Ccentric Group recognises the importance of privacy in relation to personal information of candidates and others. The Privacy Act 1988 (Cth, Australia) (Australian Privacy Act) and any other relevant legislation, including but not limited to the Data Protection Act 1998 (United Kingdom) (DPA) and the Personal Data Protection Act 2012 (Singapore) (PDPA), collectively the (Privacy Acts), apply to Ccentric Group’s collection, use, disclosure and storage of your personal information. For the purpose of the DPA, the data controller is Ccentric Group of Level 6, 92 Pitt St, Sydney, 2000.
For the purposes of this policy, “personal information” means information or an opinion about an identified person, or a person who is reasonably identifiable, from that data or from that data and other information to which Ccentric Group has or is likely to have access:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Where Ccentric Group is providing recruitment services, examples of personal information it may collect and hold include your contact details (mobile number, email address etc.) and career history. Personal information may also include information collected from you during, for the purpose of and as a result of the recruitment process in a number of ways including through your resume, reference checking, verification of educational qualifications and/or professional membership, reference data, results of psychometric and medical tests and results of background and reference checks as well as any other personal information obtained by Ccentric Group in connection with your possible candidature for a position.
Where Ccentric Group is providing leadership consulting services, the types of personal information it may collect about you for the purpose of providing these services include results of psychometric testing, information collected in 360˚ feedback surveys, individual and/or team assessments and development programs.
For the purposes of this policy, “sensitive information” means personal information about a person’s:
(a) racial or ethnic origin; or
(b) political opinions; or
(c) membership of a political association; or
(d) religious beliefs or affiliations; or
(e) philosophical beliefs; or
(f) membership of a professional or trade association; or
(g) membership of a trade union; or
(h) sexual orientation or practices; or
(i) criminal record;
(j) health information about a person; or
(k) genetic information about a person that is not otherwise health information; or
(l) biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(m) biometric templates.
“Sensitive personal data” (as defined in the DPA) shall have the same meaning as “sensitive information” referred to above.
Ccentric Group will follow the privacy principles set out below.
Collection: Ccentric Group may collect information about you in various ways, including by way of dealing with you in person, over the telephone, via video link, through its website, http://www.ccentricgroup.com, over an email server, by conducting reference checks and background checks (including checks to verify educational qualifications, relevant professional membership or working rights) or through customer feedback or survey forms.
Personal information: Ccentric Group will only collect personal information about you to the extent that it is reasonably necessary to do so for one or more of Ccentric Group’s functions or activities as a global executive search and leadership consulting firm.
Sensitive information: Ccentric Group will only collect sensitive information about you with your consent and, again, only where collection is reasonably necessary for one or more of Ccentric Group’s functions or activities as a global executive search and leadership consulting firm, or where collection of the sensitive information is required or authorised by or under a relevant law or a court/tribunal order, or where for instances in Australia, a “permitted general situation” or a “permitted health situation” exists, as defined under the Privacy Act.
Ccentric Group will only ask for information from you by fair and lawful means. In the case of personal information that Ccentric Group asks for, we will collect personal information directly from you unless it is unreasonable or impracticable to do so (which will include, for example, circumstances where Ccentric Group obtains personal information about you from a third party referee for the purpose of conducting a reference check, or where Ccentric Group obtains personal information about you through results of psychometric testing, information collected in 360˚ feedback surveys, individual and/or team assessments and development programs).
In the case of unsolicited personal information, Ccentric Group will treat the personal information in accordance with the Privacy Acts.
Notification of collection
You will be told when Ccentric Group collects personal information by way of a Privacy Collection Statement. In the Privacy Collection Statement, you will be notified of the purpose of the collection, your rights to access your personal information, the fact that your personal information will be shared amongst Ccentric Group companies and what will happen (if anything) if you do not give the information to Ccentric Group.
Use and disclosure
Generally speaking, Ccentric Group will use or disclose personal information for the primary purpose for which it is collected, being your possible placement by Ccentric Group into a new employment position.
Ccentric Group may also use your personal information for secondary purposes related to the primary purpose, which could include: analysis of test results (including medical tests and assessments); identification of training needs; workplace rehabilitation; management of any complaint, investigation or inquiry in which you are involved; or client/candidate business relationship management. Ccentric Group will also use or disclose personal information for a secondary purpose in circumstances where Ccentric Group has obtained your consent to such use or disclosure, where use or disclosure is required or authorised by or under a relevant law or a court/tribunal order, or where for instances in Australia, a “permitted general situation” or a “permitted health situation” exists, as defined under the Privacy Act.
Ccentric Group will also inform all candidates of their right to privacy during the recruitment process by taking a range of steps, including by:
c) taking reasonable steps not to disclose candidate resumes to a third party except with the consent of the candidate or in exceptional circumstances permitted under the Privacy Acts.
Direct marketing: Ccentric Group will not use or disclose sensitive information about you for the purpose of direct marketing unless such disclosure is permitted under the Privacy Act. In the case of personal information which is not sensitive information and which Ccentric has received directly from you, Ccentric Group may use and disclose such information for the purposes of sending you a newsletter or other information related to Ccentric Group’s business or activities. Ccentric Group will not send you these communications if you choose to opt out by contacting Ccentric Group at any time by way of an opt out option contained in such communications. Ccentric Group will only disclose sensitive information about you with your consent.
Ccentric Group will disclose your personal information to third parties outside of the Ccentric Group where it is required to do so in order to carry out identity and qualification verification checks through third party providers (which might include proof of identity checks, police checks, right to work checks and psychometric testing).
Quality of personal information
Ccentric Group will take reasonable steps in the circumstances to facilitate the personal information it collects being accurate, complete and up to date.
Security of personal information
Ccentric Group will take reasonable steps in the circumstances to protect the personal information it collects from misuse, loss, and unauthorised access, modification or disclosure.
Access and correction
Access: Subject to applicable exceptions set out in the Privacy Acts (including where access would pose a serious threat to the life, health or safety of a person), Ccentric Group provides the opportunity for candidates to view and obtain a copy of personal information that Ccentric Group has collected about them.
In some circumstances, Ccentric Group may seek payment for reasonable costs incurred in supplying you with this information but the charges will not apply to the making of the request itself. Please be prepared to sufficiently identify yourself with photo ID prior to viewing any of your personal information.
Correction: If you ask Ccentric Group to correct any of your personal information (for example if your personal information is not accurate or your personal information changes), Ccentric Group will take such steps (if any) as are reasonable in the circumstances to correct or update the personal information. As this procedure could involve retrieving information from storage or archives, please allow up to one week for your request to be actioned. Ccentric Group may also contact you from time to time to update your details. Ccentric Group will not charge you for the cost of making a request or for the cost of correcting the personal information.
If Ccentric Group is unable to agree that the personal information it holds about you is accurate, complete and up to date, you may ask Ccentric Group to place with the information, a statement by you claiming that the information is not accurate, complete and up to date (indicating that the correction was requested but not made). Ccentric Group will not charge you for the cost of making of the request or for the cost of associating the statement with the personal information.
If required under the Privacy Acts, except in exceptional circumstances which are outlined in the Privacy Acts, Ccentric will use Commonwealth Government identifiers for the purpose for which they were issued and will not adopt its own identifiers of a person except where this is necessary to carry out Ccentric Group’s activities or functions.
Anonymity and pseudonymity
To the extent required under the applicable Privacy Acts, wherever lawful and practicable, Ccentric Group will give you the option of not identifying yourself, or of using a pseudonym. However, please note, the nature of the recruitment, executive placement and leadership consulting services which Ccentric Group provides means that in most cases it will not be possible to preserve anonymity and pseudonymity.
Cross border disclosure of personal information
Ccentric Group may disclose personal information to overseas recipients where permitted under the Privacy Acts.
Subject to any applicable exceptions set out in the Privacy Acts, Ccentric Group will only transfer personal information to an overseas jurisdiction in circumstances where the information will have an appropriate level of protection.
By submitting your personal information, you agree to this transfer, storing or processing.
Complaints regarding personal information
Complaints about a breach of the Privacy Act, including the Privacy Principles under the Privacy Act, may be made to Ccentric Group’s Privacy Coordinator at Ccentric Group’s Head Office. The contact details for the Head Office are as follows:
92 Pitt St
Sydney NSW 2000 Australia
Phone: +61 (2) 8422 5300
Fax: +61 (2) 8422 5399