2. What is personal information?
2.1 Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
3. The information we collect
3.1 We collect personal information that is reasonably necessary for one or more of our functions or activities.
3.2 The type of information that we collect may depend on your relationship with Aspect. For example:
a) Candidate: if you are a candidate being considered for employment by Aspect or one of our clients, Aspect may collect and hold information including your name, address, email address, contact telephone number, gender, age, employment history, references, resume, medical history, emergency contact, taxation details, qualifications and banking details.
b) Client: if you are a client of Aspect, we may collect information including your name, address, email address, contact telephone number, gender and age.
c) Supplier: if you are a supplier of Aspect, we may collect and hold information including your name, address, email address, contact telephone number, business records, billing information, information about goods and services supplied by you.
d) Referee: if you are a referee of a candidate being considered for employment by Aspect or one of our clients, we may collect information including your name, contact details, current employment information and professional opinion of candidate.
3.3 Sensitive information: the Company will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of the Company’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.
3.4 COVID-19 vaccination status
Many of our clients have implemented workplace vaccination policies requiring that people attending their workplaces or performing work for them be fully-vaccinated by an approved COVID-19 vaccine (unless the worker has evidence of a medical contraindication or other protected attribute).
At any one time, there may also be government or public health orders, directions or guidance in relation to vaccination of people in certain areas, industries or roles.
Aspect has also introduced a Workplace Vaccination Policy which sets out our position in relation to workplace vaccination for our internal and external workforce.
4. How we collect personal information
4.1 We may collect personal information in a variety of ways, including:
Directly: We collect personal information which you directly provide to us, including when you register a job, through the ‘contact us’ form on our website or when you request our assistance via email or over the telephone.
Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers, as well as from past and present employers and referees when conducting reference checks.
4.2 Much of the personal information that the Company holds is stored in our Information Record System. The Company’s Recruitment Management System (“RMS”) comprises of hard copy files and/or electronic files in the Company’s ordinary IT systems. These may include cloud servers or servers of third parties.
5. Collection and use of personal information
We may collect, hold, use and disclose personal information for the following purposes:
to enable you to access and use our services, including to provide you with a login;
to contact and communicate with you about our services;
for internal record keeping, administrative, invoicing and billing purposes;
for analytics, market research and business development, including to improve our services;
for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have;
if you have applied for employment with us; to consider your employment application; and
if otherwise required or authorised by law.
5.2 If you do not allow the Company to collect all or some of the personal information we request, the Company may not be able to achieve its purposes. For example, if you are a Candidate the Company may not be able to locate suitable work for you, or if you are a Client the Company may not be able to provide you with the product or service you are seeking.
5.3 Direct marketing
a) The Company may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new services being offered by the Company).
b) You can opt out of receiving direct marketing communications from Aspect by contacting the Privacy Officer in writing or by following the unsubscribe links contained within emails from us.
6. Disclosure of Personal Information
We may disclose personal information to:
third party service providers for the purpose of enabling them to provide their services to us, including IT service providers, data storage, web-hosting and server providers, couriers, maintenance or problem-solving providers, marketing or advertising providers and professional advisors;
our employees, contractors and/or related entities;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties to collect and process data, such as Google Analytics or other relevant analytics businesses; and
any other third parties as required or permitted by law, such as where we receive a subpoena.
We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Australian Privacy Principles.
Your rights and controlling your personal information
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the Office of the Australian Information Commissioner (OAIC).
7. Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
8. Aspect Personnel Privacy Officer contact details
Aspect’s Privacy Officer can be contacted in the following ways:
Company Privacy Officer: Matthew Sampson
Telephone number: 03 9092 7200
Email address: email@example.com
Postal address: Level 13, 385 Bourke St, Melbourne, VIC 3000
Revised: December 2021