Privacy Policy

Introduction

Paragon respects your right to privacy. This Privacy Policy explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. 

Paragon (the Business) takes seriously its commitment to preserve the privacy of the personal information that we collect. This summary sets out the key points about how we handle personal information. More information can be found by clicking on the links below. 

 

We collect, hold, use and disclose personal information to carry out our functions or activities as required by the Australian Privacy Principles set out under the Privacy Act 1988 (Privacy Act) as amended. 

 

Paragon Group Privacy Policy complies with the 13 Australian Privacy Principles (APPs) contained in Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988. For the latest versions of these Acts visit the ComLaw website. The APPs are available from the Office of the Australian Information Commissioner (OAIC) website.

We will collect personal information from you directly:

  • If you are a Candidate, when you apply for work; 

  • If you are a Client, during our business relationship with you; or 

  • If you are a Referee, when seeking your opinion.  

We may also collect personal information from a third party or a publicly available source to enable us to confirm the information you have provided to us, and to include other relevant and necessary information in connection with your application to us for work. Personal information is also collected through our websites and social networking services such as Facebook and Twitter. We use this information to improve our website. 

How your personal information is held

Information is held in our secured Information Record System until it is no longer needed.

Disclosure

We may disclose your personal information for any of the purposes for which it is primarily held, or for a related purpose where lawfully permitted. Disclosure will usually be to our Clients and to Referees. Disclosures may also be to our contracted service suppliers and background checking agents. 

We don’t disclose sensitive information about you unless you agree, or would reasonably expect us to. 

Paragon manages personal information as an Australian Privacy Principles (APP) entity under the Australian Privacy Principles (APPs) of the Privacy Act.

We will collect personal information from you directly when you fill out and submit one of our registration forms, application forms, or any other information in connection with your application to us for work. As a contracted service provider to a range of Commonwealth, State and Territory government agencies, it may be necessary for us to collect and manage personal information as an Agency under different privacy arrangements. To find out if this may apply please contact us on the details below.

Paragon collects non-Personal Information on Site Visits by users including, without limitation, which sections of the Site are most frequently visited, how often and for how long. This data is always used as aggregated, non-Personal Information, and may be shared with Paragon partners to provide them with information relating to how Paragon visitors ‘use’ the Site.

 

Third Party Measurement
In order to better understand our users, Paragon utilises Google Analytics to assess Site and Site traffic. A tracking code is used to collect the following information on the usage of the Site:

  • The number of pages views (or page impressions) that occur on the Site;
  • The number of unique visitors to the Site;
  • How long these unique visitors (on average) spend on the Site when they do visit; and
  • Common entry and exit points into the Site.

The aggregated, non-Personal Information is collated and provided to Paragon to assist in the usage of the Sites.

 

  • Information of Candidates, Client and Referees

The type of personal information that we collect and hold is information that is reasonably necessary for the proper performance of our activities or functions as a recruitment agency (see Purposes below) and is likely to differ depending on whether you are a:

  • Candidate – someone who is looking for a placement or work through us; or whom we have identified as a person who might be receptive to an offer of a placement or work through us;
  • Client – someone other than a Candidate who is looking to acquire our services as a recruitment agency or whom we have identified as someone who might be interested in acquiring our services; or
  • Referee – a person from whom we have sought facts or opinions regarding the suitability of one of our Candidates for work or positions through us; and who may be a Referee nominated by the Candidate, a Client or us.

Sensitive information is only collected with consent, and where it is necessary for the performance of our functions and activities as a recruitment agency. Sensitive information will need to be collected where it relates to a genuine occupational requirement, for the purposes of the right to work in Australia verification or an inherent requirement of the job or work being considered. Our collection of some types of sensitive information is also governed by equal opportunity and anti-discrimination laws.

 

You may choose not to provide us your personal information or to act under a pseudonym. However, to do so will render us unable to provide you our services in seeking and being placed into work.

 

For Candidates 

The type of information that we typically collect and hold about Candidates 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. It includes: 

  • Information submitted and obtained from the Candidates and other sources (e.g. Referees or Clients) in connection with applications for work; 
  • Information about personality, character, skills, qualifications, experience and cognitive ability; 
  • Information about career path and preferences; 
  • Information about work entitlement and ability to undertake specific types of work;
  • Information about health status and ability to undertake specific types of work; 
  • Work performance information; 
  • Information about incidents in the workplace; 
  • Personnel information including contact details; 
  • Information in relation to absences from work due to leave, illness or other causes;
  • Bank details and Tax File Number; 
  • Information required to undertake criminal history checks and obtain criminal history records; and
  • Information required to ascertain a Candidate’s right to work in Australia. 

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: 

  • Client relationship information including behavioural models; 
  • Information about position, contracting and hiring authority; 
  • Information about team structures and roles; 
  • Information about incidents in the workplace; 
  • Client facility addresses, ABN, key personnel and contact details; and 
  • Credit check and financial information. 

For Referees 

The type of information that we typically collect and hold about Referees is information that is necessary to help make determinations about the suitability of one of our Candidates for particular jobs or particular types of work and may include: 

  • Information about work position, authority to give a reference and preferred contact details;
  • Opinions of the Referee regarding the Candidates character and work performance or work environment; and 
  • Facts or evidence in support of those opinions, sometimes involving the Referee’s own knowledge and experience of having worked with the Candidate. 

The purposes for which we collect, hold, use and disclose your personal information are those purposes that are reasonably necessary for the proper performance of our functions and activities as a recruitment agency. 

 

  • Candidates – personal information is typically used for recruitment and work placement operations, pre-employment screening, staff management, training, remuneration, workplace health and safety, statistical purposes and statutory compliance requirements. 
  • Clients – personal information is typically used for client and business relationship management, review of workplace operations and health and safety management, credit checking, statistical purposes and statutory compliance requirements. 
  • Referees – personal information is typically used to confirm identity and authority to provide references and for candidate suitability assessment. 

Generally, information will be collected directly from you. 

  • Candidate – information is collected through your application, from referees, results of any competency test or similar, and other sources such as registrations or any professional disciplinary matter. 
  • Client – information is collected when you provide it to us for business purposes.
  • Referee – information is collected from the Candidate in the course of their application for work, and from you when providing the reference.

We may also collect personal information about you from publicly available sources including newspapers, journals, directories, the Internet and social media sites. This information will be included in our records only if reasonably necessary for the performance of our activities or functions as a recruitment agency. 

 

Photos & Images
We may request proof of identification from you including copies of your passport, visa, driver’s license or any other relevant licences and will only do so for the performance of our activities or functions as a recruitment agency.

 

Electronic Transactions
We also collect personal information through our websites and social networking services such as Facebook and Twitter. We use this information to improve our website. Refer to our Electronic Transactions Policy.

 

How your Personal Information is Held
When your personal information is collected it will be 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.

 

Our Information Record System
Information you provide to us is stored in our secure cloud-based recruitment database and document storage system, which are restricted and accessible by staff through the use of individual log-in credentials.

 

Information Security 

We will take all reasonable steps to ensure the information you provide us remains secure and confidential and is only used for the performance of our functions or activities as a recruitment agency.  Refer to our Data Breach Response Framework. 

    • General Disclosures 

    We may disclose your personal information for any of the purposes for which it is primarily held, or for a related purpose where lawfully permitted. We may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a contractual duty to disclose information. 

     

    Disclosure will usually be internally and to our related entities, to our Clients, and to Referees for suitability and screening purposes. 

     

    • 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/or Background checking and screening agents. 

    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. 

     

    • Cross-Border Disclosures 

    Some of your personal information is likely to be disclosed to overseas recipients. The likely countries, type of information disclosed and likely recipients are indicated, so far as is practicable, in the following table: 

     

    Cross Border Disclosures
     Country  Type of Information Likely Recipients  
     NZ  Any information held on our recruitment database.  Our database provider holds data on their servers in NZ.
     UK Any information held on our recruitment database.  Our database provider holds data on their servers in the UK.

    We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data.



Access
Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you. You will need to be in a position to verify your identity. There are some exceptions to providing access, such as when opinions have been provided confidentially in the course of our performing reference checks and access would impact on the privacy rights of other people.

 

We might impose a moderate charge in providing access. Our Operations Lead would discuss this with you. We will generally respond to your request for access within five (5) working days.

 

Correction
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 us. 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.

 

Please advise us if you wish to be removed from our recruitment software system. We will amend your status to “inactive” and will remove information that we have no present need for or obligation to retain.

 

There is no charge to correct information. We will generally respond to your request for access within five (5) working days.

Should we suspect a data breach, we will follow our Data Breach Response Framework. The data breach will be investigated quickly and the appropriate notifications will be sent out. Should the breach be considered an eligible data breach the Australian Information Commissioner will be provided a statement as per the Notifiable Data Breaches under the Privacy Act (1988).

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.  If you are making a complaint about our handling of your personal information, it should first be made to us in writing.  Any complaints we receive will be investigated by our Management Team and a written response will be provided to you as soon as possible. 

 

Please contact our Operations Lead on 1300 856 835 or info@paragonrecruitment.com.au. You may make complaints to the Office of the Australian Information Commissioner.

This policy may change over time in light of changes to privacy laws, technology and business practice. If you use our website regularly or conduct transactions with us that involve us to collect your personal information, it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.

If you have any questions, or would like more information, please contact us via info@paragonrecruitment.com.au or call 1300 856 835. 

If you are a resident of the European Union for the purposes of the GDPR, then in addition to what is set out above, the following applies to you. Paragon Group is a data controller and processor for the purposes of the GDPR and by your consenting to this Privacy Statement Paragon Recruitment Group is able to process your Personal Data in accordance with this Privacy Statement. Our Contact details are set out in the “More Information” paragraph above. 

Thank you for your enquiry!

We will be in touch as soon as possible.