We take your privacy and the protection of personal data very seriously.
This Privacy Policy was last updated on 22/02/2023
Welcome to You+Aus! We hope you will enjoy and appreciate visiting or using the Website at www.youandaus.com.au or any subdomain thereof (the “Website”), or registering your interest in Healthcare & Community or other roles through You+Aus, participating in our recruitment and induction processes, using the functionalities and/or other services as made available to you on the Website, or otherwise being engaged by us in a role or relevant training program (the “Services”).
We want you to know that we take your privacy and protection of personal data very seriously. We are providing this Privacy Policy (the “Policy”) to tell you about who we are, what personal data we collect from you and about you, and what we do with your personal data, all while you visit the Website, use the Services or otherwise interact with us. The Policy also explains your privacy and data rights under the law, and how you can contact us and the necessary authorities to enforce those rights.
We ask that you please read this Policy carefully, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
By using our Website or Services, you agree to be bound by this Policy and that we proceed to the processing of your personal data on the terms outlined below.
References to “you” or “your” are to you as an individual using our Website and/or Services or otherwise contacting us (whether on behalf of yourself, or another individual, or organisation).
Before we get started with the details, here are a few important terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the Australian Privacy Act 1988 (as amended, the “AU Privacy Act”); (2) the “EU GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (3) the “UK GDPR”, United Kingdom’s retained version of the GDPR, which applies to our activities in the United Kingdom; (4) the UK Data Protection Act 2018 (“UK DPA”) which also applies to our activities in the United Kingdom; (5) the Ireland Data Protection Act 2018 (“Ireland DPA”), which applies to our activities in the Republic of Ireland; and (6) the New Zealand Privacy Act 2020 (as amended, the “NZ Privacy Act”). Please note that when this Policy refers only to the “GDPR”, this includes both the UK GDPR and EU GDPR as applicable. You+Aus is committed to adhering to these Data Protection laws, and any other applicable Data Protection Laws.
“Personal data” – under the GDPR, personal data is information about an individual from which that person can be identified. It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Personal data does not include data where the identity has been removed (anonymous data). Under the AU Privacy Act and NZ Privacy Act the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
Other terms and definitions used in this Policy may be found in our Terms of Use, and will have the same meaning in this Policy as they do there.
PeopleIN Group comprises PeopleIN Limited ACN 615 173 076 (ASX: PPE), a public company listed on the Australian Securities Exchange and headquartered in Brisbane, Australia, together with its subsidiaries, associated entities, and brands (together, the “PeopleIN Group”). Our brands include, for example, including Australian Healthcare Academy, Network Nursing Agency, Swingshift Nurses, VNS, First Choice Care, Carestaff, NNA Direct Support Service, Next in Health, Edmen Community Staffing Services and FIP Group.
This privacy policy is issued on behalf of the PeopleIN Group in relation to our You + Aus campaign. Therefore, when we mention “You+Aus”, “we”, “us”, or “our” in this privacy policy, we are referring to the relevant entity in the PeopleIN Group responsible for processing your data.
PeopleIN Limited is responsible for the You + Aus campaign. This entity will be the controller of your data unless we let you know a different entity will be the controller for your data when you participate in recruitment and induction or are otherwise engaged by any of our other PeopleIN Group members. Under the GDPR, our being a “data controller” means that we collect personal data from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means the collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way.
We are registered as a data controller with the Information Commissioner’s Office (“ICO”), the UK’s independent authority set up to uphold data protection rights. Our ICO registration number is ZB513942.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:
You+Aus Privacy Manager
asini@youandaus.com.au
Telephone: +61 3 9898 7000
Here is the mailing address for you as well:
You+Aus Privacy Manager
Level 6, 540 Wickham Street
Fortitude Valley, Queensland, 4006
Australia
In relation to our UK and EU activities specifically, we have appointed representatives who are responsible for overseeing questions in relation to this Policy and our data processing in those regions. Their contact details are as follows:
UK representative:
Dr Loredana Tassone
ukrep@grcilaw.com
We have appointed GRCI Law Limited to act as our UK Representative. If you wish to exercise your rights under the UK General Data Protection Regulation (GDPR), or have any queries in relation to your rights or privacy matters generally please email our Representative at ukrep@grcilaw.com or post your request or query to:
Representative, GRCI Law Limited,
Unit 3, Clive Court, Bartholomew’s Walk,
Cambridgeshire Business Park, Ely,
Cambridgeshire, CB7 4EA, UK
When contacting our Representative please ensure you include our company name in any correspondence.
EU representative:
Sarah Dalton
sarah@youandaus.com.au
Telephone: +353 (85) 826 6569
If you have questions about the Website or Services themselves, please email info@peoplein.com.au.
Under the GDPR, you have the following rights under certain circumstances in relation to your personal data.
You may also have the following rights regarding your personal data held by You+Aus, and other privacy rights, depending on the Data Protection Laws where you are located that apply to you:
These rights may be exercised without affecting the price (if any) you pay for any Services or the amounts we may pay you in connection with your engagement. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Services.
If you wish to exercise any of these rights, please contact us.
In relation to our UK activities, you also have the right to make a complaint at any time to the ICO. Please refer to the ‘Supervisory authorities and complaints’ section below for further information. We would, however, appreciate the chance to deal with concerns before you approach the ICO so please contact us in the first instance.
No fee is usually required to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Under the GDPR, we will most commonly rely on the following legal grounds when processing your personal data.
In the table below, we have set out a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so under the GDPR. We have also identified what our legitimate interests are where appropriate.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out below.
PERSONAL DATA CATEGORY WHAT WE USE IT FOR (THE “PURPOSE” OF PROCESSING) LEGAL BASIS FOR PROCESSING UNDER THE GDPR
• Identity Data
• Contact Data
• Profile Data
• Marketing and Communications DataTo manage our relationship with you and communicate with you generally, for example when we notify you about changes in our privacy policy and ask you to leave a review or take a survey • Performance of a contract with you
• Necessary for our legitimate interests (for example, to keep our records updated and to study how candidates use our Services)
• Necessary to comply with a legal or regulatory obligation
• Your consent in giving us this information
• Identity Data
• Contact Data
• Application Data
To register you as a new candidate, communicate with you when you request support for the Services through the Website, and customise your Services • Performance of a contract with you
• Your consent in giving us this information
• Necessary for our legitimate interests (for example, providing you with a good experience of the Website and Services)
• Identity Data
• Contact Data
• Application DataTo assess your skills, qualifications and suitability for roles/vacancies, carry out background and reference checks, and to communicate with you about the recruitment process. • Performance of a contract with you
• Necessary for our legitimate interests (for example, to decide whether to appoint you)
• Identity Data
• Contact Data
• Application Data
• Profile Data
• Technical Data
• Usage Data
• Marketing and Communications DataTo be responsive as possible to you, for example, when providing support for the Services or answering your candidate queries • Necessary for our legitimate interests (for example, providing you with a good service) and for your legitimate interests (for example, to receive assistance promptly)
• Your consent in giving us this information
• Identity Data
• Contact Data
• Profile Data
• Marketing and Communications DataTo manage your account, enable logging in to the Services, and customise your use of the Services • Performance of a contract with you
• Your consent in giving us this information
• Identity Data
• Contact Data
• Technical DataTo administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, validating against fraudulent transactions, support, reporting and hosting of data) • Necessary for our legitimate interests (for example, running our business administering IT services, and preventing fraud)
• Necessary to comply with our legal obligations
• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Marketing and Communications Data
• Technical DataTo deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you • Necessary for our legitimate interests (for example, to study how candidates use our services, to develop them, grow our business, and inform our marketing strategy)
• Technical Data
• Usage DataTo use data analytics to improve our Website, services, marketing, candidate relationships and experiences • Necessary for our legitimate interests (for example, to define types of candidates for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
• Your consent in giving us this information
• Identity Data
• Contact Data
• Technical Data
• Usage Data
• Profile Data
• Marketing and Communications DataTo make suggestions and recommendations to you about services that may be of interest to you, based on your use of the Website and Services, and/or to supply you with any other material or information you have requested to receive or have otherwise opted-in to receive
• Necessary for our legitimate interests (for example, to develop our services and grow our business)
• Your consent in giving us this information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested or withdraw your consent to us processing your personal data (where applicable), we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time. For example, if you fail to provide information which is necessary for us to process your application for a role/vacancy or your registration of interest more generally, we will not be able to process your application or registration of interest successfully.
We will from time to time, collect Special Category Data from you and will ensure this information is stored securely within the Services. Under the GDPR, we would normally rely on the following special processing grounds when processing your Special Category Data:
For example, we will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual orientation, with a view of ensuring meaningful equal opportunity monitoring and reporting.
We may collect Criminal Offence Data where relevant to recruitment, induction, migration, or legal requirements. For example, we may be legally required to carry out criminal record checks for certain roles, or we may seek from you a basic disclosure of your criminal records history where the role requires a high degree of trust and integrity.
When you use our Website and/or Services or otherwise interact with us, you may choose to voluntarily provide us with Special Category Data even where we have not asked for these; however, we strongly encourage you not to do so. If you do so, then you are giving us your explicit consent to process such data about you to the extent permitted under applicable Data Protection Laws.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under the UK and/or EU data protection regime (as applicable) as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
For the purposes set out in the ‘How we use your personal data’ section above, we may share some of your personal data with certain third parties as set out below.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws. We do not allow our third-party service providers to use your personal data for their own purposes and only permit to process your personal data for specified purposes and in accordance with our instructions.
We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose.
The table below identifies the external third-party service providers we may share your personal data with, and what they do with the personal data.
PERSONAL DATA CATEGORY | WHO WE TRANSFER IT TO | WHAT THEY DO WITH IT |
---|---|---|
• Identity Data • Application Data • Contact Data • Profile Data • Technical Data • Usage Data • Marketing and Communications Data | Companies providing technical infrastructure and software for the Services such as Amazon AWS, Google Cloud and Kinsta, our applicant tracking, processing and recruiting software providers such as JobAdder, iinduct and Referoo, Onboarded, and our CRM provider monday.com | • Store it so that we may retrieve it to contact you • Control your logging in to the Services so they can be provided to you, send you emails relating to the Services you have signed up for, and record-keeping purposes • Assist us in processing your application, including compliance, referencing and onboarding |
• Identity Data • Application Data • Contact Data • Profile Data • Technical Data • Usage Data • Marketing and Communications Data | Companies providing staff management systems such as iNet Allocations, Sirenum and Entire | • Store it so that we may retrieve it to contact you • Control your logging in to the Services so they can be provided to you, send you emails, and record-keeping • Assist us in rostering, payroll, invoicing and management of you as a member of our staff |
• Identity Data • Contact Data • Profile Data • Technical Data • Usage Data • Marketing and Communications Data | Companies that provide online advertising networks, like Google and Facebook | • Show you ads for You+Aus and the Services when you are on the internet, as further detailed in the ‘Third-party marketing and advertisements’ section below |
• Technical Data • Usage Data | Companies that provide data analytics, such as Google Analytics | • Provide us with analytics as to how the Website and Services are used, as further detailed in the ‘Limited gathering of information for statistical, analytical and security purposes’ section below |
We share your personal data within the PeopleIN Group. This may involve transferring your data outside the EEA or the UK.
Some of our external third parties are also based in many countries so their processing of your personal data may also involve a transfer and/or storage of personal data worldwide.
Whenever we transfer your personal data out of the UK and/or EEA (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The following safeguards are applicable to transfer of your personal data to the following limited countries:
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the UK (as applicable). Please contact our Privacy Manager to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.
We may send you marketing communications by email, telephone or mail. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or registered to use our Services and you have not opted out of receiving that marketing. You can always ask us to stop sending you marketing messages at any time by contacting us and/or by using the ‘unsubscribe’ functionality as made available to you in our marketing messages.
You+Aus is continuously evaluating and modifying our use of various advertising networks, which may change from time to time. In this section you will find all the advertising networks that You+Aus currently uses and instructions for opting out of them. If we do additional advertising in the future, this section will be updated.
We will get your opt-in consent before we share your personal data with any third party for marketing purposes.
We use the following advertising networks from time to time:
Please also see our Cookie Policy for further information relating to the use of cookies in advertising.
Entities within the PeopleIN Group may want to send you marketing communications about offerings which may be relevant to you, such as training courses relevant to your fields of interest. You have the option of opting-into receiving such marketing communications, and you can also opt out at any time by contacting us or by using the functionality on such marketing messages to opt out (as applicable).
As described in the above sections, you can always ask us or third parties to stop sending you marketing communications.
Where you opt out of receiving marketing messages, this will not apply to personal data you provided to us as a result of a service purchase, service experience or other transactions.
If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website or Services may become inaccessible or not function properly. For more information about the cookies and other similar technologies we use, please see our Cookie Policy.
As previously set out in this Policy, we automatically collect information using service providers such as Google Analytics (“Third-Party Analytics Programs”) to help us better understand your needs and the needs of Website visitors and Services candidates in the aggregate. We also process such data for statistical purposes to keep track of the number of visits to the Website (including to specific pages of the Website) with a view to introducing improvements to the Website and Services. The information collected through these Third-Party Analytics Programs are Aggregated Data.
The information collected using these Third-Party Analytics Programs may also be used to trace any fraudulent or criminal activity, or any activity in violation of our Terms of Use.
You can customise your cookie settings and accept/reject the use of such Third-Party Analytics Programs at any time. For more information, please see our Cookie Policy.
You may unsubscribe from You+Aus’ mailing list at any time, by following the link at the bottom of all You+Aus emails. Other types of emails, such as transactional, relational, and other emails related to certain Services functions will not have an opt-out option as they are necessary for the use of the Services.
You+Aus’ practices in regards to its email are designed to be compliant with anti-spam laws, including Australia’s Spam Act 2003 and New Zealand’s Unsolicited Electronic Messages Act 2007. If you believe you have received email in violation of these laws or any other anti-spam law, please contact us using the contact information further up in this Policy.
The information collected using these Third-Party Analytics Programs may also be used to trace any fraudulent or criminal activity, or any activity in violation of our Terms of Use.
You can customise your cookie settings and accept/reject the use of such Third-Party Analytics Programs at any time. For more information, please see our Cookie Policy.
The Services may send you push notifications and email notifications, to achieve the purposes outlined in this Policy.
You may opt-out of receiving these notifications by visiting your device settings.
We have implemented very strict technical and organisational procedures for ensuring that, by default, only the personal data which is necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.
You+Aus uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website and Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, You+Aus uses Amazon AWS, Google Cloud and Kinsta, recognised leaders in secure data, for hosting of the Website and Services and related data, and storage of data including personal data.
All information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check You+Aus’ valid SSL security certificates on the Website.
Under the UK and/or EU data protection regime (as applicable), you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Manager, or if you would like to make a complaint directly about You+Aus’ data practices, we invite you to contact the supervisory authority in your country.
For example, if you are in the UK, you should contact the ICO. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF).
If you are in Ireland, you should contact the Data Protection Commission. You can reach them in a variety of ways, including by phone (01 7650100 in Ireland) and mail (21 Fitzwilliam Square South, Dublin 2, D02 RD28).
The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
If you are in Australia, you can make a complaint to the Office of the Australian Information Commissioner here.
If you are in New Zealand, and you feel that we may have breached our obligations to you under the NZ Privacy Act, please contact the Privacy Manager in writing at the details set out above and we will work with you to resolve the issue. If you are not satisfied with the actions taken by the Privacy Manager, you can make a complaint to the Office of the New Zealand Privacy Commissioner here.
Your personal data will only be kept for as long as reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data. Please see the section on ‘Your legal rights’ above for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, if taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.
We do not use solely automated decision-making to make recruitment selection decisions but we may, from time to time, use automated decision-making in deciding what types of promotions to offer you. Our rationale for making automated decisions is so that we can deliver our Services to you efficiently, to enable or otherwise improve our decision-making process, and to reduce the potential harm derived from human error and/or personal bias.
By using our Website and/or our Services, you understand, acknowledge and consent to our making of automated decisions in accordance with this privacy policy and as described above. If you do not consent to our making automated decisions, you must not use our Website or Services.
Where you are subject to automated decision-making processes, you would have the right to:
Please contact us if you want to find out more about our making of automated decisions.
The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Website and Services if we make significant changes. If you have an account, we will also email you to tell you the Policy has been updated, and what the important changes are.
Historic versions of our privacy policy can be obtained by contacting us.
We reserve the right to make amendments to our privacy policy at any time.
Unless otherwise provided in this Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.