Policies

The 13 Australian Privacy Principles apply to personal information, that is, information or an opinion (whether true or not) relating to an identified individual or which can be used to identify that individual. Please note that information about companies is not personal information. However the principles will apply to an individual who is carrying on a business as a sole trader.

Harnessing Talent collects personal information that is reasonably necessary for, or directly related to, its functions or activities, e.g. human resources consulting services, talent management advice and services, strategic planning, coaching and mentoring, performance review and development, recruitment and selection and similar business activities. The specific types of personal information Harnessing Talent may collect and hold includes, but is not limited to, the following:

• name;
• address
• contact details;
• current and past employment information;
• title;
• nature of business;
• information related to work performance and job role;
• qualifications, training and development, memberships, associations and other accreditations;
• outcomes of psychological, capability or competency analysis;
• contact details of referees
• proof of residency status and any other information required for recruitment and/or selection purposes

As set out below, Harnessing Talent also collects certain information that is not directly and specifically provided by third parties, such as an IP address, browsing pattern on the site, click stream, and the status of cookies placed on a computer. Harnessing Talent does not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which Harnessing Talent has been engaged or may be engaged, or its other functions and activities.

Harnessing Talent only collects personal information that has been directly provided to us by our customers or prospective customers, associates of customers, our suppliers or potential suppliers, our employees or potential employees, third parties who you have asked to provide your personal information to us, including your referees, or is otherwise available in the public domain where this information will assist us with the provision of services to our current and prospective customers. Information may have been provided verbally or in writing (including by email, or other electronic mechanism including web forms).

Also, our website uses cookies to identify site users and their interests and to track usage of the site. Cookies are small pieces of text stored on a computer that help us to know which browser the operator is using, where they have been on the site and any web sites to which they may link in order to use some of our features. By acceptance of our cookie, the user will be permitted access to certain pages of the site without having to log in each time they visit. A user who does not accept the cookie from the site may not be able to access certain areas of the site.

We also log IP addresses, or the location of computers on the internet to help diagnose problems with our server and to administer the site. If the user prefers not to accept a cookie, they can set their web browser to warn them before accepting any cookies. Alternatively they can refuse all cookies by turning them off in their web browser.

Harnessing Talent may at times use and disclose personal information about an individual for the “primary purpose” of collection (i.e. the dominant or fundamental purpose for which that information is collected). As well as providing services to customers, that “primary purpose” includes facilitating our internal business processes, communicating with customers, prospective customers and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations and dealing with enquiries and complaints.

If any of our customers or prospective customers provide us with any sensitive personal information, we will take all reasonable steps to ensure that the sensitive information is securely protected.

Personal information is not disclosed to a third party unless the disclosure is necessary to support the delivery of the services for which Harnessing Talent has been, or is expected to be, engaged, or is required by law. Examples where personal information may be disclosed to a third party include:

• disclosures to our related companies to provide services;
• where Harnessing Talent has contracted an external service provider to assist in the execution of Harnessing Talent’s legitimate activities, including IT service providers, providers of consultancy services and professional advisors;
• potential and actual employers and customers of Harnessing Talent
• Our insurers
• where Harnessing Talent is required by law to provide personal information so that Harnessing Talent complies with court orders, subpoenas or other legislation that requires us to provide personal information.

if you consent to the disclosure of specific information to third parties

Harnessing Talent may need to disclose your personal information to other companies, service providers, including related entities which may be located overseas. The countries in which these recipients may be located will vary from time to time, but may include the United Kingdom, United States of America and other countries from which entities provide services for Harnessing Talent.

When disclosing your personal information to overseas recipients, we take all measures that are reasonable in the circumstances to ensure your personal information is treated in accordance with the APPs.

Any information disclosed to an overseas recipient may only be used for the purposes intended.

Harnessing Talent will take all reasonable steps to protect against the loss, misuse and/or alteration of the information under its control, including through appropriate physical and electronic security strategies. We may hold your personal information in a number of ways, including:

• on our computer systems and database, which may include storing your data on a third party supplier’s system;
• in hard copies (paper files)

Only authorised Harnessing Talent personnel are provided access to personal information, and these employees are required to treat this information as confidential. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will destroy or de-identify these records.

Our policy is that all electronic records are only stored within Australia whenever this is commercially feasible. However, on occasion, a limited number of specialist software applications may involve the storage of personal data at an overseas location where a suitable alternative is not available. We presently store some information in Singapore.

Harnessing Talent will store data with an external provider if a technical assessment of a service provider’s security protocols are considered to meet or exceed the level of security that Harnessing Talent could apply if the electronic data were to be stored in Harnessing Talent’s own in-house systems and where we are satisfied that Harnessing Talent is able to meet its commitments under Australian Privacy Legislation.

Harnessing Talent will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date.

If a person believes that the information we hold is inaccurate or out of date, they may contact our Privacy Officer and we will update the relevant information accordingly.

Under the Australian Privacy Principles, a person has the right to request access to any personal information that we may hold about them and to advise us if the information should be corrected. The Australian Privacy Principles set out the circumstances when we can refuse those requests. If we do refuse a request, we will provide the person with a written notice that sets out the reasons (unless it would be unreasonable to provide them).  Subject to our right to refuse access, Harnessing Talent will provide the person with a report that lists any personal information that we may hold.

Our policy is to provide written acknowledgement of our receipt of any request for access to personal information or a request for correction of personal information within 7 days of the request being received. We will then provide a written response within 30 days of our receipt of the request.

In the event that an individual would prefer to submit a privacy request using a pseudonym or otherwise keep their identity secret, Harnessing Talent will do its best to support that request if it is feasible to do so under the circumstances.

If you wish to make an enquiry about your personal information at Harnessing Talent, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please email our Privacy Officer at info@harnessingtalent.com.au or telephone 0412 857 639.

We will respond to each request within a reasonable time.  If a party has lodged a complaint with Harnessing Talent and is not satisfied with our response, they may contact the Commonwealth Information Commissioner.