1. Introduction

Sutton Recruitment manage personal information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APP). This policy applies to information collected by Sutton Recruitment Pty Ltd (ACN 129 885 838) in its role of providing recruitment services on behalf of our customers. It outlines how we collect personal information and how we maintain, use, store and disclose the personal information we hold and reflects our commitment to you.
The Sutton Recruitment Privacy Policy will be reviewed and updated from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Please regularly check our Privacy Policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of the Sutton Recruitment Privacy Policy, which is available at any time on the Sutton Recruitment website.
By accessing Sutton Recruitment’s website and/or submitting your personal information to us through any means, you consent to the use of your information as described in this policy. If you do not agree with any terms of this Privacy Policy, please do not send your details to Sutton Recruitment in any way.

2. Types of information we will obtain, hold and/or disseminate.

This will depend on whether you are a workseekers, client and/or referee, as follows:
For workseekers it includes information regarding your

  • contact details
  • employment history
  • qualifications
  • competency/psychometric test results,
  • referee reports
  • other information obtained or received by us in connection with your possible and actual work placements.

For clients it includes information that is necessary to help us manage the presentation and delivery of our services and includes:

  • Contact details
  • Organisation structures
  • Job descriptions

For referees it includes information regarding your

  • contact details,
  • authority to provide references
  • employment experience and relationship to the work seeker, and
  • validation of workseeker provided information.
  • other information obtained or received by us in connection with the verbal or written reference.

Sensitive information is a special category of personal information under the Privacy Act 1988. It is information or opinions about you, including membership of a professional or trade association or membership of a trade union; criminal record; health information, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, and sexual preferences or practices. As outlined in the Privacy Act 1988, sensitive information can, in most cases, only be disclosed with your consent.

3. Why your information is held

We will collect your personal information when it is reasonably necessary for us to carry out our activities as a recruitment consultancy and will depend on whether you are a workseeker, client or referee.
For workseekers, the personal information that we obtain, hold and use will be typically used for work placement operations, recruitment activities, statistical purposes and meeting statutory compliance requirements.
For clients, the personal information will typically be used for business relationship management, recruitment activities, marketing, statistical purposes and statutory compliance requirements.
For referees, the personal information will be typically used for the confirmation of you identity and authority to provide references, workseeker assessment, and recruitment activities.

4. When we collect your personal information.

We will collect your personal information at a time when it is reasonably necessary for us to carry out our activities as a recruitment consultancy.
For workseekers, personal information about you will be obtained from you when you complete our registration pack and/or application forms and when you submit your resume and other documentation from time to time. We will check that it is current, complete and accurate and this will sometimes mean that we have to verify the information that we collect from you with third parties.
For clients, personal information about you will be obtained when you provide it to us for business-related purposes.
For referees, personal information about you will be obtained when provided by you in the course of us conducting a workseeker reference.
For all parties we may also obtain personal information about you from publicly available sources including the internet (including social media), newspapers, directories etc. Any information obtained in this way will be managed in accordance with our Privacy Policy and with the APPS.
For all parties we will record and hold your information in our database and will retrieve your information when we need to use or disclose it to carry out our activities as a recruitment consultancy.
Subject to some exceptions, we permit you to access your personal information in accordance with APP: 12;
We will correct or attach associated statements to your personal information in accordance with APP: 13 of the (APPs).
We will 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.
General information may be collected from visitors to our website users or via online forms. You are advised that there are inherent risks associated with using the internet and that you should take all appropriate steps to safeguard your personal information. Sutton Recruitment cannot guarantee that the personal information you submit in this way will not be intercepted by others. Our websites may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. Sutton Recruitment cannot guarantee the content or privacy practices of any external websites and does not accept responsibility for those websites.

5. How your personal information is held

We hold personal information in a combination of secure computer storage facilities including our dedicated recruitment database, paper-based files and other records at our secure premises and take a range of measures to protect your personal information from misuse, interference and loss; unauthorised access, modification or disclosure. Personal information is held 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.

6. Direct marketing

If you have provided your personal details to Sutton Recruitment, we may use personal information to send you direct marketing material. Individuals have the option to unsubscribe from receiving marketing material at any time. When sending direct marketing material we will give you the direct option as to whether or not you wish to receive marketing communications and remain compliant with anti-spam legislation.
We may sometimes use personal information for marketing purposes but only subject to the following:

  • Workseekers, whilst they are registered with us, with updates in relation to employment opportunities, market information and promotions from time to time.
  • Clients, with whom we have a relationship, with market information and promotions from time to time;
    Personal Information is not used by or disclosed to any third party for marketing purposes.

6. Disclosures

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.
We outsource a number of services to contracted service suppliers (CSPs) from time to time. 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. Our CSPs may see some of your personal information. 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.

7. Contact Us

Our privacy officer Mr Andrew Sutton can be contacted during business hours (8:30am – 5:30pm, Monday to Friday, excluding Australian Capital Territory public holidays).
Telephone: 0412 618 975

8. Access

If you wish to obtain access to your personal information you should contact our Privacy Officer. You will need to be in a position to verify your identity. We can refuse access if your request interferes with the privacy rights of other persons or if it breaches any confidentiality that attaches to that information. 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.
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 may impose a moderate charge to cover the administration of processing the request. Any time delay or charge will be discussed with you at the time you request access to your personal information.

9. Correction

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.
Sutton Recruitment has several areas on our website where you can submit feedback, under the ‘contact us’ section. Any feedback that is submitted through this area becomes the property of Sutton Recruitment. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or to contact you for further feedback on the site.

10. Complaints

You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. You can complain about alleged breaches of the APP’s to our Privacy Officer:
Mr Andrew Sutton Director/Principal, Sutton Recruitment PO Box 245 Campbell ACT 2612 or via email
Any complaints should first be made to us in writing.
We aim to acknowledge receipt of all complaints within 10 working days, and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time.
If you are making a complaint about our handling of your personal information, 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 you are not satisfied with our response to your complaint you can contact the Australian Information Commissioner (OAIC).

Updated February 2015