Rest recruitment privacy policy and privacy collection notice
Privacy Collection Notice
Retail Employees Superannuation Pty Limited, ABN 39 001 987 739, AFSL 240003, as Trustee of the Retail Employees Superannuation Trust (Rest) Fund ABN 62 653 671 394 (the Fund) (referred to in this Statement as Rest, we, us, our) is committed to ensuring the confidentiality and security of your personal information.
Our privacy policy, which details our handling of personal information collected during our recruitment activities, is available upon request or can be found below this privacy collection notice (rest.com.au/why-rest/about-rest/careers/recruitment-privacy-policy-collection-statement) (Rest Recruitment Privacy Policy).
The entity collecting the information
The entity and contact details of Rest are as follows:
Rest Super
Email address: careers@rest.com.au
Address:
Privacy Officer
Level 5, 321 Kent Street
Sydney 2000
How do we collect your personal information?
A key part of Rest’s recruitment process involves collecting information about you. We generally collect your personal information directly from you, including:
- when you fill out job applications and forms through our Applicant Tracking System (ATS);
- when you send your CV or other correspondence to us (including via email);
- through your access and use of our websites, emails, apps, message services, online portals and social media sites;
- engaging with our digital advertising and communications across the internet;
- during interactions between you and our staff or representatives, including discussions over the phone or in person; and
- when you complete any application or other form, including surveys.
We may also collect information from third parties in certain circumstances, including your employer or previous employers, a third-party recruitment firm, from your personal representative(s), a publicly available record, the Australian Taxation Office, identity verification services, social media platforms, or our service providers or other representatives.
Your information is stored and managed in our ATS. When we collect your personal information by means other than through our ATS, we will upload or merge that information into our ATS. In some cases, your information may also be stored in data warehouses hosted by our ATS service provider or other third-party services providers. These data warehouses may be located overseas (refer to section 10 of the Rest Recruitment Privacy Policy for more information regarding which countries we may store your personal information in).
Why do we collect personal information?
We collect, hold, use and disclose your personal information for the following purposes:
- managing all aspects of the recruitment process, including identifying candidates for roles with us, providing you with information about current and future opportunities with us that may be of interest to you and responding to administrative queries;
- employment purposes (should you be successful for a role with us); and
- corresponding with you, including where you request information from us or have a complaint or concern;
- conducting testing, surveys, research and analytics (including through our third-party service providers);
- complying with relevant laws, regulations and other legal obligations; and
- helping us improve our recruitment process and enhance our overall business.
Consequences of not providing us with the personal information
If we cannot collect your personal information, including your tax file number, we may be unable to complete or fulfil the purpose for which such information was collected (for example, assessing and progressing your application for a role with us, managing your employment or other relationship with us (including provision of benefits, if applicable), or responding to queries or requests that you submit to us).
Disclosing your personal information
We may disclose your personal information to third parties, including people nominated by you in writing, government bodies, regulators and courts, or other service providers and agents (including for the purposes of obtaining reference check and background checks on you, or conducting online testing). We require these parties to protect your information in accordance with privacy laws and treat it confidentially.
Rest is partnering with SmartRecruiters to support our recruitment process. We will share your personal information with SmartRecruiters for this purpose. You can find out more information about SmartRecruiters and how it manages your information here: www.smartrecruiters.com/legal/general-privacy-policy
Do we disclose your personal information outside Australia?
We may disclose personal information to entities located overseas or to entities who use technology located outside of Australia (for example, third parties engaged to host electronic data on our behalf in data warehouses located overseas). The countries in which these entities may be located include the United States of America and Germany.
Your rights
Our Recruitment Privacy Policy contains information about how:
- you may access information held about you;
- you may seek the correction of information held about you;
- you can complain about a breach of the Privacy Act 1988, including the Australian Privacy Principles; and
- we will deal with a privacy complaint
Consent to the collection and disclosure of your personal information
By proceeding with your application, you agree to Rest collecting, using and sharing your personal information as set out above and in accordance with our Recruitment Privacy Policy.
Rest Recruitment Privacy Policy
1. Overview
In this Policy, the words we, us and our refer to Retail Employees Superannuation Pty Limited, ABN 39 001 987 739, AFSL 240003, as Trustee of the Retail Employees Superannuation Trust (Rest) Fund ABN 62 653 671 394 (the Fund).
Your privacy is important to us. We are committed to protecting the privacy of personal information that we collect during our recruitment processes. This document is our Recruitment Privacy Policy and it sets out important information about how we handle personal information and comply with applicable privacy laws.
We are bound by the Privacy Act 1988 (Privacy Act), including the Australian Privacy Principles (APPs) and we recognise the importance of ensuring the confidentiality and security of your personal information.
In this Recruitment Privacy Policy:
- Disclosure of information means providing information to persons outside of Rest.
- Personal information has the meaning given in the Privacy Act (1988) Cth.
- Privacy Officer means the contact person within Rest for questions or complaints regarding Rest’s handling of personal information.
- Sensitive information is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information.
- Social Media Platform means social media platform providers, including (but not limited to) Facebook, Instagram, Google and LinkedIn.
- Use of information means use of information within Rest.
2. What kind of personal information do we collect and hold?
We may ask for various kinds of personal information, to the extent that this information is necessary for us to carry out important activities, including managing all aspects of our recruitment processes, managing your employment relationship with us (should you be successful in applying for a job with us), and providing you services and information, including responding to queries or requests that you submit to us in relation to the recruitment process..
The kinds of personal information that we collect and hold include (but are not limited to):
- your name, gender, date of birth and residency information;
- contact details, such as your address, telephone numbers, email and other digital addresses;
- financial details, such as tax file number and other information relating to your tax status, bank account and direct debit details;
- information to verify your identity, such as your passport, driver’s licence information, birth certificate or Medicare details, and other government identifiers;
- information to verify your residency, visa, or work permit status;
- details about your educational qualifications;
- employment status and details of your employment history, such as ABN/ACN, occupation and job title, salary, hours of work, employment dates and references;
- superannuation and insurance details;
- details of your interactions with us such as conversation recordings, message transcripts and digital service usage (including IP addresses); and
- responses to surveys or other tests such as experiences, and information about your activities, interests and attitudes/views expressed.
In some circumstances, we may also collect and hold “sensitive information”. This includes information about:
- your health (such as medical practitioner reports and consultation notes);
- your membership of professional or trade associations or trade unions;
- your racial or ethnic origin;
- your criminal record; and
- biometric information such as your voice and image.
If the personal information we request is not provided by you, we may not be able to complete or fulfil the purpose for which such information is collected (for example, assessing and progressing your application for a role with us or managing your employment or other relationship with us).
We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for us to deal with individuals who are not identified.
3. What personal information are we required or authorised to collect by law?
If you have been successful and are employed with us, we are authorised to collect your tax file number in various circumstances covered by the Taxation Administration Act 1953 (Cth) and the Income Tax Assessment Act 1936 (Cth). You are not required to provide your tax file number to us.
You can choose whether or not to provide us with your tax file number and it is not an offence to refuse. However, there may be financial consequences if you choose not to provide us with your tax file number, for example tax may be deducted from your income at the highest marginal rate.
4. Unsolicited personal information
We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
5. How do we collect your personal information?
A key part of Rest’s recruitment process involves collecting information about you. We generally collect your personal information directly from you, including:
- when you fill out job applications and forms through our Applicant Tracking System (ATS);
- when you send your CV or other correspondence to us (including via email);
- through your access and use of our websites, emails, apps, message services, online portals and social media sites;
- engaging with our digital advertising and communications across the internet;
- during interactions between you and our staff or representatives, including discussions over the phone or in person; and
- when you complete any other form, including surveys.
We may also collect personal information from third parties including from:
- your employer or previous employers;
- your personal representative(s);
- publicly available records;
- the Australian Taxation Office;
- identity verification services;
- service providers and other representatives engaged to provide services to Rest, such as a third-party recruitment firm;
- digital platforms such as Google and Adobe utilised by us to provide our digital services;
- Social Media Platforms; and
- other representatives who may be authorised by you (such as your referees, spouse, family or friends).
All personal information collected by us from third parties is handled by us in accordance with this Policy.
If we collect your personal information from a third party, they are responsible for letting you know that your personal information has been provided to us.
Where you provide us with the personal information of any other individual (for example, an employer or referee), you must notify that individual that we have collected their personal information.
We will only collect sensitive information with your consent, unless an exemption in the Australian Privacy Principles (APPs) applies. These exemptions include if the collection is required or authorised by law, or is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
We will only use sensitive information where this is reasonably necessary for us to complete or fulfil the purpose for which such information was collected (for example, assessing and progressing your application for a role with us or managing your employment or other relationship with us), unless you specifically authorise us to use your sensitive information for another purpose.
We will always seek your permission before using or disclosing sensitive information for any other purpose.
Please see below for information about how we hold and keep your personal information secure.
Our websites, emails and mobile device applications (apps) contain links to other third-party sites. If accessing these sites, please be aware that the third parties may collect information about you and may provide us with access to that information.
6. What happens if we are unable to collect and use your personal information?
If we cannot collect your personal information one, or more of the following may occur:
- we may be unable to complete or fulfil the purpose for which such information was collected (for example, assessing and progressing your application for a role with us or managing your employment or other relationship with us (including the provision of relevant benefits)); and
- we may be unable to provide you with services or information, or respond to queries or requests that you submit to us.
7. Why do we collect and hold your personal information?
We collect, hold, use and disclose your personal information for the following purposes, which we may carry out with the assistance of our third-party service providers:
- managing all aspects of the recruitment process, including identifying candidates for roles with us, providing you with information about current and future opportunities with us that may be of interest to you, and responding to administrative queries;
- employment purposes (should you be successful for a job with us), including the provision of relevant benefits, if applicable;
- corresponding with you, including where you request information from us or have a complaint or concern;
- conducting testing, surveys, research and analytics (including through our third-party service providers);
- complying with relevant laws, regulations and other legal obligations; and
- helping us improve our recruitment process and enhance our overall business.
We also use information on a de-identified basis for planning, research and analysis so that we can operate effectively and efficiently, participate in policy discussions, and improve our processes and services.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes, which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.
8. Disclosing your personal information
We may disclose your personal information to third parties, including:
- a related entity of Rest;
- people nominated by you, if you have authorised us to do so in writing, including your previous employers and references;
- Government bodies including regulators and the Courts where required;
- our other representatives, agents, contractors and service providers (which may include but not limited to, background and reference check providers, lawyers, accountants, mail and document management companies, IT service providers, marketing and research companies, or other advisers);
- auditors, actuaries, legal advisers and consultants; and
- organisations involved in managing payment, including payment merchants and other financial institutions, such as banks.
In particular, Rest is partnering with SmartRecruiters to support our recruitment process. We will share your personal information with SmartRecruiters for this purpose. You can find out more information about SmartRecruiters and how it manages your personal information here: www.smartrecruiters.com/legal/general-privacy-policy/
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it.
If you want to nominate another person to receive information on your behalf, you can advise us of this using the contact details provided below in the ‘How to contact us’ section.
9. Where we may be required to disclose
We may disclose personal information where the law requires us to do so.
Unless we are authorised or required by law, have your consent or are acting for a purpose set out in this Recruitment Privacy Policy, we do not give your personal information to third parties.
10. Do we disclose your personal information outside Australia?
We may disclose personal information to entities located outside of Australia (e.g. our third-party service providers) or to entities who use technology located outside of Australia, for some of the purposes listed above, including:
- our data hosting and other IT service providers located in, or using technology located in, India, the Philippines, the United States of America, Canada the United Kingdom; and
- other third-party service providers located in, or using technology located in the United States of America and Germany.
In turn, those entities may disclose personal information to other organisations located outside of Australia or to other organisations who use technology located outside of Australia. We are not aware of any personal information that is disclosed to any countries in addition to those already listed above.
Your information is stored and managed in our ATS. When we collect your personal information by means other than through our ATS, we will upload or merge that information into our ATS. In some cases, your information may also be stored in data warehouses hosted by our ATS service provider or other third-party services providers. These data warehouses may be located overseas, including in the United States of America and Germany.
We will not send personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Act and the APPs; or
- the recipient is subject to an information privacy scheme similar to the Privacy Act; or
- the individual has consented to the disclosure.
11. How do we hold and keep your personal information secure?
We hold personal information in electronic and hard copy forms. We take reasonable steps to ensure that your personal information is protected from misuse, interference and loss from unauthorised access, modification and disclosure. We employ a comprehensive suite of logical and physical access controls to all systems where electronic personal information is stored and regularly audit access to our systems to ensure your personal information is securely stored.
We also take reasonable steps to ensure that our third party service providers which help us to carry out our recruitment processes have privacy arrangements which are consistent with the Privacy Act, and regularly assess whether their protections are designed and operating effectively to appropriately mitigate risks to you.
Although we take steps to ensure that your information is protected, there are always risks when transmitting information online. You should assess the potential risks when deciding whether to use our online services. If you do not wish to transmit information via our websites, or digital services, there are other ways in which you can provide us with your information, such as by mail or telephone.
We take reasonable steps to ensure personal information is only retained for as long as it is needed or as required by law. Where personal information is no longer required we take reasonable steps to destroy or de-identify this information.
12. Contractual arrangements with third parties
We ensure that all contractual arrangements with third parties adequately address privacy issues, and we make third parties aware of this Recruitment Privacy Policy.
Third parties will be required to implement the following processes in relation to the handling of any personal information:
- de-identifying personal and sensitive information wherever possible;
- ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
- ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.
13. How do we keep personal information accurate and up-to-date?
We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.
You can access and correct your personal information on your online profile by logging into your account on ATS. Alternatively, please contact us if you believe that any of your personal information is inaccurate, out of date, incomplete, irrelevant or misleading.
If we correct information that has previously been disclosed to another entity, and if you request us to notify that entity of these corrections, we will take reasonable steps to do this, within a reasonable period of the correction.
14. Accessing your personal information
You can access your personal information on your online profile via your ATS online account at any time.
We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
15. Identifiers
We do not adopt identifiers assigned by the Government (such as drivers’ licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.
16. Digital Services
We may collect other information and data about you and about how you use our services and platforms which is not personal information. We collect this information in a variety of ways:
- usage information, including services meta-data, log data, device information and location information;
- cookie information (and other similar technologies);
- third party services data - information provided by another party about how you have used their service; and
- third party data - data collected by another party through their own activity which they have made available to us either directly or through a data service.
We may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our websites. It also enables us to keep track of our services you view and may be used to improve your browsing experience by tailoring the content you see by default on those websites.
We also use cookies to measure traffic patterns and to determine which areas of our websites have been visited. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. In addition, you are able delete or clear existing cookies that you have previously accepted.
17. Making a complaint
If you have a question about our privacy practice or would like to make a complaint about a possible breach of privacy, please contact our Privacy Officer in one of the ways set out in the ‘How to contact us’ section below.
If you are not satisfied with the resolution of your enquiry or complaint, you can refer the matter to the Australian Information Commissioner. The contact details for the Office of the Australian Information Commissioner are as follows:
Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
18. How to contact us
For further information on how we handle personal information, or to complain about a possible breach of privacy, you can contact our Privacy Officer in one of the following ways:
By e-mail at careers@rest.com.au
Write to:
Privacy Officer
Rest Super
Level 5, 321 Kent St
Sydney NSW 2000
You can also contact us via the services mentioned on rest.com.au/why-rest/about-rest/contact-us.
19. Changes to our Recruitment Privacy Policy
We endeavour to continually improve our standard of service, so from time to time we may update this Recruitment Privacy Policy. Any personal information we hold will be governed by the most current version of our Recruitment Privacy Policy.