We manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles. This policy applies to information collected by Downs Nursing Agency (DNA).
We only collect information that is reasonably necessary for the proper performance of our activities or functions.
We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it.
We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.
By following the links in this document, you will be able to find out how we manage your personal information as an APP Entity under the Australian Privacy Principles (APPs). You will also be able to find out about the information flows associated with that information. If you have any questions in relation to this, please contact us.
1.1 APP Entity
DNA manages personal information, as an APP Entity, under the Australian Privacy Principles (APPs).
Because we are a contracted service provider to a range of Commonwealth, State and Territory government agencies as well as private agencies, it sometimes becomes necessary for us to collect and manage personal information as an Agency under different privacy arrangements. If you wish to know whether this applies to you, please contact us.
1.2. Information Flow
When we collect your personal information:
- we check that it is reasonably necessary for our functions or activities as a nursing recruitment agency.
- we check that it is current, complete and accurate. This will sometimes mean that we have to cross check the information that we collect from you with third parties.
- we record and hold your information in our Information Record System. No information is disclosed to overseas recipients.
- we retrieve your information when we need to use or disclose it for our functions and activities. At that time, we check that it is current, complete, accurate and relevant. This will sometimes mean that we have to cross check the information that we collect from you with third parties once again - especially if some time has passed since we last checked.
- subject to some exceptions, we permit you to access your personal information in accordance with APP:12 of the (APPs).
- we correct or attach associated statements to your personal information in accordance with APP:13 of the (APPs).
- we destroy or de-identify your personal information when it is no longer needed for any purpose for which it may be used or disclosed provided that it is lawful for us to do so. We do not destroy or de-identify information that is contained in a Commonwealth Record.
2. Kinds of information that we collect and hold
Personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as a nursing recruitment agency and is likely to differ depending on whether you are:
- a Workseeker;
- a Client;
- a Referee.
2.1. For Workseekers
The type of information that we typically collect and hold about Workseekers is information that is necessary to assess amenability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us and includes:
- your personal details including your address, phone numbers and date of birth
- Your photograph for your DNA ID card
- Your tax file number
- Photocopies of the documents supplied to support your 100 point identity check
- Your criminal history check
- Relevant financial details including banking and superannuation details
- Your registration details (if applicable)
- Mandatory training that you have undertaken
- Your resume, including your previous nursing experience and skills
- Your availability and preferences for work
- Any incidences or complaints received
2.2. For Clients
The type of information that we typically collect and hold about Clients is information that is necessary to help us manage the presentation and delivery of our services and includes:
- contractual arrangements
- Invoices and financial information including your ABN
- Billing address including email address
- Insurance details
- Contact details of relevant staff and their phone numbers
- Information in relation to any requests for work
- Any incidences or complaints
2.3. For Referees
The type of information that we typically collect and hold about Referees is information that is necessary to help to make determinations about the suitability of one of our Workseekers for particular jobs or particular types of work and includes:
- your name
- Your contact details including phone numbers and email address
- The completed reference
The purposes for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:
- a Workseeker;
- a Client;
- a Referee.
The following sections are also relevant to our use and disclosure of your personal information:
- Our Policy on Direct Marketing
- Overseas Disclosures
3.1. For Workseekers
Information that we collect, hold, use and disclose about Workseekers is typically used for:
- work placement operations;
- recruitment functions;
- statistical purposes and statutory compliance requirements;
3.2. For Clients
Personal information that we collect, hold, use and disclose about Clients is typically used for:
- client and business relationship management;
- recruitment functions;
- marketing services to you;
- statistical purposes and statutory compliance requirements;
- teaching purposes.
3.3. For Referees
Personal information that we collect, hold, use and disclose about Referees is typically used for:
- to confirm identity and authority to provide references;
- Workseeker suitability assessment;
- recruitment functions;
3.4. Our Policy on Direct Marketing
Your information is not provided to any third parties for direct marketing.
4. How your personal information is collected
The means by which we will generally collect your personal information are likely to differ depending on whether you are:
- a Workseeker
- a Client
- a Referee
We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.
Sometimes the technology that is used to support communications between us will provide personal information to us - see the section in this policy on Electronic Transactions. See also the section on Photos & Images.
4.1. For Workseekers
Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to us for work.
Personal information is also collected when:
- your annual registration is paid
- You provide us with evidence of your mandatory training / competencies
- You provide us with evidence of a complaint or clinical incident that has occurred while employed by DNA
- You are providing a response to a complaint / clinical incident while employed by
- Criminal history checks are undertaken
4.2. For Clients
Personal information about you may be collected:
- when you provide it to us for business or business related social purposes;
- when you request shifts to be booked
- when you fax time sheets to us
- when undertaking billing and invoicing
- for education purposes, for example orientation of staff to specific facilities.
4.3. For Referees
Personal information about you may be collected when you provide it to us:
- in the course of our checking Workseeker references with you and when we are checking information that we obtain from you about Workseekers;
4.4. Photos & Images
When applying for a position with DNA, we will take photocopies of your relevant photo ID for our records. These are kept in a secure file in DNA. This information is not shared with any external or third party.
4.5. Electronic Transactions
Sometimes, we collect personal information that individuals choose to give us via online forms or by email, for example when individuals:
- ask to be on an email list such as a job notification list;
- register as a site user to access facilities on our site such as a job notification board;
- make a written online enquiry or email us through our website;
- submit a resume by email or through our website;
It is important that you understand that there are risks associated with use of the Internet and you should take all appropriate steps to protect your personal information. It might help you to look at the OAIC's resource on Internet Communications and other Technologies.
You can contact us by land line telephone or post if you have concerns about making contact via the Internet.
Computers at DNA are professionally serviced at regular intervals. We do not collect any information when you are browsing our website. We do not utilise social networks to promote DNA.
5. How your personal information is held
Personal information is held in our Information Record System until it is no longer needed for any purpose for which it may be used or disclosed at which time it will be de-identified or destroyed provided that it is lawful for us to do so.
We take a range of measures to protect your personal information from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
5.1.Our Information Record System
We maintain a database of employee details to accurately record personal information pertaining to your employment. All databases are password protected.
Shift availability is maintained in a hard copy as well as electronically.
5.2. Information Security
All computers at DNA have virus and corruption protection programs that are regularly updated and maintained. Our databases are reviewed every three months and if you are no longer employed by DNA all your data is archived for seven years for taxation purposes.
After seven years, any hard copies of personal information are destroyed utilising a document shredder.
We may disclose your personal information for any of the purposes for which it is primarily held or for a lawful related purpose.
We may disclose your personal information where we are under a legal duty to do so.
Disclosure will usually be:
- internally and to our related entities
- to our Clients
- to Referees for suitability and screening purposes.
6.1. Related Purpose Disclosures
We outsource a number of services to contracted service suppliers (CSPs) from time to time. Our CSPs may see some of your personal information. Typically our CSPs would include:
- Software solutions providers;
- I.T. contractors and database designers and Internet service suppliers;
- Legal and other professional advisors;
- Insurance brokers, loss assessors and underwriters;
- Superannuation fund managers;
- Background checking and screening agents;
- Government agencies for example Centrelink.
We take reasonable steps to ensure that terms of service with our CSPs recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations.
6.2. Cross-Border Disclosures
We do not disclose your information to overseas recipients.
7. Access & Correction
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold.
Important exceptions include:
- evaluative opinion material obtained confidentially in the course of our performing reference checks; and access that would impact on the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that the person who gave us that information is entitled to expect will be observed. We do refuse access if it would breach confidentiality.
For more information about access to your information see our Access Policy.
For more information about applying to correct your information see our Correction Policy.
7.1. Access Policy
If you wish to obtain access to your personal information you should contact our Privacy Coordinator. You will need to be in a position to verify your identity. If we cannot verify your identity, personal information will not be disclosed to you. We will endeavour to address your request within five business days.
7.2. Correction Policy
If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us.
We will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading.
If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third parties to whom we made the disclosure and we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.
We will endeavour to correct any anomalies within five business days.
You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.
For more information see our Complaints Procedure.
7.3. Complaints procedure
If you are making a complaint about our handling of your personal information, it should first be made to us in writing.
You can make complaints about our handling of your personal information by contacting us directly on (07) 4617 8888 or by mail at Unit 1/4 Mylne Street, Toowoomba, QLD 4350. You can also make complaints to the Office of the Australian Information Commissioner.
Complaints may also be made to RCSA, the industry association of which we are a member.
RCSA administers a Code of Conduct for the professional and ethical conduct of its members.
The RCSA Code is supported by rules for the resolution of disputes involving members.
NOTE: The Association Code and Dispute Resolution Rules do NOT constitute a recognised external dispute resolution scheme for the purposes of the APPs; but are primarily designed to regulate the good conduct of the Associations members.
When we receive your complaint:
- We will take steps to confirm the authenticity of the complaint and the contact details provided to us to ensure that we are responding to you or to a person whom you have authorised to receive information about your complaint;
- Upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy.
- We may ask for clarification of certain aspects of the complaint and for further detail;
- We will consider the complaint and may make inquiries of people who can assist us to established what has happened and why;
- We will require a reasonable time (usually 30 days) to respond;
- If the complaint can be resolved by procedures for access and correction we will suggest these to you as possible solutions;
- If we believe that your complaint may be capable of some other solution we will suggest that solution to you, on a confidential and without prejudice basis in our response;
If the complaint cannot be resolved by means that we propose in our response, we will suggest that you take your complaint to any recognised external dispute resolution scheme to which we belong or to the Office of the Australian Information Commissioner.