1.1 From time to time Ascot Mill Consultants, a legal subsidiary of The Tullius Group Pty Ltd (“the Company “) is required to collect,
hold, use and/or disclose personal information relating to individuals (including, but
not limited to, its customers, contractors, suppliers and employees) in the performance
of its business activities.
1.2 This document sets out the Company’s policy in relation to the protection of personal
information, as under the Privacy Act 1998 (Cth) the (“Act “) and the Australian
Privacy Principles (“APP “).
1.3 The APPs regulate the handling of personal information.
2. What is personal information?
2.1 Personal information means information or an opinion (including information or an
opinion forming part of a database), whether true or not, and whether recorded in a
material form or not, about an individual whose identity is apparent, or can reasonably
be ascertained, from the information or opinion.
3. Employee records
3.1 This policy does not apply to the collection, holding, use or disclosure of personal
information that is an employee record.
3.2 An employee record is a record of personal information relating to the employment
of an employee. Examples of personal information relating to the employment of the
employee include, but are not limited to, health information and information about the
engagement, training, disciplining, resignation, termination, terms and conditions of
employment of the employee. Please see the Act for further examples of employee
4. Kinds of information that the Company collects and holds
4.1 The Company collects personal information that is reasonably necessary for one or
more of its functions or activities.
4.2 The type of information that the Company collects and holds may depend on your
relationship with the Company. For example:
(a) Candidate: if you are a candidate seeking employment with the Company,
the Company may collect and hold information including your name,
address, email address, contact telephone number, gender, age, employment
history, references, resume, medical history, emergency contact,
taxation details, qualifications and payment details.
(b) Customer: if you are a customer of the Company, the Company may collect
and hold information including your name, address, email address,
contact telephone number, gender and age.
(c) Supplier: if you are a supplier of the Company, the Company may collect
and hold information including your name, address, email address, contact
telephone number, business records, billing information, information
about goods and services supplied by you.
(d) Referee: if you are a referee of a candidate being considered for employment
by the Company, the Company may collect and hold information
including your name, contact details, current employment information
and professional opinion of candidate.
4.3 Sensitive information: the Company will only collect sensitive information where
you consent to the collection of the information and the information is reasonably
necessary for one or more of the Company’s functions or activities. Sensitive information
includes, but is not limited to, information or an opinion about racial or ethnic
origin, political opinions, religious beliefs, philosophical beliefs, membership of
a trade union, sexual preferences, criminal record, health information or genetic information.
5. How the Company collects and holds personal information
5.1 The Company must collect personal information only by lawful and fair means. The
Company will collect personal information directly from you if it is reasonable or
practicable to do so.
5.2 The Company may collect personal information in a number of ways, including without
(a) through application forms;
(b) by email or other written mechanisms;
(c) over a telephone call;
(d) in person;
(e) through transactions;
(f) through our website;
(g) through surveillance camera;
(h) by technology that is used to support communications between us;
i) through publically available information sources (which may
include telephone directories, the internet and social media
ii) direct marketing database providers;
5.3 When the Company collects personal information about you through publicly available
information sources, it will manage such information in accordance with the
5.4 At or before the time or, if it is not reasonably practicable, as soon as practicable after,
the Company collects personal information, the Company must take such steps
as are reasonable in the circumstances to either notify you or otherwise ensure that
you are made aware of the following:
(a) the identity and contact details of the Company;
(b) that the Company has collected personal information from someone other
than you or if you are unaware that such information has been collected;
(c) that collection of personal information is required by Australian law, if it is;
(d) the purpose for which the Company collects the personal information;
(e) the consequences if the Company does not collect some or all of the
(f) any other third party to which the Company may disclose the personal
access and seek correction of personal information held by the Company
and how you may complain about a breach of the APPs; and
(h) whether the Company is likely to disclose personal information to overseas
recipients, and the countries in which those recipients are likely to
5.5 Unsolicited personal information is personal information that the Company receives
which it did not solicit. Unless the Company determines that it could have
collected the personal information in line with the APPs or the information is contained
within a Commonwealth record, it must destroy the information to ensure it
6. Purposes for which the Company collects, holds, uses and/or discloses personal
6.1 The Company will collect personal information if it is reasonably necessary for one
or more of its functions or activities.
6.2 The main purposes for which the Company may collect, hold, use and/or disclose
personal information may include but are not limited to:
(a) recruitment functions;
(b) customer service management;
(c) training and events;
(d) surveys and general research; and
(e) business relationship management.
6.3 The Company may also collect, hold, use and/or disclose personal information if you
consent or if required or authorised under law.
6.4 Direct marketing:
(a) The Company may use or disclose personal information (other than sensitive
information) about you for the purpose of direct marketing (for example,
advising you of new goods and/or services being offered by the
(b) The Company may use or disclose sensitive information about you for
the purpose of direct marketing if you have consented to the use or disclosure
of the information for that purpose.
(c) You can opt out of receiving direct marketing communications from the
Company by contacting the Privacy Officer in writing or if permissible
accessing the Company’s website and unsubscribing appropriately.
7. Disclosure of Personal Information
7.1 The Company may disclose your personal information for any of the purposes for
which it is was collected, as indicated under clause 6 of this policy, or where it is
under a legal duty to do so.
7.2 Disclosure will usually be internally and to related entities or to third parties such as
contracted service suppliers.
7.3 Before the Company discloses personal information about you to a third party, the
Company will take steps as are reasonable in the circumstances to ensure that the
third party does not breach the APPs in relation to the information.
7.4 Cross-border disclosure of personal information:
(a) The Company is likely to disclose personal information to overseas recipients.
(b) Before the Company discloses personal information about you to an
overseas recipient, the Company will take steps as are reasonable in the
circumstances to ensure that the overseas recipient does not breach the
APPs in relation to the information.
(c) The countries in which overseas recipients are likely to be located include:
i) United Kingdom, United States of America, China, Hong
Kong, Russia, Taiwan, and countries within the European
8. Access to personal information
8.1 If the Company holds personal information about you, you may request access to
that information by putting the request in writing and sending it to the Privacy Officer.
The Company will respond to any request within a reasonable period, and a charge
may apply for giving access to the personal information.
8.2 There are certain circumstances in which the Company may refuse to grant you
access to the personal information. In such situations the Company will give you
written notice that sets out:
(a) the reasons for the refusal; and
(b) the mechanisms available to you to make a complaint.
9. Correction of personal information
9.1 If the Company holds personal information that is inaccurate, out-of-date, incomplete,
irrelevant or misleading, it must take steps as are reasonable to correct the
9.2 If the Company holds personal information and you make a request in writing addressed
to the Privacy Officer to correct the information, the Company must take
steps as are reasonable to correct the information and the Company will respond to
any request within a reasonable period.
9.3 There are certain circumstances in which the Company may refuse to correct the
personal information. In such situations the Company will give you written notice
that sets out:
(a) the reasons for the refusal; and
(b) the mechanisms available to you to make a complaint.
9.4 If the Company correct personal information that it has previously supplied to a third
party and you request us to notify the third party of the correction, the Company will
take such steps as are reasonable to give that notification unless impracticable or
unlawful to do so.
10. Integrity and security of personal information
10.1 The Company will take such steps (if any) as are reasonable in the circumstances
to ensure that the personal information that it:
(a) collects is accurate, up-to-date and complete; and
(b) uses or discloses is, having regard to the purpose of the use or disclose,
accurate, up-to-date and complete.
10.2 The Company will take steps as are reasonable in the circumstances to protect the
personal information from misuse, interference, loss and form unauthorised access,
modification or disclosure.
10.3 If the Company holds personal information, it no longer needs the information for any
purpose for which the information may be used or disclosed, the information is not
contained in any Commonwealth record and the Company is not required by law to
retain the information, it will take such steps as are reasonable in the circumstances
to destroy the information or to ensure it is de-identified.
11. Anonymity and Pseudonymity
11.1 You have the option of not identifying yourself, or using a pseudonym, when dealing
with the Company in relation to a particular matter. This does not apply:
(a) where the Company is required or authorised by or under an Australian
law, or a court/tribunal order, to deal with individuals who have identified
(b) where it is impracticable for the Company to deal with individuals who
have not identified themselves or who have used a pseudonym.
11.2 However, in some cases if you do not provide the Company with your personal information
when requested, the Company may not be able to respond to your request
or provide you with the goods or services that you are requesting.
12.1 You have a right to complain about the Company’s handling of your personal information
if you believe the Company has breached the APPs.
12.2 If you wish to make such a complaint to the Company, you should first contact the
Privacy Officer in writing. Your complaint will be dealt with in accordance with the
Company’s complaints procedure and the Company will provide a response within
a reasonable period.
12.3 If you are unhappy with the Company’s response to your complaint, you may refer
your complaint to the Office of the Australian Information Commissioner.
13. Privacy Officer contact details
13.1 The Company’s Privacy Officer can be contacted in the following ways:
(a) Telephone number: +61 (0)7 3184 4401
(b) Email address: email@example.com
(c) Postal address: Level 38, 345 Queen Street, Brisbane, QLD 4000