1. Introduction

Recruitly Pty Ltd (Recruitly) manages personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APPs). We protect personal information and collect only what is necessary for the proper performance of our work.

This policy explains how we manage personal information as an APP Entity and outlines the information flows associated with that information.

1.1 APP Entity

Recruitly manages personal information as an APP Entity under the Australian Privacy Principles.

As a contracted service provider to various government agencies, we may also collect and manage personal information as an Agency under different privacy arrangements.

1.2 Information Flow

When we collect your personal information:

• we confirm it is reasonably necessary for our functions or activities as an employment agency and on-hire firm

• we check that it is current, complete and accurate, including cross checking with third parties where required

• we record and store your information in our Information Record System. Some information may be disclosed to overseas recipients

• when retrieving information for use or disclosure, we again check that it is current, complete, accurate and relevant

• subject to exceptions, we allow access to your personal information in accordance with APP 12

• we correct information or attach associated statements in accordance with APP 13

• we destroy or de-identify information when no longer required, provided this is lawful

2. Kinds of Information That We Collect and Hold

The personal information we collect depends on whether you are a:

• Work seeker

• Client

• Referee

2.1 For Work Seekers

We typically collect information necessary to assess suitability for work opportunities or manage performance in roles obtained through us, including:

• contact and identification details

• education, work history, qualifications and skills

• opinions of others regarding work performance (with consent)

• work rights and eligibility documents

• sensitive information such as health data or criminal record (with consent)

• results of relevant tests

• tax file number, bank and superannuation information

• driver's licence details and related history

• other relevant information

2.2 For Clients

Information collected includes:

• role descriptions

• information about candidates

• business structure and contact details

• your opinions about Recruitly services or staff

2.3 For Referees

Information collected includes:

• contact and identification details

• your opinions about Work seekers

Purposes

We collect, hold, use and disclose personal information for purposes relevant to whether you are a:

• Work seeker

• Client

• Referee

Relevant sections:

• Direct Marketing

• Overseas Disclosures

3.1 For Work Seekers

Information is used for:

• work placement

• recruitment

• responding to queries

• psychometric and skills testing

• marketing our services

• statistical and compliance purposes

3.2 For Clients

Information is used for:

• relationship management

• recruitment

• marketing

• statistical and compliance purposes

3.3 For Referees

Information is used for:

• confirming identity

• assessing Work seeker suitability

• recruitment functions

3.4 Direct Marketing

Recruitly may use personal information to inform you about:

• job vacancies

• industry news

• promotions

We comply with the Spam Act 2003 and include unsubscribe links in all mass communications.

4. How Your Personal Information Is Collected

Collection methods differ for Work seekers, Clients and Referees.

We may collect information from third parties or publicly available sources.

4.1 For Work Seekers

Collected:

• through forms or CV submissions

• interviews

• reference checks (with consent)

• medical or criminal checks (with consent)

• competency testing

• workplace complaints or incident reports

• remuneration information from employers

• insurance or legal matters

• public sources such as media or online platforms

4.2 For Clients

Collected:

• through direct business contact

• through enquiry forms

• through publicly available sources

4.3 For Referees

Collected:

• during reference checks

• through publicly available sources

4.4 Photos & Images

We do not request photos or scanned ID unless required.
Retained images remain unless you request deletion.

4.5 Electronic Transactions

Information may be collected when individuals:

• join email lists

• register as site users

• submit online enquiries

• send resumes

• use online payroll or timesheet systems

The internet carries security risks. Contact us by phone or post if preferred.

5. How Your Personal Information Is Held

Information is retained in our Information Record System until no longer required and then destroyed or de-identified where lawful.

We protect information from:

• misuse, interference and loss

• unauthorised access, modification or disclosure

5.1 Information Record System

Our CRM stores electronic data in the cloud.
Physical records are securely stored on premises in Australia.

5.2 Information Security

Electronic data is protected by layered security measures including IPS, authentication and firewalls.
Physical documents are stored securely and shredded when disposed.

6. Disclosures

We may disclose personal information for primary purposes or lawful related purposes.

Disclosures may be made:

• internally

• to Clients

• to Referees for screening

6.1 Related Purpose Disclosures

Contracted service suppliers may access personal information, such as:

• IT and software providers

• legal advisors

• insurance providers

• superannuation administrators

• background checking services

• payroll and timesheet platform providers

6.2 Cross-Border Disclosures

We do not currently store information overseas.
If this changes, consent may be required due to limitations in foreign privacy protections.

7. Access & Correction

You may request access to personal information we hold, subject to exceptions such as:

• confidential evaluative material

• information affecting others’ privacy

7.1 Access Policy

• Contact our Privacy Coordinator

• Verify your identity

• Requests acknowledged within 5 business days

• Access provided within 30 business days where possible

7.2 Correction Policy

If information is inaccurate, incomplete, outdated or misleading, you may request correction.

If incorrect information has been disclosed to third parties, we will take reasonable steps to notify them unless unlawful or impracticable.

8. Complaints

You may complain if you believe your privacy has been interfered with.

8.1 Complaints Procedure

Complaints should be made in writing to our Privacy Coordinator.

You may also contact:

• Office of the Australian Information Commissioner

• RCSA (industry association)

When a complaint is received:

• we verify your identity

• we acknowledge receipt

• we may seek clarification

• we investigate

• we respond within 30 days

• we may suggest solutions

• unresolved issues may be referred to an external body or the OAIC

Privacy Coordinator

Julie Enticott – Director
Email: julie@recruitly.com.au