Privacy Policy | Cozens Mabel

Overview

This Privacy Policy (Policy) details how Cozens Mabel Pty Limited (‘Cozens Mabel’, ‘we’, ‘us’, or ‘our’) protects your privacy and how we comply with the requirements of the Privacy Act 1998 (Cth) and the 13 Australian Privacy Principles (APPs). This Policy also describes:

who we collect information from;
the types of Personal Information collected and held by us;
how this information is collected and held;
the purposes for which your Personal Information is collected, held, used and disclosed;
how you can gain access to your Personal Information and seek its correction;
how you may complain or inquire about our collection, handling, use or disclosure of your Personal Information and how that complaint or inquiry will be handled; and
whether we are likely to disclose your Personal Information to any overseas recipients.

Cozens Mabel assists in the recruitment of candidates on a permanent or contract basis (recruitment services). In order for us to provide our recruitment services, it’s necessary for us to collect and often store Personal Information from candidates, contractors, clients and potential clients. We are committed to managing your Personal Information in a manner that seeks to ensure its confidentiality, integrity and ongoing security.

Personal Information we typically collect

Candidate information: if you’re applying for a role through us, or would like to be considered for future opportunities, you may provide us with Personal Information. This may include Sensitive Information but only where you have consented, and it is necessary to provide our recruitment services. Personal Information we collect may include (but is not limited to) your name, date of birth, address, email address, telephone number, information contained within your resume or covering letter, salary information, bank account details, drivers licence and other identification information, right to work information, memberships of professional or trade associations, and criminal history and/or background checks.
Employer Information: if we are in contact with your business regarding potential recruitment services, or as an engaged client, you may provide Personal Information to us. This may include (but is not limited to) your name, email address, telephone number, operational structures and/or information otherwise provided by you.
Meetings with prospects/candidates: Personal Information may be collected during meetings with prospects and candidates. This may include (but is not limited to) Personal Information voluntarily provided by you, such as your name, email address or resume information.
Referees: Personal Information may be collected as part of our reference checking processes. We will only use Personal Information that is necessary to complete each reference.

How we collect and hold your Personal Information

We typically collect Personal Information directly from you. Collection methods may include:

When we meet you in person or remotely (video conference/telephone).
When you apply for a job online through our website or other online platforms.
When you interact with us directly via phone, email or other means.
When you subscribe to our newsletter.

We may also obtain Personal Information about you from the following third-party sources:

Pre-employment screening and background checking providers.
Referees provided by you as part of the recruitment process.
Our service providers, including third party payroll providers.

We will typically obtain written consent from you before collecting Personal Information from these third parties.

Our Privacy Collection Notice (PCN) can be accessed here and explains when, how and why we collect your personal information, who we may disclose this information to and how to get in contact with us.

Sometimes we may be provided with your Personal Information without having sought it through our normal means of collection. We refer to this as “unsolicited information”. Where we collect unsolicited information we will only hold, use and/or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the information as appropriate.

We will take all reasonable steps to protect the Personal Information we hold relating to you from misuse, interference and loss, unauthorised modification or disclosure, including:

restricting access to your Personal Information to our employees, and those who need that information for the primary purpose of providing our services to you;
implementing ICT security systems, policies and procedures designed to protect Personal Information stored on our computer networks, including multi-factor authentication (MFA) where possible;
staff training, including ICT systems, security and password protection, privacy and confidentiality training;
implementing a paperless office policy;
implementing human resources policies and procedures, such as email and internet usage, confidentiality and document security policies, designed to ensure that staff follow correct protocols when handling Personal Information;
undertaking due diligence with respect to third party service providers who may have access to personal information, including, as far as practicable, whether they are compliant with the APPs or a similar privacy regime; and
ensuring that any Personal Information that we hold in order to provide our Recruitment Services that is no longer needed, or required to be retained by any other laws, or where you ask it to be removed from our systems, is destroyed in a secure manner, deleted or de-identified, as appropriate.

We may retain your Personal Information for the purposes of providing future services to you unless you advise otherwise.

We take all reasonable steps to ensure the Personal Information we hold, use and disclose is accurate, complete and up-to-date. These steps include ensuring that the Personal Information is accurate, complete and up-to-date at the time of collection and when using or disclosing the Personal Information.

On an ongoing basis we maintain and update Personal Information when we are advised by individuals or when we become aware through other means that their Personal Information has changed. We will dispose of your personal information when it is no longer necessary for us to provide our services or where you request the information to be removed from our systems.

Please contact us if any of the details you have provided change. You should also contact us if you believe that the information we have about you is not accurate, complete or up-to-date or if you would like your information to be removed from our systems.

How we use your Personal Information

We only use Personal Information that is reasonably necessary for one or more of our functions or activities (the primary purpose) or for a related secondary purpose that would be reasonably expected by you, or to which you have consented.

Our use of your Personal Information may include:

Candidates:

When you submit your resume to us through any means as part of the job application process.
When we provide our clients with your resume, where your consent has been obtained.
During interview stages of the recruitment process.
When we assist in the completion of pre-employment screening such as background checks.
When we review and match your details held by us against job vacancies which you may be suitable for.
When you subscribe to our trends and opportunity alerts.
When we provide you with industry information, newsletters, or roles available in the market.
When we provide you with career advice, guidance or assistance, including our resume review services.

Contractors:

In addition to the above:

As part of initial and then ongoing payroll management processes.
During ongoing interactions with us over the course of each contract, including in relation to payroll, performance and/or issues and incidents.

Clients:

When we provide candidates with your information as part of the recruitment process.
As part of our billing and invoicing processes.
When you subscribe to our newsletter or attend our seminars.
When we provide you with industry information, newsletters or general information regarding the employment market.

Sharing your Personal Information

We only use Personal Information for the purposes for which it was given to us, or for purposes which are directly related to one or more of our functions or activities. When we provide recruitment services to you we may need to disclose some of your Personal Information to third parties in accordance with this Privacy Policy, including prospective employers, referees, our professional advisors or service providers.

We may disclose Personal Information about an individual to overseas organisations that help us provide our services, in certain circumstances, such as when storing information with a “cloud service provider” which stores data outside of Australia, or when undertaking international search campaigns. Overseas jurisdictions may include the United States, New Zealand, the UK and Ireland.

We will take reasonable steps not to disclose an individual’s Personal Information to overseas recipients unless:

we have satisfied ourselves that the overseas recipient is compliant with the APPs, or a similar privacy regime;
there are circumstances where we have the individuals consent;
we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual or to public safety; or
we are taking appropriate action in relation to suspected unlawful activity or serious misconduct.

We have implemented measures to minimise our risks in relation to cross-border disclosure of personal information, including regularly reviewing our information storage and distribution practices, processes and systems.

We will take reasonable steps to ensure that your personal information is complete, accurate and up to date, which may involve us contacting you as part of this process. You may also contact us if you believe that the information we hold about you is not complete, accurate and up to date or if you wish to request that we stop collecting, holding and using your personal information for any purpose.

You may contact us to request access to the Personal Information that we hold about you, or if you have any questions or concerns about your Personal Information held by us. We will endeavour to meet your request within a reasonable period and, where applicable and subject to any applicable laws, provide you with timely access to your Personal Information. We ask that you notify us promptly if you become aware that any of your Personal Information held by us is inaccurate.

If we do not agree to provide you with access to and/or amend your Personal Information as requested, you will be notified accordingly. Where appropriate, we will provide you with the reason/s for our decision. If the rejection relates to a request to change your Personal Information you may make a statement about the requested change and we will attach this to your record.

If you have any concerns

If you wish to make a complaint about a breach of this Privacy Policy, or of the APPs, you may do so by providing your written complaint by email, letter or facsimile to any one of our contact details as noted below. You may also make a complaint verbally.

We will respond to your complaint within a reasonable time (usually no longer than 30 days) and we may seek further information from you in order to provide a full and complete response.

Your complaint may also be taken to the Office of the Australian Information Commissioner (OAIC).

How to contact us

You can contact us about this Privacy Policy or about your Personal Information by:

Calling 0403 330 649
Emailing us at [email protected]
Writing to us at Level 1, 5 George Street, North Strathfield, 2137.

This Privacy Policy is subject to change at any time. Please check this Privacy Policy regularly for any changes.