Privacy Policy for Managed Labour Hire Pty Ltd (MLH)

Introduction

Managed Labour Hire Pty Ltd (MLH) is committed to protecting the privacy of all individuals whose personal information we collect and hold. This Privacy Policy outlines how we manage personal information in accordance with the Privacy Act 1988 in Australia and the Privacy Act 2020 in New Zealand (the Acts). It applies to all employees, candidates, and any other individuals from whom we collect or hold personal information.

This policy sets out how we will collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Acts. If you wish to seek further information on the Acts, see www.privacy.org.nz and https://www.oaic.gov.au/privacy/

 

  1. Collection of Personal Information

We may collect personal information about you when:

  • You complete one of our registration forms or provide any information in connection with your application or otherwise.
  • We receive any reference about you.
  • We receive results of inquiries that we might make of your former employers, work colleagues, professional associations, or registration bodies.
  • We receive the results of any competency or medical test or background checks, including but not limited to work rights, credit, and criminal record checks.
  • We receive any complaint or other information from or about you in the workplace.
  • We receive any information about any insurance investigation, litigation, registration, or professional disciplinary matter, criminal matter, inquest, or inquiry in which you were involved.
  • We collect information about you from public domain sources.
  1. Use of Personal Information

Your personal and sensitive information may be used in connection with:

  • Your actual or possible work placement.
  • Career guidance or management.
  • Our assessment of your performance and prospects or any training needs.
  • Any test or assessment (including medical tests and assessments) that you might be required to undergo.
  • Informing you of possible work opportunities or other events such as training or information sessions, or our direct marketing to you by mail/email/SMS by MLH and its related companies.
  • Any workplace rehabilitation.
  • Our management and resolution of any complaint, inquiry, or investigation in which you are involved.
  • Any insurance claim or proposal that requires disclosure of your personal or sensitive information.
  • Undertaking checks to verify your work rights status, criminal history, and any other background checks, including credit checks for positions in New Zealand involving significant financial risk and otherwise as permitted by law.
  • For research, development, business systems and infrastructure testing, and other business purposes to assist us in providing our services to you.
  1. Disclosure of Personal Information

We may disclose your personal information (including to trusted third parties) for the purposes for which it is primarily held or for a related secondary purpose, and in some cases, we may only disclose information with your consent. Your personal and sensitive information may be disclosed to:

  • Potential and actual employers and clients of MLH and trusted third parties who may be based outside of Australia and New Zealand.
  • MLH and its group companies’ employees and potential employers located in countries including, but not limited to, Australia, New Zealand, and other countries where MLH may provide its services in the future regarding possible or actual work placements and to assist us in providing our services to you.
  • Referees.
  • External providers used in providing our services to you, such as online inductions and training providers, background checking agencies (e.g., criminal record, work rights, and credit checking).
  • Third-party outsourced IT, including cloud-based storage providers and document storage providers where we have an appropriate processing agreement (or similar protections) in place, providing us with specialised and efficient database management, development, and storage.
  • Marketing technology platforms and suppliers who assist us with the provision of marketing communications to you and customer feedback survey providers.
  • Third parties used by our clients as part of their recruitment administration, screening, and selection processes.
  • Internal and external auditors of MLH or our clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations.
  • Third parties who assist us by developing services and processes to optimise and improve the quality and efficiency of recruitment services.
  • Third-party contractors/service providers, job boards, job platforms, job aggregators, software providers, and cloud-based databases for the purposes of assisting us to provide you with our services and/or to improve the services we offer you.
  • Our insurers.
  • A professional association or registration body that has a proper interest in the disclosure of your personal and sensitive information.
  • A Workers Compensation body.
  • Any person with a lawful entitlement to obtain the information.
  • If MLH merges with or is acquired by another business or company in the future (or is in meaningful discussions about such a possibility), we may share your personal data with the (prospective) new owners of the business or company.

For any disclosures outside of Australia or New Zealand, as the case may be, we take reasonable steps to ensure that the recipients of such information do not breach the Australian Privacy Principles (APPs) or Information Privacy Principles (IPPs) in relation to that information. We will take reasonable steps to ensure, for instance, pursuant to a contractual agreement, that your personal information receives an adequate level of protection; for example, your information will be stored on secure servers that are protected in controlled facilities. We have put in place appropriate procedures with the third parties we share your personal information with to ensure that (a) your personal information is treated by those third parties in a way that is consistent with and respects the privacy laws of Australia or New Zealand as appropriate, and (b) will only use your information for the purpose of providing services to MLH and will not use your information for any other purpose.

  1. Use of Artificial Intelligence

We also sometimes use automated systems such as filtering tools or occasionally more complex tools which use an element of artificial intelligence, such as algorithms or machine learning (including those provided by third parties), to help us quickly, efficiently, and more accurately to analyse data we have about you and other candidates as well as data we hold on our clients’ needs. This ultimately helps us to make decisions based on this data. This can include applying tools which use algorithms (such as filtering tools or machine learning) to candidate personal data in order to help us come up with the best possible shortlist for a particular role. Such technology should reduce significantly the amount of time needed to consider when candidates might be the best fit for relevant jobs. This should, in turn, make the recruitment process much more efficient and effective, which we hope will improve your overall experience with us.

  1. Management of Personal Information

At MLH, we train our staff to respect the confidentiality of customer information and the privacy of individuals. MLH regards breaches of your privacy very seriously, and any breach will result in disciplinary action being taken, dependent upon severity. MLH has appointed a Privacy Officer to ensure that our management of personal information is in accordance with this policy and the relevant Privacy Acts.

  1. How Do We Store and Protect Personal Information?

Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet, or other electronic medium. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records and take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse, interference, and loss, unauthorised access, modification, or disclosure. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you, or we will securely destroy the records.

  1. How Do We Keep Personal Information Accurate and Up to Date?

MLH takes such steps as are reasonable in the circumstances to ensure that the personal information it holds and discloses is accurate, up to date, complete, relevant, and not misleading. We recognise that information changes frequently with changes of address and other personal circumstances. We generally update your customer information over the telephone. Please advise your consultant when your personal details change.

If you have created a profile with MLH via our website, you are able to review and edit your personal information at any time by logging into your account and reviewing your profile. You can delete your personal information or close your account by contacting the Privacy Officer. If you do choose to close your account with MLH, MLH may retain personal information from your account as and where required by law.

  1. General Information Collected from Visitors to Our Website

We gather information about all our website users collectively, such as what areas users visit more frequently and what services users access the most. We only use such data anonymously and in the aggregate. This information helps us determine what is most beneficial for our users and how we can continually create a better overall website experience for you. We do not disclose information about your individual visits to the MLH website.

  1. Your Personal Information Collected on the MLH Websites

In some instances, we may need specific information about you, such as name, address, email address, telephone number, etc. We will collect this information if you apply for a job or sign up for a service via our website. We may also ask you for other information, such as the types of jobs you are interested in and your workplace concerns, in order to provide you with the best possible service and internet experience.

  1. Cookies Policy

A ‘cookie’ is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.

Cookies are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We also provide information about this in our Marketing preferences page on the MLH website.

  1. How to Reject Cookies

If you don’t want to receive cookies that are not strictly necessary to perform basic features of our site, you may choose to opt out by changing your browser settings. Most web browsers will accept cookies, but if you would rather we didn’t collect data in this way, you can choose to accept all or some or reject cookies in your browser’s privacy settings. However, rejecting all cookies means that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the ‘Help’ menu of your browser to learn how to change your cookie preferences.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

  1. Enquiries & Complaints

You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches of the APPs or IPPs to our Privacy Officer:

Australia

Privacy Officer
Managed Labour Hire Pty Ltd
[Address]
Email: privacy@mlh.com.au
Phone: [Phone Number]

New Zealand

Privacy Officer
Managed Labour Hire Pty Ltd
[Address]
Email: privacy@mlh.co.nz
Phone: [Phone Number]

Complaints

We aim to acknowledge receipt of all complaints within 10 working days and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances, depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time. If you are not satisfied with our response to your complaint in Australia, you can contact the Australian Information Commissioner (OAIC); or in New Zealand, you can contact the Office of the Privacy Commissioner.

  1. Access

Subject to some exceptions that are set out in both the Australian Privacy Principles and the New Zealand Information Privacy Principles, you can gain access to the personal information that we hold about you. To make a request to access your personal information, you will need to complete an application form verifying your identity and specifying what information you require. Please contact our Privacy Officer for an application form. We will respond to your request within a reasonable period (and in any event in compliance with any legal requirements) after the request is made and provide access to the information in the manner requested if it is reasonable and practicable to do so.

We may impose a moderate charge in providing access. Our Privacy Officer will discuss this with you. You should also anticipate that it may take time to process your application for access as there may be a need to retrieve information from storage and review it in order to determine what information is relevant.

If we refuse to provide you with access to your personal information, we will notify you in writing of the reasons for the refusal and the process for escalation regarding this refusal.

  1. Correction

You may request that we correct the personal information that we hold about you if you deem it to be inaccurate, incomplete, out-of-date, irrelevant, or misleading. We will respond to your request within a reasonable period (and in any event in compliance with any legal requirements), and we will take reasonable steps under the circumstances to correct the information.

If we refuse to correct your personal information, we will notify you in writing of the reasons detailing our refusal to correct the information and the process for escalation regarding this refusal. Should we refuse, you may ask us to place with the information a statement that the information is inaccurate, incomplete, out-of-date, irrelevant, or misleading, and we will take such reasonable steps under the circumstances to associate the statement with your information. If you wish to exercise your rights of correction, you should contact our Privacy Officer for an application form. We will not charge you for making the request to correct your information, correcting the information, or associating a statement.

  1. Feedback

MLH has several areas on our website where you can submit feedback under the ‘contact us’ section. Any feedback that is submitted through this area becomes the property of MLH. We may use this feedback, such as success stories or responses to surveys, for marketing purposes or to contact you for further feedback on the site.

  1. Changes to Our Privacy Policy

If at any time our privacy policy changes, the updated details will be available on the privacy policy on our website. Any information we hold about you will be governed by the most current version of the privacy policy.

Contact Details

Australia

Privacy Officer
Managed Labour Hire Pty Ltd
8 Beulah Road, Norwood, SA, 5067
Email: privacy@mlh.com.au
Phone: 02 8366 2332

Effective Date

This Privacy Policy is effective as of the 1st of April 2024.