privacy EEO policies

"Understanding the importance of maintaining workplaces discrimination & harassment free"


Privacy Principles

  • For Information subject to Australian law, the National Privacy Principles established by the Privacy Act 1988 (C’th) apply to APS PERSONNEL.

How to contact us

If you wish to contact us about your personal information you should contact Roy Johnson, APS Personnel’s Privacy coordinator on 02 66 580 755 during normal office hours which are Monday to Friday 8.30am to 5.00pm.


We will only collect information that is necessary for the proper performance of our tasks 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 do not routinely conduct criminal history checks and only do so in order to obtain relevant criminal history with regard to particular jobs you are offered or for which you are shortlisted. We do not collect or use personal information for the purposes of unlawful discrimination. We may decline to collect unsolicited personal information from or about you and may take such measures as we think appropriate to purge it from our systems.

Type of Personal Information Held

Personal information that we collect and hold usually falls into the following categories:

  • Candidate information submitted and obtained from the candidate and other sources in connection with applications for work;
  • Work performance information;
  • Information about incidents in the workplace;
  • Staff information;
  • Information submitted and obtained in relation to absences from work due to leave, illness or other causes;
  • Information obtained to assist in managing client and business relationships;

How your information will be collected

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:

  • we receive or give any reference about you;
  • we receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body;
  • we receive the results of any competency or medical test;
  • we receive performance feedback (whether positive or negative);
  • we receive any complaint from or about you in the workplace;
  • we receive any information about a workplace accident in which you are involved;
  • we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
  • you provide us with any additional information about you;
  • electronically through our telecommunications and technology systems – see the section in this policy on electronic transactions.

Purposes for which we hold personal information

We primarily hold personal information for the following:

  • Employment placement operations;
  • Recruitment;
  • Staff management;
  • Training;
  • Risk management;
  • Client and business relationship management;
  • Marketing services to you; but only where this is permitted and whilst you are registered with us;
  • Statistical purposes and statutory compliance requirements;


We may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted. We may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a contractual or lawful duty of care to disclose information. We do not share personal information about you with government agencies, organisations or anyone else unless one of the following applies:

  • You have consented;
  • You would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies;
  • it is required or authorised by law;
  • it will prevent or lessen a serious and imminent threat to somebody’s life or health;
  • the disclosure is reasonably necessary for the enforcement of the criminal law or of a law imposing a pecuniary penalty, or for the protection of public revenue.

Outsourced Service Suppliers

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:

  • I.T. contractors and database designers and service internet service suppliers, some of whom may be off shore;
  • Legal and other professional advisors;
  • Insurance brokers, loss assessors and underwriters;
  • Superannuation fund managers;
  • Background checking and screening agents;

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

Personal Information Quality

We rely on you to tell us when there are changes to your personal information that we hold about you.  This could be e.g. a change of address, contact details or employment status.

Children, Minors and Persons under a Legal Disability

Determining the decision-making capabilities of a person who is under a legal disability can be a complex matter, often raising ethical and legal issues. We endeavour to address each case individually with a view to deciding whether the individual is able to give consent or receive notifications based upon an assessment of whether the individual has sufficient understanding to comprehend the nature and quality of what is being proposed. In some circumstances, it may be appropriate for a parent, guardian, holder of an enduring power of attorney (or like authority) or next of kin whom to be contacted in any case in which consent is required or notification is to be given and where it is not practicable to obtain it from or give it directly from the individual.

Personal Information Security

We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed.  However it is not always practicable to destroy or de-identify electronic data.  Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent inadvertent access to it.

Photos and Images

We may not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances. But we may request a digital photo be taken for ID purposes and included on your data-base file at the time of registration.

Inquiries and Complaints

You can make further inquiries or complaints about our privacy policies to our Privacy Co-ordinator whose contact details are as above. You can also make complaints to the Privacy Authorities in your state and for information go to Complaints may also be made to RCSA with regard to Member conduct.

Other Parties

We cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.


Subject to some exceptions that are set out in privacy law, you can gain access to the personal information that we hold about you. 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. We do refuse access if it would breach any confidentiality that attaches to that information or if it would interfere with 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 we make and which the communicator of that information is entitled to expect will be observed. If you wish to obtain access to your personal information you should contact our Privacy Co-ordinator.  You will need to be in a position to verify your identity. We might impose a moderate charge in providing access.  Our Privacy Co-ordinator would discuss these with you. You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within 20 working days.

Electronic Transactions

This section explains how we handle personal information collected from our website and by other technology in the course of electronic transactions. 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:

  • Australia: –

It is important that you:

  • Know your rights: read our privacy policy, collection statement and consent to electronic transactions.
  • Be careful what information you share on the Web.
  • Use privacy tools on the site – control access to your search listing and profile.
  • Make sure your anti-virus and data protection software is up-to-date.

Please contact our office by phone or mail if you have concerns about making contact via the internet. For further information see the How to contact us in this document. 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;

Browsing – When an individual looks at our website, our internet service provider makes a record of the visit and logs (in server logs) the following information for statistical purposes:

  • the individual’s server address
  • the individual’s top level domain name (for example .com, .gov, .org, .au, etc)
  • the pages the individual accessed and documents downloaded
  • the type of browser being used.

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the internet service provider’s server logs. We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

Cookies – Cookies are uniquely numbered identification numbers like tags which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on our site we will then link your cookie back to your personal information details. This site uses cookies to monitor usage of the website, to enable purchases, and to create a personal record of when you visit our website and what pages you view. Cookies are necessary to enable various activities on our web site, but if you do not wish us to retain any information about your visit to our site you could delete the cookies on your browser and change the settings on your web browser program.


Our website uses session cookies during a search query of the website. Our internet service provider does not employ cookies on our website except in those circumstances. The website statistics for this site are generated from the server logs as outlined above. When an individual closes their browser the session cookie set by our website is destroyed and no personal information is maintained which might identify an individual should they visit our website at a later date.

Social Networks and Web Searches – In order to assess your suitability for positions and to assist you to find work, we will need to collect, use and disclose personal information about you. It has become common practice in some places for employment service providers to conduct background checking via social network media sites frequented by candidates. We will not conduct background checking via social network media sites other than those that you identify and authorise us to check.  However we do conduct internet searches using search engines and entering your name and relevant identifying details.

Uploading photographs – Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws, and you may be responsible for any legal consequences.

Emails – Our technology systems log emails received and sent and may include voting, and read and receipt notifications to enable tracking.

When your email address is received by us because you send us a message, the email address will only be used or disclosed for the purpose for which you have provided it and it will not be added to a mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Call and message logs – Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display. When your call number is received by us because you phone us or send us a message, the number will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Teleconferences and Video conferences – Teleconferences and video conferences may be recorded with your consent.  In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

Database – We use recruiting software and databases to log and record recruitment operations.

Paperless Office – Recognising the environmental advantages and efficiencies it provides, we operate a partially paperless office as a result of which your paper based communications with us may be digitised and retained in digital format, the paper based communications may be culled. It is therefore important that, except where specifically requested, you do not send us originals of any paper based document and that you retain copies for your own records. Where we do request original paper based documents we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed.

Future Changes

This policy may change over time in light of changes to privacy laws, technology and business practice.  If you use our website regularly it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.




Our Commitment

As an employment and recruitment service provider APS Personnel understands the importance of maintaining workplaces and recruitment practices that are free from unlawful discrimination and harassment, including sexual harassment. Our clients, employees and contractors expect us to be leaders in recruitment and workforce management and we understand that our influence extends to candidates looking for work, employees working directly for us, individuals working on assignment as on-hired workers and to clients seeking our advice and support.  We therefore promote recruitment based on merit and fairness.

We recognise that a workplace free from unlawful discrimination and harassment will inspire confidence, creativity and general wellbeing which will ultimately result in improved productivity and better delivery of service to customers and clients.  Our ability to maintain healthy workplaces is also critical to our capacity to attract higher quality candidates and present them to our clients. Unlawful discrimination and harassment, including sexual harassment, will not be tolerated by us and we encourage the reporting of any alleged breaches of this policy and related procedures to management and other nominated equal opportunity officers.



Direct discrimination means treating someone unfairly or less favourably because of one of the personal characteristics listed below or because of their association with someone identified with one of those characteristics.


Indirect discrimination happens when a rule, policy or requirement unnecessarily or unreasonably disadvantages a person or group of people because of a protected personal characteristic they share.

Harassment is behaviour (through words or actions) based on personal characteristics listed below, that is unwanted, unasked for, unreturned and likely to make the workplace an unfriendly or uncomfortable place.

Sexual harassment is an unwelcome sexual advance, request for sex or any other sexual behaviour that a reasonable person would know or expect would offend, humiliate, seriously embarrass or humiliate another.

Personal Characteristics Protected by the Law

In most States and Territories of Australia it is unlawful to discriminate or harass a person in the workplace on the basis of the following characteristics or personal association with someone who has, or is assumed to have, one of these personal characteristics:

  • age
  • breastfeeding
  • carer status
  • disability/impairment
  • gender identity
  • industrial activity
  • lawful sexual activity
  • marital status
  • parental status
  • physical features
  • political belief or activity
  • pregnancy
  • race
  • employment activity
  • religious belief or activity
  • sex
  • sexual orientation

Application of this Policy


This policy applies to our recruitment and employment practices, including our recruitment systems, performance management processes, promotional policies, training policies as well as our remuneration and bonus structures. This policy applies to our employees, contractors, volunteers and on-hired workers whether they are another organisations workers working within our workplace or those on-hired to our clients. This policy applies to all work within standard working hours as well as functions, events and training that are sponsored by us e.g. conferences and Christmas parties. Where a complaint arises during the course of an on-hired worker assignment with one of our clients we will work with our client to ensure the complaint is effectively managed and resolved.

Responsibility for this Policy


Whilst management of APS PERSONNEL are primarily responsible for ensuring this policy is implemented at all levels of the business, it is important that all persons covered by the agreement understand that they have an active role to play in implementation.  We may assign specific responsibility for implementation and complaints resolution to employees of the company. Any person covered by this policy has a responsibility to report suspected breaches of this policy to management or other nominated equal opportunity officers.


We are committed to resolving any complaints fairly and effectively.  All complaints will be treated confidentially, fairly and consistently, and resolved as speedily as possible. Complaints shall be resolved in accordance with the APS PERSONNEL Equal Opportunity Complaints Resolution Procedure and all persons covered by this policy are required to adhere to this procedure unless suitable alternative arrangements are agreed.


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