Privacy Policy

1. Introduction

Hallis Group Pty Ltd (Hallis) manages personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and Australian Privacy Principles (“APPs”). This Privacy Policy also constitutes a collection statement for the purposes of the Privacy Act.

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.

You will also be able to find out about the information flows associated with that information.

1.1 APP Entity

Hallis manages personal information, as an APP Entity, under the 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 at:

Address:         Hallis, Level 7, 60 Albert Road, South Melbourne, Vic, 3205, Australia
Email:              melbourne@hallis.com.au
Phone:             (03) 9674 9674

1.2 Information Flow

When we collect your personal information:

  • we check that it is reasonably necessary for our functions or activities as a employment 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 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 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.

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 a recruitment and employment agency and is likely to differ depending on whether you are:

  • a Workseeker;
  • a Client; or
  • 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:

  • contact and identification details (such as contact details and other information you may provide);
  • information about your previous work history, performance appraisals, qualifications, and skills;
  • information recorded when you attend our office for an interview or participate in a telephone or digital interview with us and our assessment of you as a prospective workseeker for recruitment;
  • information about your work rights and your eligibility to work within Australia which may include details, copies or presentation of the originals of any applicable visa, passport, birth or citizenship certificate, or other relevant documentation;
  • sensitive information (e.g. information about your health, medical history or specific condition, criminal record, professional memberships etc.), which will only be collected with your consent;
  • information from third parties including any references about you (whether true or not), incidents in the workplace, absences from work due to leave, illness or other causes, psychometric or competency test results or any information about any insurance investigation, litigation, criminal matter, or inquiry in which you are involved;
  • should you be engaged as an employee or contractor, information including your Tax File Number, superannuation account details, bank account details and other ancillary information that is required to fulfil contractual, legislative, security and reporting obligations (including the payment of salary and wages); and/or
  • any additional information about yourself you provide us with.

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:

  • contact and identification details (such as contact details and other information you may provide);
  • information on the client business, structure, or role you provide us with;
  • your feedback or opinion of prospective and/or successfully placed workseekers, or Hallis employees; and
  • other relevant correspondence.

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:

  • contact and identification details (such as contact details and other information you may provide); and
  • information that you have provided in relation to a Workseeker or their suitability for a position.

3. Purposes

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

  • a Workseeker;
  • a Client; or
  • a Referee.

The following section is also relevant to our use and disclosure of your personal information:

  • Our Policy on Direct Marketing

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;
  • provision of our services to you and answering your enquiries;
  • maintaining our business relationship, where you are a user of our website;
  • to enable you to submit your CV generally, to apply for specific jobs or to subscribe to our services (Job Alerts);
  • matching your details with job vacancies to assist finding a position that may be suitable for you and, where you provide your prior consent as a workseeker, to send your personal information to clients in order to apply for jobs;
  • different parts of Hallis to enable the development and marketing of other products and services and to improve our customer service and to make our services more valuable to you, including tailoring our website when you log on to make it relevant to you personally;
  • trusted third parties where we have retained them to provide services that you have requested, such as psychometric evaluations or skills tests, and who also provide services to us, such as professional advisers, IT consultants, administration providers and function co-ordinators. These third parties must comply with similar undertakings of privacy and confidentiality as Hallis;
  • release of personal information to regulatory or law enforcement authorities, if they require us to do so;
  • identity and work entitlement verification; and
  • seeking your consent to collect, hold, use and disclose your personal information for any other purposes not listed above.

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;
  • payroll services;
  • marketing services to you; and
  • 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:

  • confirmation of identity and authority to provide references;
  • workseeker suitability assessment;
  • recruitment functions; and
  • confirmation of workseeker’s job history

3.4 Our Policy on Direct Marketing

  • Generally, we will only use and disclose your personal information for direct-market products and services, to advise you of news and industry updates, events, promotions and competitions, reports and other information. Where we do so, you will be able to unsubscribe from such communications.
  • These communications will be delivered by Hallis and no information will be provided to a third party for marketing purposes. Hallis do not obtain customer lists from third parties for marketing purposes.
  • Hallis complies with the anti-spam laws of Australia: The Spam Act 2003.

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; or
  • a Referee.

We sometimes collect information from third parties and publicly available sources, such as LinkedIn, 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.

  • 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.

Sometimes the technology that is used to support communications between us will provide personal information to us.

4.1 For Workseekers

Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work.

Personal information is also collected when:

  • you attend our office for an interview or participate in a telephone or digital interview with us;
  • you register or subscribe to our services or request further services on any of our websites;
  • you contact us to report a problem with our websites or make any enquiry or comment;
  • you apply online for a job or work with Hallis. You may need to provide (without limitation) information about your education, employment history and accreditations. Your application will constitute your express consent to our use of this information to access your application and to allow us to carry out any reference checking and other related activities as may be required of us under applicable law as an employer.
  • we have a face to face meeting or telephone conversation with you;
  • results of any competency or medical test or inquiry was received about you;
  • we receive any reference or performance feedback about you; and
  • you provide us with any additional information about you.

4.2 For Clients

Personal information about you may be collected:

  • when you provide it to us for business or business related social purposes; or
  • when you fill out and submit one of our online enquiry forms.

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. At times, video surveillance which operates in or near our premises may capture images of you.

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 résumé by email or through our website; or
  • submit a timesheet via 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.

External sites that are linked to or from the Hallis website are not under our control and it is your responsibility to familiarise yourself with those privacy policies. Clicking on links and banner advertisements and RSS feeds may result in your transfer to another website, where data privacy practices may be different to those of Hallis. Users should note there are inherent risks associated with the transmission of information via the internet and you should therefore make your own assessment of the potential risk to the security of your information.

You can contact us by landline 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

Your personal information may be stored in hard copy documents, or electronically on Hallis’s software, systems, devices or premises. Cloud storage may also contain your personal information.

Any physical records of your information are securely stored on Hallis premises or off-site storage locations within Australia.

5.2 Information Security

Hallis takes reasonable steps to protect the personal information we hold from loss, interference, unauthorised access, modification or disclosure. Our security procedures include:

  • authorised security access to building premises;
  • authorised access, locks and security systems;
  • password protection on software and electronic devices;
  • password protection and limited access to shared network drives to authorised staff;
  • appropriate virus checking; and
  • secure disposal of hard copy documents stored in secure bins and shredded.

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 potential and actual employers and clients of Hallis;
  • to Referees for suitability and screening purposes;
  • to a parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom we may contact in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly to you; or to
  • any person with a lawful entitlement to obtain the information.

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;
  • IT 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; and
  • administration facilitators.

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 may 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.

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.

For more information about access to your information see our Access Policy.

For more information about applying to correct your information see our Correction Policy.

7.1 Access Policy

If you wish to obtain access to your personal information you should contact our Privacy Officer. Additionally, 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 Hallis 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 our Privacy Officer.

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 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 your information being corrected within this time frame, Hallis 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 Officer.
  • 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; and
  • 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.

If you wish to contact us about your personal or sensitive information you may contact our Privacy Officer by email: privacy@hallis.com.au or phone: (03) 9674 9674.