The Australian Privacy Principles (APPs) apply to LSA. The APPs were established by the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988. LSA is committed to protecting the privacy of individuals it deals with. We only collect information that is reasonably necessary for the activities directly related to our core business. This process sets out our policies on handling personal information.
3. How We Collect Personal Information
LSA will only collect and record personal information by fair, lawful, and unobtrusive means.
Generally, personal information held by LSA is collected directly by individuals, or through their appointed representatives or agents, either:
by Telephone, mail, or email, or
using an LSA website
We may also gain such information held by LSA is collected directly from individuals, or through their appointed representatives or agents, either:
statutory bodies / government agencies
other service providers through information sharing protocols
public sources of information (e.g. the White Pages, social media, Google, Twitter etc.)
Prior to, at the time of collecting personal information, or as soon as practicable afterwards, LSA will provide information in an appropriate manner regarding:
why the personal information is being collected (i.e. purposes/requirements for collection)
consequences for individuals if the personal information is not provided and collected
entities to which the personal information may be disclosed, including to any overseas recipients
how individuals can access and seek corrections to their personal information, where necessary
how to contact us
4. Anonymity and Pseudonymity
Individuals may deal with LSA anonymously or via the use of pseudonyms. Examples where it may be possible to do so include when:
submitting online feedback
joining an LSA Facebook/Blog
However, in many instances, dealing with us anonymously or via a pseudonym may prevent us or limit us in providing/delivering the service.
Questions about providing personal information to LSA may be referred to the LSA Business Support Manager via email@example.com or by calling 1300 268 986.
5. Types of Personal Information We Collect
LSA is an outsourced supplier of labour that delivers recruitment and workforce management solutions across Australia.
The following table provides a summary of the types of personal information that is collected by LSA and the main purposes they are used for.
In addition to the table information relating to below may also be collected and recorded as required:
financial information required to complete and reconcile financial transactions (e.g. credit card numbers, cheque numbers, BSB numbers etc.)
regarding skills, qualifications, and employment history
that relates to current, pending, or anticipated legal proceedings
For What Purpose?
How Is It Collected?
LSA On-Hire Employees
Government related identifiers such as tax file numbers, passport details, copies of drivers' licence, and copies of other competency-based tickets, licenses, and certificates.
Results of employment associated testing, including but not limited to: psychological testing, medical testing, competency, or technical skills testing.
We may also be required or permitted by legislation or contract to collect information for:
Statistical reporting purposes
Incident and Duty of Care reporting purposes
Tailoring and improving our services
Securing professional advice (e.g. from our auditors, lawyers etc.).
Assisting contractors, service providers, and other organisations working with or for LSA to manage and/or deliver services.
6. Accuracy of Personal Information
LSA takes reasonable steps to ensure the personal information we collect, use, and disclose is accurate, complete, and up to date.
If it is believed that any personal information held by LSA is inaccurate or inappropriate, we will:
Amend or remove personal information if it is possible and reasonable for us to do so.
Provide a reason, in writing, if the record cannot be altered or removed.
Place a note on file of an individual’s objection and what they believe is the correct personal information.
All requests for the removal or amendment of personal information must be approved by the LSA Business Support Manager or authorised personnel.
7. Sensitive Information
Sensitive information may need to be collected where it relates to a genuine employment requirement of the job or work that a candidate is being considered for. If sensitive information is required, we will only collect it with the individual’s prior consent.
Sensitive information is a special category of personal information. It is information or opinion about an individual’s:
Racial or ethnic origin.
Membership of a political association or religious beliefs, affiliations, or philosophical beliefs.
Sexual orientation or practices.
Health or disability (at any time).
Expressed wishes about the future provision of health services.
8. The Rights of Job Seekers/Candidates
Candidates enjoy the following rights:
The employment placement service must not charge a job seeker a fee for the purpose of finding the job seeker employment.
An employment placement service must not engage in misleading or deceptive conduct (such as advertising a position as being available when the agency knows no such position exists or knowingly giving misleading information to a job seeker about the nature of a position).
If a job seeker believes that an employment placement service has acted inappropriately, the job seeker may contact the Department of Fair Trading for information on possible action that may be taken.
9. Understanding the Agreement
Personal and sensitive information about individuals being:
Collected by LSA as indicated above.
Used as indicated above.
Disclosed as indicated above
Consideration for an individual’s consent is given when the personal or sensitive information is collected by Labour Solutions Australia.
10. Unsolicited Information
We may accept or reject unsolicited information that is sent to us. If a Job Seeker sends their personal information to us for the primary purpose of seeking employment, then we will treat that information in the same manner that we do of a person that has responded to a job advertisement. If the unsolicited information is unrelated to LSA’s core business, then the information is destroyed.
11. Disclosure of Personal Information
Personal information that is held about individuals is only disclosed for the primary purpose for which it was collected or where we under a legal duty to do so.
Disclosure will usually be:
Internal and to any LSA entity.
Our clients for consideration for vacant positions.
Referees for job suitability purposes.
Ensure continuity of service, to another company if the supply of the service has been transferred to that company.
Applicably Government agencies as requested by law.
We outsource several our business activities to contracted suppliers. Because of this outsourcing our suppliers may see some personal information. Typically, our suppliers include:
Legal and other professional advisors.
Superannuation Fund Managers.
Insurance Brokers and Assessors.
Background Checking and Screening Consultants.
Software solutions providers for the purposes of parsing resume data into our database, and the creation of administration of any online profile.
3rd parties that request access to individual’s personal information (e.g. employment history checks) will only be granted access based on the individual’s written consent.
12. Storage and Security of Personal Information
No data transmission across any network, including the internet, can be guaranteed to be 100% secure. While we strive to protect personal information from misuse, loss and unauthorised access, we cannot guarantee the security of information that is transmitted across a network (including the internet) by 3rd parties (e.g. job seekers). These are conducted at the 3rd parties’ risk.
LSA will however, take reasonable steps to ensure that we hold personal information in a secure environment accessed only by authorised persons for the purposes and processes described within this policy. Our reasonable steps include, but are not limited to:
Records management practices in accordance with our ISO9001 quality certification. Where information is lawfully destroyed at the end of its use by a secure means of disposal.
Training all staff on their responsibilities when handling personal information, including awareness of the Australia Privacy Principals and respecting the confidentiality of client and jobseeker information and the privacy of individuals.
Ensuring a high level of IT security is applied to all systems that hold personal information under LSA control.
14. How We Protect and Share Personal Information
We treat the protection and security of personal information seriously. We strive to ensure that all individuals enjoy:
Respect and dignity in accordance with our corporate values.
Freedom from intrusion and public attention.
A commitment that personal information is protected from unauthorised access and interference.
A commitment that any other LSA partner (e.g. service partners, consultants, contractors, etc) or overseas recipient (e.g. data services) who may have access to personal information will also agree to act in accordance with the applicable Privacy Principles by:
Completing a Privacy/Confidentiality Agreement and demonstrating relevant clearances, and/or
Having appropriate privacy and confidentiality clauses included in their contract, and/or
No personal information will be shared without due consideration of the Privacy Principles, other applicable Acts or Regulations.
LSA will not sell, licence, rent, share, disclose, or swap personal information unless we have consent or where disclosure is authorised or permitted by legislation or a contractual requirement.
For instance, we may be obliged to share personal information about individuals to government agencies and/or other service providers without consent to lessen or prevent a serious threat to life, health or safety.
Unless not appropriate or reasonable in the circumstances, we will attempt to gain consent where it is safe to do so before disclosing personal information. In circumstances where consent has not been obtained, an authorised person will make reasonable efforts to advise them of the disclosure.
15. Information Security
LSA’s information and business management systems are protected and meet numerous information security standards as relevant to each application.
We maintain a comprehensive information technology (IT) security system supported by:
Information security policies/processes which outline LSA’s expectations of information security practice by personnel.
Virus scans and security/operational checks.
Physical records containing personal information are held in secured premises with access only permitted by authorised personnel.
Internal audits are conducted on the management of both soft and hard copy records to test system and data integrity, along with compliance with records management and records protection protocols.
A “cookie” is a small piece of data (file) that a website transfers to an individual’s computer hard drive.
Most internet browsers are pre-set to accept “cookies”. Individuals may modify their settings to prevent receiving “cookies”.
17. IP Addresses
Each time an individual visits an LSA website, we may collect and record the IP address of the internet connection being used. This number is assigned by the individual’s Internet Service Provider.
18. Quality of Personal Information
LSA will take reasonable steps to ensure that personal information collected is accurate, up to date and complete. Our reasonable steps include but not limited to:
Job seekers’ personal information is date stamped when it is collected.
Candidates’ personal information will be updated when they are contacted regarding an available and suited position The LSA recruitment consultant will update the candidate’s record as applicable at this time to ensure all information is current and correct.
Contractors’ personal information is updated upon contract renewal.
19. Responsibilities of Individuals
Individuals (or their appointed representatives) are responsible for:
Providing accurate and current personal information.
Contacting us whenever their contact details change.
Contacting us in a timely manner when their personal circumstances change.
Act in a manner that is respectful to LSA personnel.
Pay any fee requested relevant to employment and placement where applicable.
Access a service for the purpose it is offered.
20. Access, Correction, and Deletion of Personal Information
Under the Australian Privacy Principals individuals have a right to access and correct their personal information that is held by LSA.
Individuals, or their appointed representatives, have the right to access personal information held by LSA unless LSA has a legal or legitimate reason not to release the information (see Our Right to Refuse Access, below).
All requests to access personal information must be provided in writing, preferably using the firstname.lastname@example.org email address. LSA may request additional information to clarify such requests.
LSA requires proof of identity before granting access to any personal information. Individuals who have engaged with us via the use of a pseudonym are also required to establish to our satisfaction that they are the ‘owner’ of the pseudonym to whom the personal information relates.
LSA requires photographic identification wherever possible (e.g. a copy of the individual’s drivers’ licence, passport, Student of 18+ card, etc.). In lieu of photographic identification, we require two (2) other forms of identification (e.g. birth certificate plus a rate notice, or a health care card plus a bank statement in the individual’s name, etc.). Other forms of identification may also be acceptable, as agreed with LSA.
Where an individual has appointed a representative to access personal information, we require signed consent from the individual confirming the representative’s appointment. The representative will need to provide identification prior to any information being released, as detailed above.
An employee of LSA will be present when an individual or their appointed representative/s views any personal information held. Personal information can only be altered or removed in accordance with LSA’s policies and procedures.
LSA reserves the right to charge a fee to access personal information to cover the costs incurred in collating and/or copying information and records.
Individuals can request to access their personal information or for us to amend the information we hold about them by emailing email@example.com or by writing to the LSA Business Support Manager at Labour Solutions Australia, PO Box 1101 Milton, Brisbane, QLD 4064).
To the extent that they are entitled under the Privacy Act and other applicable laws, individuals can access and/or request a correction of their personal information held by LSA except where:
Evaluative opinion information has been obtained confidentially in the course of LSA performing reference checks to which that access would impact on the privacy rights of other people. We reserve the right to refuse access if we believe that it would breach any confidentiality that is attached to that information or the access would interfere with the rights of other people.
If an individual wants to obtain access to their personal information held by LSA they can do so by contacting the LSA Privacy Inquiry Service (firstname.lastname@example.org).
If an individual believes that the personal information that we hold about them is inaccurate, out of date, incomplete, irrelevant and/or misleading they can request that we correct this information by contacting our Privacy Inquiry Service (email@example.com).
If an individual would like their personal information removed from our system/s they can simply send us a deletion request to our Business Support Manager (firstname.lastname@example.org).
When requesting access, correction and/or deletion of personal information individuals must understand that we will seek enough identification from the individual to verify that the information is pertaining.
21. Our Right to Refuse Access
To the extent allowed under applicable privacy legislation, LSA reserves the right to refuse any request to access personal information. We may refuse a request if, for example:
The individual is not genuinely entitled to the information under legislation.
Providing access to the information would pose a serious and imminent threat to the life, health or safety of any individual.
We consider the request to be of a frivolous or vexatious nature.
Giving access would compromise the privacy or safety of another individual.
LSA reserves the right to seek professional advice before deciding upon any request to access personal information. We will provide reasons for any refusal of a request to access or amend personal information.
23. Privacy Inquiries, Feedback and Complaints
Inquiries, feedback and complaints concerning privacy can be submitted by:
Talking to a LSA worker.
Using the Contact Us form.
Emailing email@example.com, or by
Writing to the Business Support Manager at the above address.
LSA responds to complaints by investigating the issue, deciding on any required actions, and responding to the individual within twenty (20) business days of lodgement (or sooner if required). Further information is contained within the Feedback and Complaints Policy (PO-034).
Anyone providing feedback or making a complaint is entitled to remain anonymous or use a pseudonym if they so choose. In both instances, LSA may be limited in what action it can take in investigating and addressing the feedback or complaint.
24. Related Documents
This document should read in conjunction with any applicable specific requirements as found in:
Privacy notices on our websites.
Contractor Confidentiality Agreements.
Request to Information application form(s) and associated guidelines.
Consent to Release/Obtain Personal Information forms.
For further assistance, please email Info@laboursolutions.com.au.
25. Direct Marketing
Personal information is not used by or disclosed to any third party for purposes of direct marketing. From time to time though, we may use personal information for marketing purposes within LSA that are directly related to the following activities:
Clients with whom we have a relationship, with market information and service satisfaction surveys.
Subscribers to our website and social media accounts with news and job alerts to which they have subscribed too.