Privacy Policy

1. Introduction

We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This policy applies to information collected by Lloyd Connect.

We 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 may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.

By following the links 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 .

1.1 APP Entity

Lloyd Connect 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

When we collect your personal information:

we check that 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. 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 and your 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 access 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 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

2. Kinds of information that we collect and hold

Personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as an employment agency and is likely to differ depending on whether you are:

a Workseeker
a Client
a Referee

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 and includes:

general contact and identification information such as name, address, email and phone number
information about your work history, education, experience, qualifications and skills
information about your eligibility to legally work within Australia, which may include copies of your passport, applicable visas or other relevant documentation
your tax file number and relevant bank and superannuation account information necessary to facilitate the payment of wages and superannuation contributions and to ensure appropriate taxation treatment
other information that may be relevant in the circumstances

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:

general contact and identification information such as name, address, email and phone number
details of current and past employment placement
your opinion of prospective of potential and/or successfully placed candidates
other information that may be relevant in the circumstances

2.3 For Referees

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 includes:

general contact and identification information such as name, address, email and phone number
details of current and past employment
your opinion of prospective of potential and/or successfully placed candidates
other information that may be relevant in the circumstances

3. Purposes

The purposes for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:

a Workseeker
a Client
a Referee

The following sections are also relevant to our use and disclosure of your personal information:

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
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
recruitment functions
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

3.4 Our Policy on Direct Marketing

From time to time, your personal information may be used by Lloyd Connect employees inform you about:

job vacancies
market or industry news
relevant promotions

Lloyd Connect complies with the anti-spam laws of Australia: The Spam Act 2003

We will include ‘Unsubscribe’ links in all mass email campaigns. Anyone who opts out will not be contacted again. At any time should you wish change your preference in relation to receiving direct marketing please contact us.

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

We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.

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 forms, apply to a position advertised on the Lloyd Connect website or any other information in connection with your application to us for work.

Personal information is also collected when:

you submit an application form or your resume through a third-party website
we interview you either over the phone, video conference or in person
we undertake reference checks by inquiring with, or we otherwise receive references or performance feedback (whether negative or positive) from, any of your former or current employers, work colleagues, professional associations or registration bodies (reference checks are only undertaken with your consent)
Social Networks and Web Searches – including LinkedIn, Seek and other industry specific job board search
we receive results of any medical tests or criminal history checks, (which are only undertaken with your consent)
we receive results from any competency tests in which you participate
we receive any complaint from or about you in the workplace
we receive information from your employer in relation to your employee benefits including rate or remuneration
we receive information about a workplace accident in which you were involved; and
we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were or are involved during, or in connection with, a work placement.

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

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

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. In the event we retain photos or images of you for use in the recruitment process, they will be retained unless you request they be destroyed.

4.5 Electronic Transactions

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
register as a site user to access facilities on our site such as a job notification board
make a written online enquiry or email us through our website
submit a resume or application by email or through our website

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

You can contact us by land line telephone or post if you have concerns about making contact via the Internet.

5. How your personal information is held

Personal information is 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 de-identified or destroyed, provided that it is lawful for us to do so.

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

misuse, interference and loss; and
unauthorised access, modification or disclosure.

5.1 Our Information Record System

Our Information Record System is a recruitment CRM system that stores data electronically. Information is stored on a server in a secure data room in Melbourne/Sydney in Australia.
If you forward Lloyd Connect an email via the email link on our website, or contact us directly to apply directly for a position, the information collected through the email will only be used for the purpose for which it is provided
Any digital records or email correspondence will also be stored in our Cloud storage provided by MS Outlook 365, whose servers are found within Australia. You can access the
Any physical records of your information are securely stored in on Lloyd Connect premises in Australia

5.2 Information Security

All electronic data is protected by multi-layer security systems both physical and online including IPS, authentication and firewalls.

The data in our Information Record System is securely stored with Job Adder Operations Pty Ltd. JobAdder are ISO-27001 Certified (international standard for Business Continuity Management Systems (BCMS)) and their privacy policy can be located here.

Any physical records of your personal information are securely stored on a Lloyd Connect premises in Australia. We de-identify personal information from our database or securely destroy physical copies as soon as the law permits, and provided that the information is no longer needed by Lloyd Connect.

6. Disclosures

We may disclose your personal information for any of the purposes for which it is primarily held or for a lawful related purpose.

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

Disclosure will usually be:

internally and to our related entities
to our Clients
to Referees for suitability and screening purposes.

6.1 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
Background checking and screening agents

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.

6.2 Cross-Border Disclosures

Some of your personal information is likely to be disclosed to overseas recipients. We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to 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.

For users in Australia, Microsoft OneDrive stores data primarily in Microsoft’s Australian data centers located in Sydney and Melbourne to support data residency and compliance with local laws. Microsoft also operates a global network of data centers across continents—including North America, Europe, and Asia.

Please click here to read Microsoft’s policies.

Amazon Web Services (AWS) stores data in the AWS Asia Pacific Region, based in Melbourne, Australia. Their ISO 27018 International code of practice focuses on protection of personal data in the cloud.

Please click here to read Amazon Web Services (AWS) policies.

The likely countries, type of information disclosed, and recipients are indicated, so far as is practicable, in the following table:

Country	Type of Information	Likely Recipients
Australia, New Zealand, North America, Europe, and Asia.	Personal data (including name, address, contact numbers) stored on servers located in the countries listed.	IT Personnel and Contractors of our technology providers who may access data for maintenance and software upgrade purposes.

7. Access & Correction

Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold. Important exceptions include:

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. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that the person who gave us that information is entitled to expect will be observed. We do refuse access if it would breach confidentiality.

7.1 Access Policy

If you wish to obtain access to your personal information you should contact our Privacy Co-Ordinator. You will need to be in a position to verify your identity.

Requests to access to your personal information will be acknowledged within 5 working days
Where possible such access will be granted within 30 working days
In the event there are circumstances restricting access within this time frame Lloyd Connect will advise you of these restrictions and communicate the revised timeframe

7.2 Correction Policy

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 are 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.

Requests to correct your personal information will be acknowledged within 5 working days
Where possible such corrections will be made within 30 working days
In the event there are circumstances restricting access within this time frame Lloyd Connect will advise you of these restrictions and communicate the revised timeframe

8. Complaints

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

8.1 Complaints procedure

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 Privacy Coordinator, by clicking here.

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

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

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

The RCSA Code is supported by rules for the resolution of disputes involving members.

NOTE: The Association Code and Dispute Resolution Rules do NOT constitute a recognised external dispute resolution scheme for the purposes of the APPs; but are primarily designed to regulate the good conduct of the Associations members.

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.

5.1 Our Information Record System﻿

5.1 Our Information Record System