Privacy Policy

OUR OBLIGATIONS UNDER THE PRIVACY ACT

This Policy sets out how we must comply with our obligations under the Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs) in the Privacy Act which regulate how organisations may collect, use, disclose and store personal information, and how individuals may access and correct personal information held about them.

COLLECTION OF PERSONAL AND SENSITIVE INFORMATION

If you would like to access Jobs Hub services on an anonymous basis or using a pseudonym, please tell us. If this is possible and lawful, we will take all reasonable steps to comply with your request. However, we may not be able to provide the services in question if we are not provided with the personal information requested.

The nature and extent of your personal and sensitive information collected by Jobs Hub varies depending on your particular interaction with Jobs Hub.

Jobs Hub collects personal and sensitive information from clients/beneficiaries, donors, business partners, employees, volunteers and online users. Further information about the kind of information collected from each of these groups and the usage of such information is detailed below.

Jobs Hub Clients and Beneficiaries

Kind of information collected:

• Contact details (name, address, email etc).
• Personal details including date of birth, place of birth, gender, income.
• Government Identifiers (e.g. Job Seeker Identification Number, Customer Reference Number).
• Work history and educational qualifications.
• Languages (both written and spoken).
• Information on personal issues and experiences, relationships.
• Family and/or cultural background, supports clients may have in the community.
• Areas of interest.
• Health information and/or medical history.
• Credit card numbers or bank account details.
• Course details and results.
• A Police Check may be required for some student placements (particularly those placements that work with children, young people and other vulnerable individuals.) Individuals will be required to provide certain information for a Police Check.

How the information is collected:

• Forms.
• Online registration.
• Telephone.
• Email.

Purpose for which Jobs Hub uses the information:

• To provide Jobs Hub services.
• To provide clients/beneficiaries with the most appropriate services for their needs.
• To meet any requirements of government funding for our programs.
• To meet any government reporting requirements.
• To monitor and evaluate existing services and plan for future services.
• To produce annual reports and for research purposes which may involve contracted organisations.
• To comply with legal obligations.

Jobs Hub Donors

Kind of information collected:

• Contact details (name, address, email etc.)
• Personal details including date of birth, gender, income.
• Donation history.

How the information is collected:

• Communications, email, flyers.
• Telephone.
• Functions or events.

Purpose for which Jobs Hub uses the information:

• To provide Jobs Hub services.
• To process donations and provide accurate receipts.
• To facilitate ongoing fundraising and marketing activities.
• To comply with legal obligations.
• To provide transparency relating to donated funds, particularly for appeals and public donations.
• To recognise support of Jobs Hub.

Jobs Hub Business Partners

Kind of information collected:

• Contact person’s name, the organisation which employs the person.
• Telephone numbers, fax number.
• Street and postal address and position title.
• Number of employees, structure, position description etc.
• Areas of interest by category and industry.
• Bank details (if Jobs Hub is to receive payment or make payment for services received).
• Australian Business Number (ABN).
• Type of support or process (e.g. employment vacancy, employment incentives, industry placement, goods in kind, program support, volunteering, payment of invoices).
• For Auspice Partners Jobs Hub will collect information on students, clients, employers and employees.

How the information is collected:

• Communications, emails, flyers.
• Online registration.
• Telephone.
• Invoices.
• Contracts.

Purpose for which Jobs Hub uses the information:

• To provide Jobs Hub services.
• To establish and manage partnerships to receive services from you or the organisation which employs you.
• To manage Jobs Hub relationship with the business partner.
• To provide information about Jobs Hub services.
• To update the company on Jobs Hub programs and services.
• To meet any requirements of government funding for our programs.
• To meet any government reporting requirements.

 Jobs Hub employees, volunteers and prospective employees and volunteers

Kind of information collected:

• Contact details (name, address, telephone numbers, email etc).
• Personal details including personal details of emergency contact person (s).
• Date of birth.
• Country of birth, citizenship, residency and/or visa details.
• Languages spoken and written
• Bank account and superannuation details
• Details of current/ previous employment or volunteer involvement.
• Skills and experience.
• Qualifications and drivers licence details.
• Information and opinions from referees for prospective employees and candidates for volunteer work.
• A Police Check may be required for some of the roles within Jobs Hub (particularly those involving children, young people and other vulnerable individuals). Individuals will be required to provide certain information for a Police Check.
• In some situations it is necessary for Jobs Hub to collect or receive information about a workers health. In this circumstance, Jobs Hub will advise why the information is being collected and whether and to whom it will be released.

Purpose for which Jobs Hub uses this information

• To provide Jobs Hub services.
• To process an application to be become a volunteer or employee of Jobs Hub.
• To facilitate a placement in an appropriate service or position.
• To assist with services
• To provide feedback on performance as a volunteer or employee.
• To meet legislative responsibilities to all volunteers and employees.
• To obtain feedback from individuals about their experiences.
• To assist Jobs Hub to review and improve its programs and services to keep individuals informed about Jobs Hub development and opportunities.
• To provide information about Jobs Hub services.
• To facilitate further involvement with Jobs Hub (e.g. disability support, membership, donor).
• To meet any government reporting requirements.
• To ensure Jobs Hub is able to contact employees/ volunteers as required.

Jobs Hub Members

Kind of information collected:

• Contact details (name, address, telephone numbers, email etc).
• Date of birth.

Purpose for which Jobs Hub uses this information:

• To provide Jobs Hub services.
• To provide communication updates and ensure transparency.
• Relating to donated funds, particularly appeals for public donations and Jobs Hub operations.
• To provide information about Jobs Hub.
• For invitations to upcoming events and activities.
• To recognise support of Jobs Hub.

 Online Users

To the extent that this Policy applies to online privacy issues, it is to be read as forming part of the terms and conditions for use for Jobs Hub website. Jobs Hub will not knowingly share any personal information with any third party other than our service providers who assist Jobs Hub in providing the information and/or services we are providing to you.

Kind of information collected:

• Contact details (name, address, telephone numbers, email etc).
• Non personal information (e.g. visitor navigation and statistics).
• Server address, browser type, date and time of visit.
• Personal information (e.g. news campaigns).

Purpose for which Jobs Hub uses this information:

• To provide updates regarding our website.
• To analyse website usage and make improvements to the website, identify user demands.
• Jobs Hub does not match personal information collected with the non-personal information.
• Provide direct marketing material.
• Information in the form of newsletters.

ADDITIONAL INFORMATION

The website from time to time contains links to other websites. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Jobs Hub stresses that when an online user accesses a website that is not Jobs Hub website, it may have a different privacy policy. To verify how the website collects and uses the information, the user should check that particular website’s policy.

HOW Jobs Hub COLLECTS INFORMATION

Where possible Jobs Hub collects personal and sensitive information directly from you. Jobs Hub collects information through various means, including telephone and in person interviews, emails, appointments, forms and questionnaires. If you feel that the information Jobs Hub is requesting, either on our forms or in our discussions with you, is not information you wish to provide, please feel free to raise this with us.

In some situations Jobs Hub may also obtain personal information from a third party source. If we collect information about you in this way, we will take reasonable steps to contact you and ensure that you are aware of any purposes for which Jobs Hub is collecting your personal information and the organisations to which we may disclose your information, subject to any exceptions under the Act.

HEALTH INFORMATION

As part of administering services Jobs Hub may collect health information. For example Jobs Hub collects health information (such as medical history) from some clients/beneficiaries participating in Jobs Hub programs. When collecting health information, Jobs Hub will obtain your consent to such collection and explain how the information will be used and collected.

If your health information is collected from a third party (such as your doctor) Jobs Hub will inform you that your information has been collected and will explain how this information will be used and disclosed.

Jobs Hub will not use health information beyond the consent provided by you, unless further consent is obtained or in accordance with one of the exceptions under the Privacy Act or in compliance with another law. If Jobs Hub uses your health information for research or statistical purposes, it will be de-identified if practicable to do so.

USE AND DISCLOSURE OF PERSONAL INFORMATION

Jobs Hub only uses personal information for the purposes for which it was given to Jobs Hub or for purposes which are related to Jobs Hub functions or activities.

Jobs Hub may share personal information with associated operational divisions such as Quality or Finance.

For the purposes referred to in this Policy (discussed above under ii – Collection of Personal and Sensitive Information), Jobs Hub may also disclose personal information to other external organisations including:

• Government Departments/agencies who provide funding for Jobs Hub services.
• Contractors who manage some of the services offered to you, such as File Archiving Providers who securely store records. Steps are taken to ensure they comply with the APPs when they handle personal information and are authorised only to use personal information in order to provide the services or to perform the functions required by Jobs Hub.
• Doctors and health care professionals, who assist Jobs Hub to deliver our services.
• Other regulatory bodies
• Referees, employees and volunteers, former employees of Jobs Hub and prospective candidates for Jobs Hub employee and volunteer positions.
• Our professional advisors, including Jobs Hub accountants, auditors and lawyers.
• Auditors as required by Government Contracts/Certifications and Registrations.

Except as set out above, Jobs Hub will not disclose an individual’s personal information to a third party unless one of the following applies:

• The individual has consented.
• The individual would reasonably expect Jobs Hub to use or give that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected).
• It is otherwise required or authorised by law.
• It will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety.
• It is reasonably necessary for Jobs Hub to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to Jobs Hub functions or activities.
• It is reasonably necessary to assist in the location of a missing person.
• It is reasonably necessary to establish, exercise or defend a claim at law.
• It is reasonably necessary for a confidential dispute resolution process.
• It is necessary to provide a health service.
• It is necessary for the management, funding or monitoring of a health service relevant to public health or public safety.
• It is necessary for research or the compilation or analysis of statistics relevant to public health or public safety.
• It is reasonably necessary for the enforcement of a law conducted by an enforcement body.

Jobs Hub does not usually send personal information out of Australia. Some data services have storage centres offshore. Where this occurs Jobs Hub will take all measures to protect your personal information. Jobs Hub will protect your personal information either by ensuring that the country of destination has similar protections in relation to privacy or that Jobs Hub enters into a contractual arrangements with the recipient of personal information that safeguards your privacy.

SECURITY OF PERSONAL AND SENSITIVE INFORMATION

Jobs Hub takes reasonable steps to protect the personal and sensitive information Jobs Hub hold against misuse, interference, loss, un-authorised access, modification and disclosure.

These steps include password protection for accessing our electronic IT system, securing paper files in locked cabinets and physical access restrictions. Only authorised workers are permitted to access these details.

When the personal information is no longer required, it is destroyed in a secure manner.

ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

If an individual requests release of information we hold about them, or requests that Jobs Hub changes personal information, Jobs Hub will allow access or make the changes unless Jobs Hub considers that there is a sound reason under the Privacy Act or other relevant law to withhold the information, or not make the changes.

Requests for access and/or correction should be made to the Quality and Customer Services Manager (details of which are in subsection ix – How to Contact Us). For security reasons you will be required to put your request in writing and provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is not undermined.

Jobs Hub will provide access by allowing you to inspect, take notes or print outs of personal information that we hold about you. If personal information (for example, your name and account details) is duplicated across different databases, Jobs Hub will generally provide one printout of this information, rather than multiple printouts.

Jobs Hub will take all reasonable steps to provide access of the information requested within 14 days of request. In situations where the request is complicated or requires access to a large volume of information, Jobs Hub will take all reasonable steps to provide access to the information requested within 30 days.

Jobs Hub may charge you a reasonable fee to reimburse Jobs Hub for the cost we incur relating to the request for access to information, including in relation to photocopying and delivery cost of information stored off site. Any fees will be advised at the time of the request.

If an individual is able to establish that personal information Jobs Hub holds about him/her is not accurate, complete or up to date, Jobs Hub will take reasonable steps to correct our records.

Access will be denied if:

• The request does not relate to the personal information of the person making the request.
• Providing access would pose a serious threat to the life, health or safety of a person or to public health or public safety.
• Providing access would create an unreasonable impact on the privacy of others.
• The request is frivolous and vexatious.
• The request relates to existing or anticipated legal proceedings.
• Providing access would prejudice negotiations with the individual making the request.
• Access would be unlawful.
• Denial of access is authorised or required by law.
• Access would prejudice law enforcement activities.
• Access would prejudice an action in relation to suspected unlawful activity, or misconduct of a serious nature relating to the functions or activities of Jobs Hub.
• Access discloses a ‘commercially sensitive’ decision making process or information.
• Any other reason that is provided for in the APP’s or in the Privacy Act.

If Jobs Hub denies access to information Jobs Hub will set out our reasons for denying access. Where there is a dispute about your right of access to information or forms of access, this will be dealt with in accordance with the complaints procedure set out below.

COMPLAINTS PROCEDURE

If you have provided us with personal and sensitive information, or we have collected and hold your personal and sensitive information, you have the right to make a complaint and have it investigated and dealt with under the complaints procedure.

If you have a complaint about Jobs Hub privacy practices or Jobs Hub handling of your personal and sensitive information please contact our Quality and Customer Service Manager (details of which are set out below).

All complaints will be logged on our Organisational System Improvement (OSI) System.

A privacy complaint relates to any concern regarding Jobs Hub privacy practices or Jobs Hub handling of your personal and sensitive information. This could include matters such as how information is collected and stored, how information is used or disclosed or how access is provided to personal and sensitive information.

The goal of this complaints procedure is to achieve an effective resolution of your complaint within a reasonable timeframe, usually within 20 days or as soon as practicable. However, in some cases, particularly if the matter is complex, the resolution may take longer.

Once the complaint has been made, Jobs Hub will try and resolve that matter in a number of ways such as:

• Request for Further Information: Jobs Hub may request further information from you. You should be prepared to provide us with as much information as possible, including the details of any relevant dates and documentation. This will enable Jobs Hub to investigate the complaint and determine an appropriate solution. All details provided will be kept private and confidential.
• Discuss Options: Jobs Hub will discuss the options for a resolution with you and if you have any suggestions about how the matter might be resolved you should raise these with our Quality and Customer Services Manager.
• Investigation: Where necessary, the complaint will be investigated. Jobs Hub will try to do so within a reasonable timeframe. It may be necessary to contact others in order to proceed with the investigation. This may be necessary in order to progress your complaint.
• Conduct of our Employees: If your complaint involves the conduct of our employees we will raise the matter with the employee concerned and seek their comment and input in the resolution of the complaint.
• The Complaint is substantiated: If your complaint is found to be substantiated, you will be informed of the finding. Jobs Hub will then take appropriate agreed steps to resolve the complaint, address your concerns and prevent this problem from reoccurring.
• If the complaint is not substantiated, or cannot be resolved to your satisfaction, but this complaints procedure has been followed, Jobs Hub may decide to refer the issue to an appropriate intermediary. For example this may mean an appropriately qualified lawyer or an agreed third party to act as a mediator.
• At the conclusion of the complaint, if you are still not satisfied with the outcome you are free to take your complaint to the Office of the Australian Information Commissioner at oaic.gov.au.

Jobs Hub will keep a record of your complaint and the outcome.

Jobs Hub is unable to deal with anonymous complaints. This is because Jobs Hub are unable to investigate and follow up such complaints. However, in the event that an anonymous complaint is received Jobs Hub will note the issues raised and, where appropriate, try and investigate and resolve them appropriately.

CHANGES TO THIS POLICY

Jobs Hub reserves the right to view, amend and/or update this Policy from time to time.

Jobs Hub aims to comply with the APP’s and other privacy requirements required to be observed under the State or Commonwealth Government contracts.

If further privacy legislation and/or self-regulatory codes are introduced or our Privacy Policy is updated, Jobs Hub will summarise any substantial modifications or enhancements in this section.

HOW TO CONTACT US

Individuals can obtain further information in relation to this Policy, or provide any comments, by contacting us:

Quality and Customer Services Manager

Jobs Hub

2 Tolosa Street, Glenorchy, TAS 7010

If you do not speak English, or English is your second language and you need assistance to communicate with us please email and we will identify a relevant translation service.

Note: These calls can be made for the cost of a local call from fixed residential landlines anywhere in Australia, but calls from mobile and pay phones may incur higher charges. Check with the service provider for costing from mobile or pay phones.

PUBLIC RELATIONS FILES

Purpose:

The purpose of public relations files is record details of public relations activities that may involve web-based interactions, educational material, promotional information, and other activities such as contact with the media, speeches, event management, surveys and publication preparation.

The limited personal information in public relations files relates to organisations, individuals, media representatives, event attendees, service providers and event calendar listings which appear on Jobs Hub website.

Collection:

It is Jobs Hub usual practice to collect personal information in public relations files directly from individuals.

Sometimes Jobs Hub may collect personal information from an individual’s representative or from publicly available sources such as website and telephone directories.

Use and disclosure:

Jobs Hub only uses the personal information in public relations files for the purposes of undertaking communication initiatives and managing public relations.

The personal information on public relations files is not disclosed to other organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to those organisations or individuals, or the disclosure is otherwise required or authorised by law.

Data Quality:

Jobs Hub maintains and updates personal information in our public relations files as necessary, or when advised by individuals that their personal information has changed.

Data Security:

Public relations files are stored in either password protected electronic media or in locked cabinets in paper form. When no longer required, personal information in public relations files is destroyed in a secure manner.

The following employees have access to public relations files on a need to know basis:

• Officers of the Organisation
• Marketing and Communications Staff
• Staff included in Compliance and Performance Measurement

Access and Correction:

For information about how to access or correct personal information in public awareness and education files see ‘Access and Correction’ in Part A of this document.

CONTACTS LISTS

Purpose:

Jobs Hub maintains contact lists which include contact information about individuals who may have an interest in the services provided by Jobs Hub Group Australia. Jobs Hub uses these contacts lists to distribute information about our activities and publications.

Collection:

It is Jobs Hub usual practice to collect personal information in contacts lists directly from individuals, for example, where they have asked to be added to a contacts list.

Sometimes Jobs Hub collects personal information from a third party or from a publicly available source such as a website or telephone directory. Jobs Hub only usually collects personal information in this way if the individual would reasonably expect us to, or has given their consent. For instance, Jobs Hub might collect this information if we thought that the individual (or the organisation they work for) would like to receive information about Jobs Hub  services, or that they might like to consider information about disability care useful to the work that they do. Jobs Hub would only contact this individual in their work capacity.

Use and disclosure:

Jobs Hub only uses personal information in contacts lists for the purpose of managing stakeholder relations.

Jobs Hub does not give personal information about an individual to other organisations or anyone else without consent unless the individual would reasonably expect, or has been told, that information of that kind is usually passed to these organisations or individuals, or the disclosure is otherwise required or authorised by law

Data Quality:

Jobs Hub maintains and updates personal information in our contacts lists when we are advised by individuals that their personal information has changed. Jobs Hub will remove contact information of individuals who advise us that they no longer wish to be contacted.

Data Security:

The personal information in the contacts lists is stored in either password protected electronic media or in locked cabinets in paper form. When no longer required, personal information in contacts lists is destroyed in a secure manner.

Routine access to contacts lists is limited to the database operators and other authorised workers who have responsibility for maintaining the contact lists. Other employees  have access to the personal information in contacts lists on a need to know basis.

Access and Correction:

For information about how to access or correct personal information in Jobs Hub contacts lists see ‘Access and Correction’ in Part A of this document.