Privacy Policy

Privacy Policy

RGF Staffing APEJ Pty Ltd (RGF) and its related companies, Chandler Macleod Pty Ltd, AHS Services Group Pty Limited, Aurion Corporation Pty Ltd and Vivir Healthcare Pty Ltd, Chandler Macleod People Insights Pty Ltd, Ready Workforce (a division of RGF Staffing APEJ Pty Ltd) Pty Ltd, Leaders IT Services Pty Ltd, OCG Consulting Limited, Chandler Macleod Group (NZ) Limited Peoplebank Australia Limited, Peoplebank Singapore Pte Ltd, Peoplebank Hong Kong Ltd and Chandler Macleod Group (HK) Limited (referred to as “RGF”, “us”, "we" or “our”) are committed to protecting the privacy of your personal information that we collect, respecting your rights to privacy and complying with the Associated Legislation (listed below).

This Privacy Policy details how we comply with our privacy obligations and how we collect, hold, use and disclose your personal information. By submitting personal information to us, you agree to the terms of this Privacy Policy. Your use of all websites owned or operated by or on behalf of RGF Staffing APEJ, including those associated with our related companies (collectively, the “RGF Staffing APEJ Site”), is subject to this Privacy Policy. You may not use the RGF Staffing APEJ Site, and we may not be able to provide services to you, if you do not agree to this Privacy Policy.

We have a separate but interrelated privacy policy governing our psychological assessment services which may be accessed here: (“Privacy-policy-for-psychological-assessments”).

1. What is your personal information and personal data?

When used in this Privacy Policy, the term “personal information” means information, data or an opinion about an identified natural individual, or a natural individual who is reasonably identifiable, directly or indirectly, whether the information or opinion is true or not and whether or not it is recorded in material form. Personal information covers a broad range of information.

2. What personal information do we collect and hold?

The personal information collected and held by RGF may consist of your name, address, telephone number, photo, email address, age or birthdate, a unique site access ID, company or educational affiliations, profession or occupation, qualifications, titles, proof of entitlement to work in Australia (where relevant), contact information, information from your CV, employment records, biographical information, medical clearance details, criminal / police and government check details and details of our services you have used or enquired about and other information about you.

Some personal information that we collect and hold about you may be sensitive information. When used in this Privacy Policy, the term “sensitive information” includes membership of a profession or trade association, health information (including medical check results), whether you have a criminal record (including associated check results) and the like. We may need to collect, hold, use and disclose sensitive information about you in relation to the specific requirements of your placement with our clients or your direct engagement by us or to provide you with services. If we do, we will get your specific consent to the collection, holding, use and disclosure of this information at the time the information is collected.

3. How do we collect your personal information?

We collect your personal information directly from you and from the third parties listed in this section 3. By consenting to this Privacy Policy, you consent to us collecting information from those listed third parties. If it is otherwise unreasonable or impracticable to collect your personal information directly from you, we may also collect that personal information from other sources.

We may collect your personal information from you in a variety of ways, including via the RGF Site (such as when you register or apply for employment via the RGF Site), when you respond to e-mail questionnaires or when you provide personal information to us by other means, such as in-person during conversations with our representatives, via you providing a business card, over the phone or by email.

We may collect your personal information from the following third parties:

• your employer;
• our service providers;
• our business affiliates;
• our clients;
• credit agencies or government agencies; and
• persons nominated by you as referees.

4. For what purposes do we collect, hold, use and disclose your personal information?

We collect, hold, use and disclose your personal information for the following purposes, all of which are required for us to carry on our business and provide the best possible service to you and our other clients:

to provide our services to you and, in some cases, your employer, including to fulfil your requests for information and to manage recruitment processes for third parties and ourselves;

• to manage recruitment processes for third parties and ourselves;
• to manage our client and business relationships;
• to provide assessment and other consulting services to you and our other clients, including in some cases, your employer;
• if you have been engaged by RGF, to provide to you important work-related information including workplace health and safety information, work rosters and other information relating to your engagement by RGF;
• to undertake psychometric testing;
• to perform statistical analyses of user behaviour in order to measure interest in specific areas and articles posted on the RGF Site;
• to send communications requested by you (including in respect of areas of interest you may indicate to us), answer enquiries and provide information about our existing or new services;
• to operate the RGF Site;
• to maintain and update our records;
• to process and respond to any complaint made by you;
• for the purpose of considering any merger with another business or sale of all or the majority of our assets or equity;
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a governmental authority or regulator, or to cooperate with any governmental authority of any country; and
• any other purpose approved by you.

When required for or in connection with any of the purposes listed above, we may disclose your personal information to our realted companies, your employer, our other clients, contractors and service providers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, any person with whom we may enter into any agreement for the merger or sale of all or part of our business, our professional advisors such as accountants, solicitors, business advisors and consultants and any other person or organisation approved by you.

We will not intentionally disclose (and will take reasonable steps to prevent the accidental disclosure of) your personal information to third parties, whether for such third parties' marketing purposes or otherwise, except when we have your consent to do so or we believe we have a legal right, or a legal duty, to do so.

If we are unable to collect, hold, use and disclose your personal information, or if you wish to deal with us on an anonymous basis or using a pseudonym, we may be unable to fulfil some or all of the purposes listed in this section 4. In particular, we may be unable to provide our services to you or provide you with full access to the RGF

Site.

5. Are cookies and IP addresses used?

The RGF Site uses “cookies” to identify you and your interests and to track usage of the RGF Site in order to help personalise your browsing experience. Cookies are small pieces of text stored on your computer that help us know which browser you are using and where you have been on the RGF Site and on other websites. Cookies also let us know whether you have registered with us and otherwise enable us to relate your current usage of the RGF Site to your prior usage. If you do not wish to receive cookies, you can set your browser to refuse them. However, a user who does not accept a cookie from the RGF Site may not be able to access certain areas of the RGF Site and that user may not be able to use all of the features and services available on the RGF Site.

In administering the RGF Site and diagnosing potential system problems, we also log all IP addresses which access the RGF Site.

6. Direct Marketing Materials

We may send you direct marketing communications and information about our products and services that we consider might be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with all applicable laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method wherever practicable to do so. At any time you may opt out of receiving marketing communications from us by contacting our Privacy Officer (see details below) or by using the opt out facilities provided in the marketing communications.

We do not provide your personal information to other organisations for the purposes of direct marketing without consent by you.

7. Do we disclose your personal information to anyone outside Australia?

We may disclose personal information to our related bodies corporate, clients and third party service providers and suppliers located overseas for any of the purposes listed in section 4. The jurisdictions in which these entities may be located include New Zealand, Singapore, Hong Kong, India, the Philippines, the USA, the United Kingdom, Canada, the Netherlands and Japan.

We have measures in place to ensure information is managed in-line with our Privacy Policy.

8. How can I access, change or delete information?

You may request access to any personal information we hold about you at any time by contacting us. To make a request, please contact your RGF representative or our Privacy Officer (see details below). You may be asked to provide information to allow us to confirm your identity at the time a request is made.

As soon as practicable after your request is received, we will give you access to your personal information that you are entitled to receive. There may be times when we cannot grant you access to your personal information that we hold. For example, if access would interfere with the privacy of others or if it would result in a breach of confidentiality or law, we will not be required to grant you access. We will let you know if you cannot access any of your personal information, and why that access cannot be provided, when we respond to your request for access to that information.

If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

You may also have your personal information deleted from our systems. You should be aware that we are required by law to retain certain personal information (such as payroll records); such information will not be deleted. We will let you know if we cannot delete your personal information for legal or other reasons. Of course, if your personal information has been deleted and you wish to apply for another position through us, you will need to repeat the application process.

We will not charge you for providing access to your personal information held by us or for making any corrections to, or deleting, that personal information.

9. Holding your personal information and security

We take reasonable steps to ensure that your personal information is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We may hold your information in either or both electronic or hard copy form in secure physical and electronic data systems. Only authorised personnel will be provided with access to personal information. These personnel are required to treat this information as confidential and deal with it in accordance with this Privacy Policy. Personal information is destroyed or de-identified when no longer needed by us.

If any personal information we hold has been lost or subjected to unauthorised access, use, interference, modification, disclosure or other misuse (Data Breach), RGF will take all steps in relation to the Data Breach that are required by us in our role as the data owner, and as required by the applicable acts and regulations.

As the RGF Site is linked to the internet and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us over the internet. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any information which you transmit to us over the internet is transmitted at your own risk.

10. Links to third party sites

The RGF Site may contain links to third party websites as a service to our users. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. We encourage you to review and understand the privacy policies of the relevant third parties before providing any information to them.

11. Contact our Privacy Officer

If you have any questions in relation to your personal information, this Privacy Policy or any concerns or a complaint regarding the treatment of your personal information by us, please:

e-mail us at:

• privacy@rgfstaffing.com.au (Australia)
• privacy@rgfstaffing.com.sg (Singapore)
• privacy@rgfstaffing.com.hk (Hong Kong)
• privacy@rgfstaffing.co.nz (New Zealand)

or write to us at:

Privacy Officer
345 George Street
SYDNEY NSW 2000

call us at:

+61 (02) 9269 8666

call us at:

Lodge a privacy request

We will treat your request or complaint confidentially. Our Privacy Officer will contact you

within a reasonable time after receipt of your request or complaint to discuss your concerns and to outline options regarding how they may be resolved.

If you have a complaint regarding the treatment of your personal information by RGF that is not resolved by our Privacy Officer, you may be able to make a complaint to the Office of the Australian Information Commissioner.

12. Changes to our Privacy Policy

We may change this Privacy Policy from time to time and all personal information held by us will be governed by the most recent version of this Privacy Policy. The most up to date version of this Privacy Policy is available on the RGF website.

13. General Privacy Information and Complaints

If you have a complaint regarding the treatment of your personal information by RGF that is not resolved by our Privacy Officer and you wish to make a complaint about this, or, if you would like general information about privacy, data protection and your rights, information may be found at the following sites:

• the Office of the Australian Information Commissioner: https://www.oaic.gov.au

• the Personal Data Protection Commission Singapore: https://www.pdpc.gov.sg

• the Hong Kong Privacy Commission: http://www.pcpd.org.hk

• the New Zealand Privacy Commissioner: https://www.privacy.org.nz/

14. Additional provisions applicable to personal information relating to individuals in the European Union

When we handle personal information relating to individuals in the European Union (EU), we are classified as a “controller” for the purposes of the EU General Data Protection Regulation (GDPR).

You must tell us if you are in the EU when you first provide any of your personal information to us. In addition to the other rights outlined in this Privacy Policy, if you are in the EU, you have the additional rights set out below under the GDPR. If the GDPR applies to you, in the event of any inconsistency between this section 14 and the other provisions of this Privacy Policy, the provisions of this section 14 will prevail.

Right to restriction on data processing

In certain circumstances, you may request a restriction on the processing of your personal information by us. You may make such a request in the following situations:

• where you believe that the information we hold is inaccurate;
• where the processing is unlawful;
• where we are storing the information for legal claims, however do not require it for processing purposes; or
• you have legitimate grounds to object to data processing.

If you make such a request, we will not process any of your personal information without your consent, unless it is for the purposes of storage, legal claims, protecting the rights of another person or it is in the public interest of either the EU or the respective EU Member State.

Right to data portability

In certain circumstances, you may request that we provide you with all personal information that we hold that relates to you. If you make such a request, we will provide you with that information in a structured, commonly used and machine-readable format. Upon request from you, and subject to certain conditions, we will also transmit that information to another controller (as defined for the purposes of the GDPR).

Right to object

In addition to your right to opt out of receiving marketing communications from us as set out in section 6 of this Privacy Policy, you have the right to request that your personal information is not processed by us in various other circumstances. These circumstances include the pursuit of business interests and profiling. Unless we have legitimate grounds to object to your request, we will stop processing data for the purposes requested.

Withdrawal of consent

If at any time you wish to withdraw your consent to us processing your personal information, please send your request to our Privacy Officer. Our Privacy Officer details are set out in section 11 of this Privacy Policy.

Data breach notification

In the unlikely event that we experience a personal data breach that is likely to result in a high risk to individuals in the EU, we will notify those affected individuals without undue delay.

15. Associated Legislation

• The Privacy Act 1988 (Privacy Act) (Australia)

• Personal Data Protection Act (PDPA) (Singapore)

• The Personal Data (Privacy) Ordinance (the "PDPO") (Hong Kong)

• Privacy Act 2020 (Privacy Act) (New Zealand)

• General Data Protection Regulation (GDPR)