Privacy policy

1. Introduction

This privacy policy applies to information collected by Pulse Staffing Australia Pty Ltd. We will only collect information that is reasonably necessary for the proper performance of our activities or functions.

We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it.

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.

By reading the information in this document, you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs).

If you have any questions please contact us at Pulse Staffing on (02) 9965 9456.

1.1. APP Entity

Pulse Staffing Australia manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).

Because we are a contracted service provider to a range of Commonwealth, State and Territory government agencies, it sometimes becomes necessary for us to collect and manage personal information as an Agency under different privacy arrangements. 

If you wish to know whether this applies to you, please contact us. 

1.2. Information Flow

We check that it is reasonably necessary for our functions or activities as a recruitment agency we check that it is current, complete and accurate. This will sometimes mean that we have to cross check the information that we collect from you with third parties;

  • We record and hold your information in our Information Record System. Some information may be disclosed to overseas recipients.
  • We retrieve your information when we need to use or disclose it for our functions and activities. At that time, we check that it is current, complete, accurate and relevant. This will sometimes mean that we have to cross check the information that we collect from you with third parties once again - especially if some time has passed since we last checked.
  • Subject to some exceptions, we permit you to your personal information in accordance with APP:12 of the APPs.
  • We correct or attach associated statements to your personal information in accordance with APP:13 of the APPs.
  • We destroy or de-identify your personal information when it is no longer needed for any purpose for which it may be used or disclosed provided that it is lawful for us to do so. We do not destroy or de-identify information that is contained in a Commonwealth Record.

1.3. Future Changes

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly or conduct transactions with us that involve to collection of your personal information, 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.

2. Kinds of information that we collect and hold

The type of personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as a recruitment agency and is likely to differ depending on whether you are:

  • A Workseeker- i.e. someone who is looking for a placement or work through us; or whom we have identified as person, who might be receptive to an offer of a placement or work through us
  • A Client- i.e. someone other than a Workseeker, who is looking to acquire our services as a recruitment agency or whom we have identified as someone, who might be interested in acquiring our services
  • A Referee - i.e. a person from whom we have sought facts or opinions regarding the suitability of one of our Workseekers for work or positions through us; and who may be a nominated by the Workseeker, a Client or us

Sensitive information is only collected with consent and where it is necessary for the performance of our functions and activities. Sensitive information will need to be collected where it relates to a genuine occupational requirement or an inherent requirement of the job or work being considered.

Our collection of some types of sensitive information is also governed by equal opportunity and antidiscrimination laws. 

2.1. For Workseekers

The type of information that we typically collect and hold about Workseekers is information that is necessary to assess amenability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us.

Personal Information: Personal information means information or an opinion about you, including information regarding your contact details, work experience, qualifications, aptitude test results, opinions about your work performance (eg references), incidents at the workplace, and other information obtained or received by us in connection with your possible and actual work placements.

Sensitive information: Is defined in the Privacy Act to mean information or an opinion about an individual’s:

  • Racial or ethnic origin
  • Political opinions
  • Membership of a political association
  • Religious beliefs or affiliations
  • Philosophical beliefs
  • Membership of a professional or trade association
  • Membership of a trade union
  • Sexual preferences or practices
  • Criminal record

‘Sensitive information’ also includes health information and genetic information about an individual that is not otherwise health information.

Pulse Staffing Australia will only collect ‘sensitive information’ with the consent of the candidate, except in specified circumstances.

‘Sensitive information’ will not be used or disclosed for a secondary purpose unless the secondary purpose is directly related to the primary purpose of collection and within the reasonable expectations of the individual.

Collection

We may collect personal or sensitive information about you when:
  • You complete one of our application forms or provide any other information in connection with your application online or in person
  • We receive any reference about you
  • We receive results of inquiries 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 or any background check
  • We receive any complaint or other information 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 were involved
  • We receive any information about a workplace accident in which you are involved
  • You provide us with any additional information about you

2.2. For Clients

The type of information that we typically collect and hold about Clients is information that is necessary to help us manage the presentation and delivery of our services and includes:

  • Client relationship information;
  • Information about position, contracting and hiring authority;
  • Information about team structures and roles;
  • Information about incidents in the workplace;
  • Information about the OH&S standards of the workplace

2.3. For Referees

As part of our compliancy and quality assurance, all candidates (workseekers) are required to give the contact details of recent references. All candidates are encouraged to notify the nominated referee that they may be expecting contact from a Pulse Staffing representative.

The type of information that we typically collect and hold about Referees is information that is necessary to help to make determinations about the suitability of one of our Workseekers for particular jobs or particular types of work and may include:

  • Information about work position, authority to give a reference and preferred contact details, opinions of the Referee regarding the Workseeker's character and work performance or work environment
  • Facts or evidence in support of those opinions, sometimes involving the Referee's own knowledge and experience of having worked with the Workseeker

All referees are required to answer a series of questions over the phone or via email correspondence prior to commencing the body of the reference. These questions ask for:

  1. The referee’s consent for the information disclosed in the reference to be made available to our client (relating to employment of the candidate)
  2. Consent for the referee’s name, role, workplace and contact number to be disclosed to the appropriate client
  3. Their consent for the document to be retained on file knowing that the candidate may request to view the document.

3. Purposes

The purposes for which we collect, hold, use and disclose your personal information are those purposes that are reasonably necessary for the proper performance of our functions and activities as an recruitment agency and are likely to differ depending on whether you are:

  • A Workseeker
  • A Client
  • A Referee
  • Our Policy on Direct Marketing
  • Overseas Disclosures

3.1. For Workseekers

Information that we collect, hold, use and disclose about Workseekers is typically used for:

  • Work placement operations
  • Recruitment functions
  • Staff management
  • Payment purposes
  • Training needs assessments
  • Risk management
  • Work health and safety operations
  • Marketing services to you; but only where this is permitted and whilst you are registered with us
  • Statistical purposes and statutory compliance requirements

3.2. For Clients

Personal information that we collect, hold, use and disclose about Clients is typically used for:

  • Client and business relationship management
  • Work placement operations
  • Recruitment functions
  • Training needs assessments
  • Risk management
  • Work health and safety operations
  • Marketing services to you
  • Statistical purposes and statutory compliance requirements

3.3. For Referees

Personal information that we collect, hold, use and disclose about Referees is typically used for:

  • To confirm identity and authority to provide references
  • Workseeker suitability assessment
  • Recruitment functions
  • Risk management

3.4. Our Policy on Direct Marketing

The personal information you have provided to Pulse Staffing Australia may be used to make future contact with you regarding relevant employment opportunities with Pulse or suitable clients.

  • Your information will only be accessed by the staff at Pulse Staffing, on our secure database
  • Your personal information will not be accessed by any third parties for marketing purposes
  • We will seek your verbal approval to keep your personal details on our database
  • If you verbally disclose that you do not wish to to be kept on our database, your details will be disposed of confidentially and you will not receive further contact from Pulse Staffing
  • Candidates are required to give verbal consent if they would wish to keep their details on our database

4. How your personal information is collected

The means by which we will generally collect your personal information are likely to differ depending
on whether you are:

  • A Workseeker
  • A Client
  • A Referee

Sometimes the technology that is used to support communications between us will provide personal information to us - see the section in this policy on Electronic Transactions.

See also the section on Photos & Images.

4.1. For Workseekers

Personal information will be collected from you directly when you fill out and submit one of our application/ registration 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 inquiries that we might make of your former employers, work colleagues, professional associations or registration body
  • We receive the results of any competency, psychometric, or medical test
  • We receive performance feedback (whether positive or negative)
  • We receive any complaint from or about you in the workplace
  • We receive any information about a workplace accident in which you are involved
  • 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 the section in this policy on Electronic Transactions

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APPs and our Privacy Policy.

4.2. For Clients

Personal information about you may be collected:

  • When you provide it to us for business or business related social purposes
  • Electronically through our telecommunications and technology systems – see the section in
    this policy on Electronic Transactions

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APPs and our Privacy Policy.

4.3. For Referees

Personal information about you may be collected when you provide it to us: 

  • In the course of our checking Workseeker references with you and when we are checking information that we obtain from you about Workseekers
  • For business or business related social purposes
  • Electronically through our telecommunications and technology systems – see the section in this policy on Electronic Transactions

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the APPs and our Privacy Policy.

4.4. Photos & 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 images of you. You should also read the section about Electronic Transactions because sometimes your communications with us may attach profile images of yourself that you have uploaded to the Internet.

4.5. Electronic Transactions

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 the OAIC's resource on Internet Communications and other Technologies.

It is important that you:

  • Know your rights: read our privacy policy, collection statement and consent to electronic transactions.
  • 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 is up-to-date.

Please contact us by land line phone or mail if you have concerns about making contact via the Internet.

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 a job notification list
  • Make a written online enquiry or email us through our website
  • Submit a resume by email or through our website

4.6. 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 may conduct Internet searches using search engines and entering your name and relevant identifying details.

4.7. Web Browsing

On certain pages of our website we will ask you to provide us with certain information about yourself. We maintain strict security standards and procedures with a view to preventing unauthorised access to your data. We use leading technologies such as (but not limited to) data encryption, firewalls and server authentication to protect the security of your data. All Group companies, all our staff and whenever we hire third parties to provide support services, are
required to observe our privacy standards and to allow us to audit them for compliance.

4.8. Cookies

Cookies are tiny text files stored on your computer when you visit certain web pages. We use cookies to keep a record of what country section of the website you were most recently viewing, so that next time you come to our site we can load that country for you. Some of the pages on our site also use cookies set by carefully selected 3rd party suppliers. None of our cookies store personal information.

We're giving you this information as part of our initiative to comply with recent legislation, and to make sure we're honest and clear about your privacy when using our website.

4.8.1. Our Cookie Policy

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.

To make your experience on our websites as specific to your needs as possible you will need to accept cookies. Our cookies do not store sensitive information such as your name or address they simply inform us of your past and current browsing behaviour i.e. what country you were last looking at, what browser you use and how many times you visit the site. If you'd prefer to restrict, block or delete cookies from our website, or any other website, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.

4.8.2. 3rd Party Cookies

When you visit our websites you may notice some cookies that aren't to our websites, these are cookies set by 3rd parties. One piece of 3rd party software that we use, called Google Analytics, uses cookies to measure how many visits we get to our website. In addition to this, if you go on to a web page on our site that contains embedded content, you may be sent cookies from these websites. We don't control the setting of these cookies, and suggest you check the third-party websites for more information about their cookies and how to manage them.

If you'd like to learn more about cookies in general and how to manage them, visit www.aboutcookies.org.

4.9. Uploading Photographs

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.

4.10. Emails

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 for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

4.11. Call & Message Logs

Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display, which may include your profile picture if you have provided it.

When your call number is received by us because you phone us or send us a message, the number (and profile picture) 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 purpose without your consent other than as may be permitted or required by law.

4.12. Teleconferences & Video

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.

4.13. Database

We use recruiting software and databases to log and record recruitment operations.

4.14. Mobile Access

Our staff use laptops, phones and other portable electronic devices that allow them to access, retrieve and store your personal information.

4.15. Paperless Office

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 digitised 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.

5. How your personal information is held

When your personal information is collected it will be held in our Information Record System until it is no longer needed for any purpose for which it may be used or disclosed at which time it will be deidentified or destroyed provided that it is lawful for us to do so.

All personal information on paper record will be destroyed after 12 months of the candidate requesting to end employment with our agency. Financial details will be kept by Pulse Staffing Australia for 7 years post termination of employment in accordance with the Australian Privacy Law guidelines.

Your personal information may be accessed by our staff and disclosed in accordance with the APPs.

We take a range of measures to protect your personal information.

There are some inherent risks in the use of the Internet Communications and other Technologies

It is important that you read the section on Electronic Transactions if you are using Internet Communications or other technologies to communicate with us.

You should also read the section on Cross-Border Disclosures.

5.1. Our Information Record System

Information is stored in hard copy and electronic format. All hardcopy documents are stored and locked for confidentiality, and can only be accessed by the staff at Pulse Staffing Australia.

All confidential documents will also be stored on our server.

5.2. Information Security

We take a range of measures to protect your personal information from:

  • Misuse, interference and loss
  • Unauthorised access, modification or disclosure

We may disclose your personal information where we are under a legal duty to do so.

Disclosure of information will usually be:

  • Internally and to our related entities
  • To our Clients
  • To Referees for suitability and screening purposes

In addition to disclosures for general purposes, we may also disclose your personal information for a range of related purposes.

5.3. Related Purpose Disclosures

We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically our CSPs would include:

  • Software solutions providers
  • I.T. contractors and database designers and Internet service suppliers
  • Legal and other professional advisors
  • Insurance brokers, loss assessors and underwriters
  • Superannuation fund managers

We take reasonable steps to ensure that 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 those obligations.

5.4. Cross-Border Disclosures

Some of your personal information is likely to be disclosed to overseas recipients in the United Kingdom of Great Britain.

Table

CountryType of informationLikely Recipients
The United Kingdom of Great
Britain
Personal data submitted on the
pulsejobs.com website
IT Personnel and Contractors of our
technology providers who may access
data for maintenance and software
upgrade purposes Independent
Clinical Services Group- our parent
company

We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles.However we cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought be protected. The costs 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.

See also Electronic Transactions.

6. Access & Correction

You have a right to access and correct personal information under the Australian Privacy Principles (APPs). 

6.1. Access

Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you.

  • 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 communicator of that information is entitled to expect will be observed.
  • If you wish to obtain access to your personal information you should contact our Compliancy Officer. You will need to be in a position to verify your identity.
  • We might impose a moderate charge in providing access. Our Compliancy Officer would discuss these 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 10 working days.
  • If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice that sets out:
  • The reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so
  • The mechanisms available to complain about the refusal.

6.2. Correction

If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us.

We will take such steps as re reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.

If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third parties to whom we made the disclosure and we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.

You should also anticipate that it may take a little time to process your application for correction as there may be a need to retrieve information from storage and review information in order to determine what information may be corrected. We will generally respond to your request for access within 7 working days.

There is no charge to correct information.

In some cases we may not agree that the information should be changed.

If we refuse to correct your personal information as requested by you, we will give you a written notice that sets out:

  • The reasons for the refusal except to the extent that it would be unreasonable to do so; and
  • The mechanisms available to complain about the refusal.

You may also ask us to associate a statement that the information is contested as being inaccurate,
out of date, incomplete, irrelevant or misleading and we will take such steps as are reasonable to
do so.

7. Complaints

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.

7.1. How to complain

If you are making a complaint about our handling of your personal information, it should first be
made to us in writing.

You can make complaints about our handling of your personal information to our Manager, whose contact details are; Mandy Sheen, Suite 3, Level 1, 189 Kent street, Sydney NSW 2000.

You can also make complaints to the Office of the Australian Information Commissioner.

Complaints may also be made to the RCSA industry association of which we are a member.

RCSA administers a Code of Conduct for the professional and ethical conduct of its members.

7.2. How your complaint will be handled

When we receive your complaint:

  • We will take steps to confirm the authenticity of the complaint and the contact details provided to us to ensure that we are responding to you or to a person whom you have authorised to receive information about your complaint
  • Upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy
  • We may ask for clarification of certain aspects of the complaint and for further detail
  • We will consider the complaint and may make inquiries of people who can assist us to established what has happened and why
  • We will require a reasonable time (usually 30 days) to respond
  • If the complaint can be resolved by procedures for access and correction we will suggest these to you as possible solutions
  • If we believe that your complaint may be capable of some other solution we will suggest that solution to you, on a confidential and without prejudice basis in our response

If the complaint cannot be resolved by means that we propose in our response we will suggest that you take your complaint to any recognised external dispute resolution scheme to which we belong or to the Office of the Australian Information Commissioner.