Privacy Policy - You+Aus

Privacy Policy

We take your privacy and the protection of personal data very seriously.
This Privacy Policy was last updated on 22/02/2023

Welcome!

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).

Some important terms

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.

About us

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

Contacting us

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.

Your legal rights

Under the GDPR, you have the following rights under certain circumstances in relation to your personal data.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    1. if you want us to establish the data’s accuracy;
    2. where our use of the data is unlawful but you do not want us to erase it;
    3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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:

  • The right to be notified that personal data about you is being collected and to be notified when personal data has been accessed or acquired by an unauthorised person;
  • The right to withdraw at any time your consent for You+Aus to process your personal data;
  • The right to have your personal data erased from You+Aus’ records;
  • The right to access your personal data and any relevant information around its processing and use;
  • The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to another data processor;
  • The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
  • The right to object, on reasonable grounds, relating to your particular situation, to the processing of your personal data;
  • The right to opt out of marketing communications we send you, at any time;
  • The right to know whether You+Aus sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Manager if you need additional information or clarifications;
  • The right to demand that You+Aus not sell your personal data;
  • The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law;
  • The right to refuse any marketing or advertising targeted at you by You+Aus; and
  • The right to institute civil proceedings regarding the alleged interference with the protection of your personal data.

 

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.

The personal data we collect about you 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, work experience, title, job title, company, location, date of birth, gender, languages spoken, citizenships and visas including anticipated applications, copies of other applicable identification documents (such as passports or driving licences) and any photographs which are transmitted via the Services.
  • Contact Data includes postal address, email address and telephone numbers.
  • Application Data includes any other information you provide to us in your CV, covering letter, application form, and any other information gathered pursuant to you applying for or registering your interest in roles/vacancies via our Website and Services.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, access times, webpage from which you came, webpage(s) or content you accessed, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
  • Profile Data includes your username and password, expressions of interest made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Website and Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Special Category Data includes information about your race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union memberships, genetic information, biometric data, and information about your health (including any medical condition and sickness records). Under the AU Privacy Act, such data is known as “sensitive information”. Special Category Data may also form part of the other categories of personal data above, such as Application Data (as applicable).
  • Criminal Offence Data includes any information relating to criminal convictions and offences. Criminal Offence Data may also form part of the other categories of personal data above, such as Application Data (as applicable).

How your personal data is collected

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, and Application Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes but is not limited to personal data you provide when you:
    1. apply for or register your interest in our Services;
    2. create an account using the Services;
    3. submit any information to us via the Website;
    4. give us feedback or contact us; or
    5. request marketing to be sent to you.

 

  • Automated technologies or interactions. As you interact with the Website and Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using certain service providers, cookies, server logs/log files and other similar technologies such as tracking pixels, web beacons and tags. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties We may receive personal data about you from various third parties worldwide, such as the partners we work with from time to time in relation to the running of the Website and our provision of the Services to you.
    1. Technical Data from parties such as:
      1. analytics providers;
      2. search information providers; and
      3. advertising networks.
    2. Contact Data from providers of technical services.
    3. Identity and Contact Data from data brokers or aggregators.
    4. Identity and Contact Data from third party applications, from which users of the Services may import information.
    5. Identity, Contact and Application Data from background check providers, credit reference agencies, your named referees, and any other third parties we may reasonably need to collect personal data from pursuant to you applying for or registering your interest in roles/vacancies via our Website and Services.

 

  • Publicly available sources. We may receive personal data about you from public sources including but not limited to publicly available social media accounts, Companies House and the Electoral Register based in the UK (and similar sources In other applicable jurisdictions) and law enforcement or government entities in any applicable jurisdiction.

How we use your personal data

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.

  • Where we need to perform the contract we are about to enter into or have entered into with you. This includes processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Where we need to comply with a legal obligation that we are subject to. Under the AU Privacy Act and NZ Privacy Act, the legal basis for our processing is your informed consent, and by submitting this personal data you acknowledge having granted this consent to You+Aus. To the extent that we processed your personal data before the commencement date of the aforementioned data protection legislation (as applicable to your jurisdiction), you consent to us continuing to process such personal data in accordance with this Policy.
  • Where you have given your consent.

 

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 CATEGORYWHAT WE USE IT FOR (THE “PURPOSE” OF PROCESSING)LEGAL BASIS FOR PROCESSING UNDER THE GDPR
• Identity Data
• Contact Data
• Profile Data
• Marketing and Communications Data
To 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 Data
To 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 Data
To 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 Data
To 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 Data
To 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 Data
To 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 Data
To 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 Data
To 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:

  • Where you have given your explicit consent.
  • Where the processing is necessary to carry out our legal obligations or to exercise rights in connection with employment.
  • Where the processing is necessary in the public interest, such as for equal opportunities monitoring or for protecting you or another person from harm.

 

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.

Change of purpose

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.

Aggregated Data

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.

Who we transfer your personal data to

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.

  • External third parties including:
    1. professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK, EU/EEA, Australia or New Zealand (or any other jurisdiction as applicable) who provide consultancy, banking, legal, insurance, and accounting services;
    2. law enforcement, regulators or other public authorities based in the UK, EU/EEA, Australia or New Zealand (or any other jurisdiction as applicable) if, for example:
      1. we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements;
      2. we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of You+Aus’ terms of use;

 

  • we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website or Services infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks);
    1. our service providers acting as sub-processors which we use for time to time, as set out in the table below; and
    2. third-party employers you decide to work for, for example a hospital or a facility (which are outside the PeopleIN Group). We will share your personal data reasonably required by these third-party employers to consider your application or registration of interest for the applicable job/vacancy, pursuant to your use of the Website and/or Services. If you are subsequently engaged or employed by the applicable third-party employer, then that employer would be the controller of your personal data throughout the course of your employment or engagement with that employer. You should review the privacy policy of that applicable employer for more information about how your personal data will be handled.

 

  • Internal third parties within the PeopleIN Group (including parent company, subsidiaries, joint ventures, or other companies under common control) acting as joint controllers or processors and provide services including IT and system administrative services and undertake certain reporting functions. Your personal data may also be shared with any entities within the PeopleIN Group who may be your prospective employer pursuant to your applications and/or registration for roles and vacancies via our Website and Services.

 

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change of ownership or restructuring happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. It may also be the case that a new privacy policy may apply to you, in which case we will inform you accordingly.

 

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 CATEGORYWHO WE TRANSFER IT TOWHAT 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

Transfer of personal data outside of the European Economic Area (EEA) and the UK

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:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable).
  • Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).

 

The following safeguards are applicable to transfer of your personal data to the following limited countries:

  • New Zealand. We may transfer personal data to our operations in New Zealand, but New Zealand has been determined to have an “adequate level of protection” for your personal data under European data protection law.
  • Australia. We may transfer personal data to our operations in Australia, but when we do so we rely on binding corporate rules to protect your personal data.

 

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.

Marketing and promotional material from us

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.

Third-party marketing and advertisements

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:

  • Google AdWords and Display Network. You+Aus uses the remarketing features of interest-based advertising of Google AdWords that delivers you advertisements that will be of particular interest to you, based on your browsing and activity history interacting with the Website and Services. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these ads around the web, and you may prevent this type of advertising by deleting the appropriate Google cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google advertising by adjusting your Google ad settings or using the WebChoices online opt-out tool.
  • Facebook Custom Audience. You+Aus uses Facebook Custom Audience to display advertisements to you on Facebook or in Facebook Messenger that will be of interest to you, and by visiting or using the Website you consent to this use. Facebook may collect or receive information from the Website and Services and other applications and websites and use that information to provide measurement services and targeted ads. If you do not want to receive such Facebook advertisements, you can opt-out of such advertising by adjusting your Ad Preferences settings while logged in to Facebook.
  • Instagram for Business. You+Aus uses Instagram for Business to display advertisements to you on Instagram that will be of interest to you, and by visiting or using the Website you consent to this use. Instagram may collect or receive information from the Website and Services and other applications and websites and use that information to provide measurement services and targeted ads. If you do not want to receive such Instagram advertisements, you can opt-out of such advertising by adjusting your Ad Preferences settings while logged in to Instagram.

 

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).

Opting out

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.

Tracking technology (“cookies” and other similar technologies)

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.

Limited gathering of personal data for statistical, analytical and security purposes 

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.

Email communications and compliance with anti-spam laws

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.

Push notifications and email notifications

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.

How we protect your personal data

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.

Supervisory authorities and complaints

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.

Data retention

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 decision-making

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:

  • Obtain an explanation about any decision taken as a result of automated decision-making and express your point of view regarding such a decision;
  • Challenge such a decision by asking us to reconsider a decision or take a new decision on a different basis; or
  • Request and obtain human intervention on such processing.

 

Please contact us if you want to find out more about our making of automated decisions.

Changes to this Policy and your duty to inform us of changes

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.

Third party links

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.