Last updated 28 July 2019
Why your privacy matters to us
We collect a variety of information from visitors to our website, some of which can be confidential. This document explains the types of information we collect, how we collect it and what we do with that information (among other things).
Like most website operators, PQC collects non-personally identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. PQC’s purpose in collecting non-personally identifying information is to better understand how PQC’s visitors use its website. The information collected will also help us trouble-shoot problems, analyse our resources and improve our services. There is nothing in that kind of information that could enable anyone to identify who you are.
PQC also collects potentially personal information like Internet Protocol (IP) addresses for logged in users. PQC only discloses logged in user IP addresses under the same circumstances that it uses and discloses personal information as described below.
In certain circumstances we may be required or permitted by law, court or tribunal order to collect certain personal information about you.
When do we collect personal information?
Visitors to PQC’s website choose to interact with PQC in ways that require PQC to gather personal information. The amount and type of information that PQC gathers depends on the nature of the interaction. We collect personal information in a number of ways, including:
- when you visit and interact with our website and related software (including any mobile applications);
- when visitors sign up for a Company or Candidate account, submit our "Contact Us" form or sign up for our newsletter;
- when you engage in transactions with PQC;
- when you submit your application to join PQC;
- when you contact us independently of the website, such as by email, phone or in person.
In each case, PQC collects such information only insofar as is necessary or appropriate to fulfil the purpose of the visitor's interaction with PQC. PQC does not disclose personal information other than as described below. Visitors can always refuse to supply personal information, with the caveat that it may prevent them from engaging in certain website-related activities and we may not be able to provide our services or assistance to you or on your behalf.
Where relevant you consent to PQC posting and using any photographs, content and/or personal information you might upload on our website or have otherwise provided consent to publish on our website, blog, in our marketing collateral or social media channels, which we may use in order to provide our services, the marketing of our services or for the purpose of our functions and/or activities.
How do we use your personal information?
We collect your personal information in order that you may receive the benefit of our website and services.
- establish, maintain and administer your account;
- send you service or promotional communications, including surveys and information about security updates;
- create or distribute marketing material that is relevant to you;
- conduct verifications of profiles, checking credentials, monitoring and reporting as permitted in the terms and conditions you have agreed with us or under any applicable laws;
- promote and market PQC, our services, our websites (including any social media pages maintained or operated by us such as LinkedIn, Twitter, Facebook etc) and/or the Candidates and Clients registered with PQC;
- any other uses identified at the time of collecting your personal information.
Your personal information will also be used by us to enable more direct connectivity between Candidates and Clients, and between Candidates and members of the public, for the purposes of the services. In particular:
As a Candidate, the visibility of certain personal information included in your professional profile to Clients will depend on the extent to which you have opted in to share your personal information via your account settings.
Personal information about Candidates
You authorise us to collect any personal information (whether written or verbal) from any referee as part of the PQC Scorecard for evaluation of your employment and to hold such information on your personal file for future evaluation of your employment by us.
Accessing your personal information held by PQC You may review, edit, correct or delete any personal information you submit to us at any time. You just need to log into your account to do this.
You may access personal information we otherwise hold about you. Access to your personal information may be denied on certain grounds including, for example: it is unlawful; it may have an unreasonable impact upon the privacy of other individuals; or your request is frivolous or vexatious. If we deny you access, we will provide our reason for doing so at the time of your request.
If you wish to access the personal information, we hold about you or request correction of it, you should contact the Privacy Officer on the details below who will respond to your request within a reasonable period after the request is made.
While we do not charge you for a request for accessing your personal information you should be aware that we may charge a reasonable fee (which will be notified to you once you make a request) for time and cost in the following circumstances:
When we might disclose personal information?
- if an extended amount of time is required to collate and prepare material for you; and
- if you wish to have your files photocopied for you.
PQC may disclose your personal information to other entities or individuals to facilitate the purpose for which information was collected. Such entities and individuals include:
- our Clients or Candidates, as the case may be;
- third party service providers for the purpose of enabling them to provide a service such as (but not limited to) payroll, contractor management and accounting.
- any third-party partners or entities with whom PQC has a commercial relationship;
- any related entity of PQC;
- any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting or when PQC believes in good faith that disclosure is reasonably necessary to protect the property or rights of PQC, third parties or the public at large; or
- other entities if you have given your express consent. Those entities and individuals will be permitted to obtain only the personal information necessary to deliver the service. PQC takes reasonable steps to ensure that these organisations and individuals are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
If you conduct any transaction that requires a payment by you, some of your details may be provided to a third-party payment processor to allow the transaction to be completed.
Certain information will be disclosed to Clients to allow them to determine which Candidates might be suitable. Contact details will only be shared between Clients and Candidates insofar as is necessary or appropriate to facilitate the Services that PQC provides to Candidates and Clients.
Payment Card Industry Data Security Standards (PCI DSS)
PQC uses Stripe Payment for the processing, transmission or storage of card data and no card data is stored on the PQC Site. Stripe has been audited by an independent PCI Qualified Security Assessor (QSA) and is certified as a PCI Level 1 Service Provider. This is the most stringent level of certification available in the payments industry.
If PQC, or substantially all of its assets, were acquired, or in the unlikely event that PQC goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of PQC may continue to use your personal information as set forth in this policy.
Does PQC use personal information for direct marketing?
From time to time we may use the personal information we collect from you to identify particular PQC services that we believe may be of interest to you. We may then contact you to let you know about these services, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what's going on with PQC and our products.
Direct marketing from PQC generally takes the form of an Electronic marketing email.
Electronic marketing - Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or implied consent. You may give us your express consent by, for example, ticking a box on an electronic or signing in paper form where we seek your permission to send you electronic or other marketing information. Consent may be implied from our existing business relationship or where you have a reasonable expectation of receiving an electronic marketing communication.
Every directly addressed marketing contact sent (excluding project and consultant alerts) or made by PQC will include a means by which customers may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to us via the channels provided under 'Contact Us' below.
Links to third party websites
How can you correct and update your information?
We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information by maintaining and updating your profile.
Please contact us using the contact details below as soon as possible if there are any changes to your personal information or if you believe the personal information, we hold about you is not accurate, complete or up-to-date so that we can update your file accordingly.
Dealing with us Anonymously or by Pseudonym
In order for us to successfully do business with you it will not, in most circumstances, be practical for us to deal with you without you providing relevant personal information to us. However, where it is lawful and practicable to do so, you may deal with us anonymously or by using a pseudonym.
Storage and security
PQC takes all measures reasonably necessary to protect against the unauthorised access, use, alteration or destruction of personal information.
Although we aim to create a safe, secure environment by trying to limit access to the website to legitimate users, we cannot guarantee that unauthorised parties will not gain access. We will not have any liability arising from any unauthorised access to your personal information.
Notifiable Data Breaches Scheme
Privacy Amendment (Notifiable Data Breaches) Bill 2017 (Cth)
On 13 February 2017, Federal Parliament passed the Privacy Amendment (Notifiable Data Breaches) Bill 2016 (Cth) to introduce mandatory data breach reporting regime, requiring certain organisations to report "a serious data breach" to the Australian Information Commissioner.
The Bill seeks to introduce a new obligation on relevant organisations to report a "serious data breach" to the Australian Information Commissioner and notify individuals whose data is affected by a breach.
In line with the Australian Governments legislation “Notifiable Data Breach (NDB)” we are required (as of 23rd February 2018) to notify the Office of the Australian Information Commissioner if we suspect or know of any breach of our database or systems enabling illegal and unauthorised access to personal information residing on our databases.
Any such breach must be reported within 30 days of becoming aware of a possible breach.
In addition to your rights set out above, you may:
- update or rectify any of the Personal Data that we hold about you.
- request that PQC:
- provides you with a copy of the Personal Data PQC holds about you in a portable and machine-readable form; or
- share your Personal Data with a nominated third party;
Should you have any concerns in relation to PQC’s collection and/or processing of your Personal Data, then in addition to the process set out above (including the right to complain to the Office of the Australian Information Commissioner), you have the right to complain to a supervisory authority (within the meaning of the GDPR).
All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.
Please contact us at our offices via the contact details provided below if you want to:
- obtain further information about the way we manage your personal information;
- access your personal information held by us;
- raise a concern or make a complaint regarding how we collect or handle your personal information;
- correct or update your personal information held by us; or
- unsubscribe from any PQC mailing list or have any questions or complaints regarding unsolicited electronic communications that you may have received or are concerned about.
Please contact us immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security.
Attention: Privacy Officer
PQC Nominees Pty Ltd
Need more information on privacy?
For more general information regarding privacy in Australia, visit the website of the Office of the Australian Information Commissioner (www.oaic.gov.au