Your privacy is important to us

This Privacy Policy applies to the operations of Konekt Limited and its related bodies corporates (as that term is defined in the Corporations Act 2001), in particular Konekt Australia Pty Ltd and Konekt Employment Pty Ltd, Communicorp Group Pty Ltd, SRC Solutions Pty Ltd, Innovative Training Recruitment Pty Ltd (Konekt).

Konekt is committed to protecting the privacy of our clients and other individuals by complying with the Privacy Act (1988) (Cth), in particular the Australian Privacy Principles contained in that Act. This privacy policy sets out how personal information in the Konekt Group will be collected, held, used and disclosed in order to comply with the privacy legislation.

Where you provide us with your personal information in person, by email, fax or through our intranet or websites we will ensure that your information remains private and is used in accordance with the Privacy legislation and this policy.  By providing us with your personal information, you also consent for us to collect, hold, use and share it in accordance with this policy.

In the Privacy Act,

• Personal Information is defined as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether the information is recorded in a material form or not.
• Sensitive information is defined to include information or 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 orientation or practices, criminal record or health information or genetic information about an individual.

What kinds of personal information do we collect and hold?

Konekt has partnered with a Return to Work provider to provide an integrated Injury and Workers Compensation claims management service. The Return to Work provider will liaise closely with Konekt on these items, with specific responsibilities detailed below.

We only collect and hold personal information that is reasonably necessary for our functions and activities.  This includes in particular injury prevention, injury management and occupational rehabilitation services, training, employment and related services.

The kinds of personal information we may collect and hold are:

• your name, date of birth & contact details
• drivers licence and passport information
• your qualifications & work history and other information from your résumé.

We may also collect sensitive information, which is a special category of personal information under the Privacy Act.  We will give your sensitive information a greater level of protection from unnecessary disclosure and we will not share it unless you have consented.  There are some exceptions and they are listed below.  Sensitive information about you would for example be:

• your racial or cultural origin (such as information identifying you as a being an Aboriginal or Torres Strait Islander)
• membership of a professional or trade association or trade union
• any criminal record or
• information relating to your health (your medical history or if you any disabilities).

You may sign up to receive emails that alert you to new jobs on our Konekt Employment website (job alerts).  To subscribe to job alerts, you need to provide your email address, which will be used for the purpose of keeping you informed of the latest jobs matching your criteria.  If you no longer wish to receive job alerts, click on the unsubscribe links which are provided in every job alert that you receive.

You are not required to disclose all your personal information to us but we may not be able to accept or process your application, request or enquiry or provide you with our services if you do not supply this information.  Similarly you can choose to remain anonymous or use a pseudonym when dealing with us, but this might be impractical in providing you with our services.

Why do we collect, hold, use or share your personal information?

Reason for collecting or using personal information

We only use your information for the purpose it was collected, or for related purposes. We collect, use, manage and share your personal information to carry out our functions and activities, in particular injury prevention, injury management and occupational rehabilitation services, training, employment and related service for purposes such as:

• to answer your enquiries or complaints
• to enable proper governance processes such as internal and external audit purposes or
• to seek your feedback about the quality of services that we provide so that our services can be continuously improved
• to conduct reference checks and other pre-employment screening that might be required such as national police record checks, right to work and your qualifications.

For example at Konekt Employment we typically may disclose your personal information:

• to enable you to submit your résumé generally, to apply for specific jobs or to subscribe to job alerts;
• to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to distribute this information within our organisation to apply for jobs;
• to comply with our contract with the Commonwealth Department
• to other service providers if you are transferred to another service provider
• to government departments or agencies involved in the administration of employment services and income support payments and services (such as Centrelink), which maybe by a portal directly into the agency’s database system
• to host organisations, training providers and other organisations, if you are a participant under their activities, courses or programs.

In Konekt Australia we may typically disclose your personal information:

• to your insurer representatives
• your employer representatives
• your medical practitioners, doctors and health providers
• solicitors or other legal parties
• other parties (including family members, unions, community organisations, support services, service providers).

These third parties must similarly comply with undertakings of protecting your privacy in relation to your personal information.  Where we share any of your sensitive information that ought to be kept confidential, we will require that third parties maintain the confidentiality of that information.

Exceptions that apply

We only collect, hold, use or share your personal information (including your sensitive information) for the reasons stated above and where your information relates to the services we provide.  There are certain exceptions and they are where:

• you have consented to or requested the disclosure
• we are required or authorised by law (such as social security law) or a court or tribunal order
• in terms of our agreement with the relevant Commonwealth Department we believe there exists a duty of care towards a third party or
• a permitted general situation exits. A permitted general situation is relevant where we believe it is necessary to:
  • lessen or prevent a serious threat to the life, health or safety of any person (and we cannot reasonably or practicably obtain your consent in that circumstance)
    • Konekt Employment may need to apply for a public interest certificate or act pursuant to a class Public Interest Certificate issued by the relevant Government department from time to time.
  • take action due to an unlawful activity or serious misconduct relating to our services
  • assist in locating a missing person
  • establish or defend a legal proceeding or
  • conduct confidential alternative dispute resolution processes.

Communication and marketing policy

We may also use and store your personal information which we hold for marketing purposes, in order to inform you of the services we offer.  These details will only be used in accordance with the terms of this policy and the Australian Privacy Principles.   If you do not want to receive marketing material from us, you can unsubscribe by responding to our marketing material as indicated, or by e-mailing us at marketing@konekt.com.au.

Our websites may include functionality to enable sharing via third party social media applications, such as Facebook and Twitter. These social media applications may collect and use information regarding your use of our websites. Any personal information that you provide on these social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.

Where we have social media features on our websites (to facilitate the sharing of knowledge), any personal information that you provide on our social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection).  We have limited or no control over those users.

Where we have links to other websites, we cannot ensure that your privacy will be protected in accordance with this Policy.  You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.

The internet is not always a secure method of transmitting information. Accordingly, while we seek to protect your personal information by implementing digital security systems in various parts of our websites, we cannot accept responsibility for the security of information you send to or receive from us over the internet or for any unauthorised access or use of that information.

In general we gather information and statistics about all visitors to our websites including users IP address, browser and computer type, the most frequently accessed pages and most frequently used services. We only use such data in aggregate form (the information does not identify any one individual). This information helps us determine the most beneficial parts of our websites and ways in which we can continually improve our online service.

A cookie is a small data file which is automatically sent from our web servers to your individual web browser when your browser visits our servers’ website.  We use cookies to personalise your online experience, advance our online performance and measure the effectiveness of our marketing appeals.  Most browsers allow you to turn off cookies (see the help menu on your browser); however, switching off cookies will restrict your use of our websites. You can find out more about the use of cookies on http://www.allaboutcookies.org.

Overseas recipients

It is not likely that we will share your personal information to an overseas recipient.

How do we collect your personal information?

We will mostly collect your personal information directly from you unless you have consented for us to collect it from someone else, we are authorised to do so by an Australian law or a court/tribunal order or it is unreasonable or impracticable to obtain it from you.

If we receive any of your personal information, not from you and we are not entitled to that information, we will destroy or de-identify that information as soon as practical (if it is lawful and reasonable to do so).

How do we hold your personal information?

Personal information may be collected in hard copy form or electronic format. We will hold hard copy records securely. Electronic records are held in databases with security safeguards. Some of those databases are government controlled and some are held by a third party provider.

Working with children, criminal records and other checks are securely stored at all times or deleted when required to ensure confidentiality.

How do we secure your personal information otherwise?

We take all reasonable steps to keep your personal information:

• secure;
• free from interference, misuse, loss and unauthorised access, modification and disclosure; and
• accurate, relevant and up to date

whether you interact with us personally, by phone, fax, mail, over the internet or any other electronic medium.

We also have information security policies in place to minimise the risk of unauthorised use and access of Personal Information.

We hold hard copy records, secure and electronic records are held in databases with security safeguards. Some of those databases are government controlled and some are held by a third party provider.

How can you access your personal information?

You are entitled to request access to your Personal Information that we held.  This request should be in writing to your primary point of contact at Konekt.  We will respond within a reasonable time (but at least within 30 days).  If we believe for some reason we cannot give you access, we will give you our reasons for refusing and tell you what further steps you may take.

You may also request that we stop using your information and contacting you and we will comply with your request. However, if this involves a request for deletion of your file, please be aware that we may not be required or able to do so, particularly where your file also holds information we are requested to retain under any government contract or where we are required by law or a court or tribunal order to retain your records.  However, when we consider your information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

How can you correct your personal information?

We will take reasonable steps to correct your personal information to ensure it is accurate, up-to-date, complete, relevant and not misleading.

If you seek a correction of your Personal Information you should make a request in writing to your primary point of contact at Konekt.  We will respond within a reasonable time (but at least within 30 days).  If we believe for some reason we cannot make the correction, we will give you our reasons for refusing and tell you what further steps you may take.

If you request us, we will also notify relevant third parties to whom we have previously disclosed your information (if it is practical and lawful to do so).

How can you complain about breaches of your personal information?

You are entitled to complain about a breach of your personal information.  We view breaches of your privacy very seriously and will comply with the notification of eligible data breaches as set out in the Privacy Act if we are required to do so.

Your complaint or enquiry should be in writing. You can make enquiries or complaints about your privacy to your primary point of contact at Konekt or directly to our Privacy Officer.

You can contact our Privacy Officer at:

Privacy Officer

Konekt

PO Box 20246

World Square Sydney

NSW 2002

Email:   privacy@konekt.com.au

If you complain to our Privacy Officer, this person:

• will acknowledge your complaint in writing
• will conduct a preliminary assessment of your complaint
• may decide not to deal with a complaint if he or she is satisfied that the complaint is frivolous, vexatious, lacking in substance or is not brought in good faith and
• will endeavour to informally resolve all complaints.

Your complaint will be considered resolved when:

• you have expressed satisfaction with the resolution provided
• we have determined that all avenues available to resolve the issue have been exhausted or
• an external agency considers the complaint to be resolved.

If we take more than 30 days to respond to your privacy complaint or you are not satisfied with our response or feel that you can’t discuss the complaint further with us, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or at www.oaic.gov.au.

Review

The Konekt Group Privacy Policy will be reviewed every three years or upon legislation changes.