Privacy Statement

Jonathan Wren Australia Pty Ltd is committed to ensuring the privacy of your information. We understand how important the privacy of your personal information is to you.

As such, Jonathan Wren is committed to complying with the Privacy Amendment (Private Sector) Act 2000 and the privacy provisions of all applicable legislation.

This Privacy Policy covers all personal information held by Jonathan Wren, that is, information, or an opinion, about an individual, whose identity is apparent, or can be reasonably ascertained, from that information or opinion. The policy also covers personal information that we have sourced from third parties.

The privacy provisions affecting private sector organisations came into effect of 21 December 2001. The National Privacy Principle (NPP) Legislation applies to Jonathan Wren. The main aim of NPPs is as far as possible to establish a nationally consistent approach to handling of personal information. They aim to ensure that organisations that hold information about individuals handle and manage that information responsibly. They also give individuals some control over the way in which information about them is handled.

Application

This Policy covers Jonathan Wren Australia Pty Ltd.

Objective

The objective of this policy is to outline Jonathan Wren’s commitment to ensuring the adherence of the National Privacy Principles established by the Privacy Amendment (Private Sector) Act 2000.

National Privacy Principle

The ten National Privacy Principles (NPPs) that Jonathan Wren adhere to are briefly summarised below.

NPP 1 – Collection

Collection of personal information must be fair, lawful and not intrusive. A person must be told the organisation’s name, the purpose of collection, that the person can get access to their personal information and what happens if the person does not give the information.

NPP 2 – Use and Disclosure

An organisation should only use or disclose information for the purpose it was collected unless the person has consented, or the secondary purpose is related to the primary purpose and a person would reasonably expect such use or disclosure, or the use is for direct marketing in specific circumstances, or in circumstances related to public interest such as law enforcement and public or individual health and safety.

NPP 3 – Data Quality

An organisation must take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up to date.

NPP 4 – Data Security

An organisation must take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access modification or disclosure.

NPP 5 – Openness

An organisation must have a policy document outlining its information handling practices and make this available to anyone who asks

NPP 6 – Access and Correction

Generally speaking, an organisation must give an individual access to personal information it holds about that individual on request.

NPP 7 – Identifiers

Generally speaking, an organisation must not adopt, use or disclose an identifier that has been assigned by a Commonwealth government ‘agency,’ such as a Tax File Number, Medicare Number or Drivers Licence Number.

NPP 8 – Anonymity

Organisations must give people the option to interact anonymously whenever it is lawful and practicable to do so.

NPP 9 – Transborder Data Flow

An organisation can only transfer personal information to a recipient in a foreign country in circumstances where the information will have appropriate protection.

NPP 10 – Sensitive Information

An organisation must not collect sensitive information unless the individual has consented; it is required by law – or in other special circumstances, for example, relating to health services provision and individual or public health safety.

When do the NPP’s apply?

• New information collected from the 21st December 2001, is subject to compliance with all ten (10) NPP’s as listed above.
• Existing information only needs to apply to NPP 4 (Data Security), NPP 5 (Openness), NPP 7 (Identifiers), NPP 9 (Transborder Flows).
  

Arrangements for privacy compliance

The organisational arrangements for privacy compliance in our company on a national basis is that of (insert name), telephone (03) 9963 600, email: (insert emai), who is the Privacy Compliance Manager reporting to the Chief Executive Officer.

Collection of Information by Jonathan Wren

Jonathan Wren obtains most of the personal information about candidates and contractors from them directly. Normally, when they apply for employment, training and/or career management opportunities, they will provide us a resume of their skills and experience. In some cases, we may also request the candidate or contractor to perform a skills and/or behavioural analysis to determine their skill set and suitability of positions or training. We may also seek personal information from the referees provided by the candidate and/or contractor.
Jonathan Wren endeavours to advise individuals of the purposes for which their personal information is collected, and of those third parties to whom the information is usually disclosed.
If we collect personal information, in particular sensitive information (as defined under the Act), we will treat it with the utmost security and confidentiality. We will ensure that it is not collected for any purposes, other than those for which we have obtained the individual's consent, unless the law requires otherwise, or other exceptional circumstances prevail as described under the Act.
Where an individual chooses not to provide requested information, we will advise that individual of what impact this non-disclosure may have. For example, withholding certain information may affect the individual's success in gaining employment.

Type of Information held by Jonathan Wren

• Personal information collected and held by Jonathan Wren usually falls into the following categories:
• The personal information of candidates and contractors collected in the course of the recruitment, training and management process including information collected and recorded from the practice of reference checking and contractor care programs.
• All personal information that is normally required to be transferred between an employee and employer in the context of an employment relationship, including but not limited to tax file number, banking details and information that might be relevant to a workers compensation claim.
• Information obtained to assist in managing client and business relationships.
• Candidate information submitted and obtained from a Candidate and other sources in connection with applications for training and/or reskilling programs.
• Jonathan Wren only seeks to collect sensitive information when it is necessary for a client assignment. In such cases, we would only do so with the consent of a candidate or contractor, or if required by law if necessary in connection with a legal or equitable claim.
  

Purposes for which we hold Personal Information

• Placement Operations
• Recruitment Services
• Training
• Client and business relationship management
• Marketing
• Payroll
• Superannuation
• Deduction of Membership Fees/subscriptions for Professional and/or Trade Unions
  

Obtaining your consent and disclosure

We may disclose personal information provided to us for which it is primarily held or for a related secondary purpose. We will seek consent in writing, over the phone or on our website. At other times, where candidates and contractors have indicated to us that they wish to be considered for positions generally or within certain parameters, consent will be taken as given.
To facilitate our efficient use of your information, and to provide you with the best recruitment and contracting services and/or career management opportunities, it may sometimes be necessary for Jonathan Wren to disclose your information to third parties. However, this disclosure will only occur in the following circumstances:

To our Employees, Contractors and Agents

From time to time we may engage or employ other companies and individuals to perform functions on our behalf. Examples may include, bulk recruitment exercises or administrative functions associated with our business activities. Such parties will have access to only that personal information required by them to perform the activity, and will only do so by adhering to our Privacy Policy, and may not use such information for any other purposes.

Where required by Law

In certain circumstances we may be required by law to disclose your personal information, for example, where disclosure is ordered by a Court, or subpoenaed in relation to third party litigation. We also reserve the right to choose to disclose your information to law enforcement agencies in circumstances described in the National Privacy Principles and other applicable laws and regulations, including for the purpose of investigating alleged contraventions of the law.

With your Consent

Other than as outlined above, we will endeavour to provide you with notice (which may occur via your nominated e-mail) when we wish to provide personal information about you to third parties, and provide you with the opportunity to chose not to share that information.

Unauthorised disclosure or access

Jonathan Wren is committed to protecting the privacy of individuals, therefore we will view unauthorised disclosure of, or access to, personal information by our employees, contractors or agents, as a serious breach of this policy. Appropriate action (which may include disciplinary or legal action) will be taken in such cases.

Un-subscribe

We will always provide individuals with a nil-cost way of contacting us to register a request to "un-subscribe" from receiving further marketing and/or career management promotional offers.
We will provide an un-subscribe opportunity with direct marketing offers in accordance with the legislation.

Security

Jonathan Wren aims to protect the personal information that it collects. Personal information will be managed confidentially and securely and destroyed appropriately when no longer required.
We will monitor and implement appropriate technical advances or management processes, to safeguard personal information.

Data Quality

Jonathan Wren will take all reasonable steps to ensure that the data we collect, use or disclose is accurate, complete and up to date, and has been obtained directly from individuals or other reputable sources.

Emails

• Jonathan Wren may save any email that you send under the following circumstances:
• If Jonathan Wren believes that it has a legal requirement to do so,
• Where an individual has sent resumes (or associated personal information) to Jonathan Wren for the primary purpose of seeking Jonathan Wren’s assistance in gaining employment and/or training (recruitment and career services)
• Where an individual has sent resumes (or associated personal information) to Jonathan Wren for the primary purpose of seeking the Groups assistance in sourcing contract or project work (Independent Contracting).
• Where the content of the email is suspected to threaten security or is in breach of Jonathan Wren’s policies and/or standards.
  

How to obtain access and make corrections to personal information

A candidate or contractor who requests information can gain access to the personal information we hold about them by making application for access to our Privacy Compliance Manager, (insert name), e-mail: (insert email), or in writing.
Addressed to the Privacy Complaints Manager, Jonathan Wren, Level 12 / 350 Collins Street, Melbourne, 3000.
If the granting of access results in the identification of information that is not accurate, complete or up-to-date, generally, we will make corrections to the information.
We will respond to the request as quickly as possible, but not more than 14 days after the request has been made.
The Privacy Amendment [Private Sector] Act 2000 provides that a company may require the applicant to meet the reasonable costs of providing this access. Our company’s charge for this service is $40.00. This fee covers our costs to locate, access and copy your information.
It is important to note that our application for access to personal information is a lengthy process, as we are mindful that the information being accessed, is by the person the information belongs too.

Requesting deletion of current personal data for candidates

If you wish to have your current personal details deleted from Jonathan Wren’s internal systems and database, then please send an email to de-register@jwren.com.au with "delete my personal details" in the subject line, with your full name and State of residence. This will be performed with 14 days of receiving your request and there is no charge.

Complaints Resolution

Step 1

The handling of personal information is of extreme importance to Jonathan Wren. We have trained our Consultants and built our systems with quality controls to ensure we handle personal information with confidentiality and care.
If a candidate or a contractor has a complaint about how our company is handling their personal information they should direct that complaint to our Privacy Compliance Manager. We will respond to the complaint as quickly as possible but not more than 28 days after the complaint has been made.

Step 2

If they are not satisfied with the response or outcome of that enquiry, they should raise the complaint and our response to it with the Office of the Federal Privacy Commissioner. The Office is located at Level 8, Piccadilly Tower, 133 Castlereagh Street, Sydney, NSW, 2000 (Telephone Number 1300 363 992).
The Federal Privacy Commissioner, who is also the Code Adjudicator, is responsible for accepting, investigating and making a decision on a complaint under the Recruitment Industry Privacy Code.

This Privacy Statement may be updated from time to time.
We encourage you to check this Privacy Statement regularly.