- for general management and reporting purposes, such as invoicing and account management
- for recruitment purposes
- for purposes related to the employment of our personnel and providing internal services to our staff and,
- all other purposes related to our business.
If we collect or use personal information in ways other than those described in this policy, we will do so in accordance with the Privacy Act's requirements.
Employee records are not normally covered by the Privacy Act, so this policy may not apply to TRLH's processing of employee information. Please contact us directly if you have any questions concerning our employee information practises.
Personal information about a student may be requested to be sent to the National Centre for Vocational & Educational Research (NCVER) on a form that does not identify the student and maintains confidentiality.
Disclosure of personal information
TRLH will only share personal information with third parties for the purposes for which it was acquired. However, we may use the information for additional purposes only with the consent of the individual or if the subject would reasonably expect their information to be used in this way.
Disclosure to Service Providers
Personal information is given to several service providers used by TRLH. Providers who operate TRLH's IT, payroll, and student administration systems are among them. A contract is agreed into to protect the personal information TRLH discloses, requiring the service provider to only use or disclose information for the purposes of the contract.
Access to Personal Records
TRLH will provide access to personal information upon request, except in the few cases where it is entitled to withhold it (for example, if allowing access would infringe on the privacy of another person).
Requests to view personal files must be made in writing detailing the specific information required. TRLH may ask for identification (such as driver's license or passport) to verify the identity of the person to whom the information relates. Requests can be submitted to Transition Recruitment & Labour Hire via email: firstname.lastname@example.org
All records are stored on TRLH's dedicated servers, and a backup copy of the data is stored offsite and in the cloud.
Restricted access is enforced on files that hold sensitive information to ensure authorised access only.
TRLH will always take reasonable steps to ensure the security of physical files (including student files), computers, networks and communications are maintained.
Further details can be obtained by contacting the allocated Field Officer at Transition Recruitment & Labour Hire.