We are Redpath Partners, a recruitment services firm founded in Australia with offices in Sydney, Hong Kong, Dubai and New York. (“”our” “we,” “us”). Detail for each of our entities, including registered office address, is set out below:
|Location||Company name||Company number||Registered office address|
|Australia||Redpath Partners Pty Ltd||ACN 142 902 30||Level 5, 107 Pitt Street Sydney, NSW 2000|
|Hong Kong||Redpath Partners Limited||52367105-000-05-18-0||9/F, Shun Ho Tower, 24-30 Ice House Street, Central, Hong Kong|
|United States||Redpath Partners Inc.||DOS ID #: 4733388||21 W 46th Street, 16th Floor New York, New York, 10036|
|United Arab Emirates||Redpath Partners HR Consultancy||727704||Level 27, Marina Plaza, Dubai Marina, P.O Box 112229 Dubai, United Arab Emirates|
We are committed to ensuring that we demonstrate our commitment to protecting and respecting privacy in our dealings with personal information regarding job-seekers, referees, clients, users of our website and others with whom we deal (“you,” your”). This statement sets out our policy on how we process your personal data.
It is our intention to concurrently comply with the Australian Privacy Principles (APPs) and European General Data Protection Regulation 2016/679 (“GDPR”), to the extent possible. Where dual compliance is not possible, the GDPR will apply to your personal data if you reside in the EU while the APPs will apply if you reside in Australia or any other country, which will be reflected in this policy.
In this policy, “personal data” is the collective term used to refer to both ‘personal information’ as it is defined under Australian privacy law and ‘personal data’ as it is defined under the GDPR.
We decide the purpose and means by which personal data collected about you is processed. For GDPR purposes, we are known as the ‘controller’ of your personal data. For information on how to contact us, refer to the Privacy Officer section of this policy.
Your privacy is important to us and we have a Privacy Officer dedicated to seeing that we comply with the policy. Our Privacy Officer’s details are set out below:
Redpath Partners Pty Ltd
Level 5, 107 Pitt Street Sydney, NSW 2000
p: +61 (0) 2 8071 4260
f: +61 (0) 2 8071 4269
Types of personal data we collect
Usually, the type of personal data that we collect includes, but is not limited to:
- Contact details;
- Job-seeker or consultant information submitted by resume, CV or application;
- Financial information;
- Educational information;
- Work performance information; and
- Information obtained from reference checks.
We may also collect personal data of a more detailed and sensitive nature (“special category data”) about you if you provide your explicit consent. This includes:
- Health or medical information, such as if you require any special assistance or arranging medicals as part of the screening process;
- Nationality, which may incidentally include racial or ethnic origin, as a result of conducting right to work checks; and
- Details of any prior criminal convictions if you reside in Australia, or another country in which the laws authorise such processing.
How we collect your personal data
We endeavour to only collect personal data which you knowingly provide us, for example, when you complete an online form or information you provide to us when you send us an email or call us. In general, we will record your email address if you send us an email.
Methods by which we may request or obtain your personal data include when you:
- contact us for further information;
- participate in surveys and other types of research;
- subscribe to a mailing list that we operate; and
- express interest in a particular service offered by us or submit a job application or resume.
There may be occasions when we obtain personal information about you from third parties, where it is unreasonable or impracticable to collect the personal information from you. If we are unable to notify you prior to the collection of your personal data from a third party, we will always take reasonable steps to inform you as soon as practicable after the collection. No sensitive information will be collected, either from you or a third party, without your prior consent.
We may also collect personal data from you when you use our website www.redpathpartners.com. Your use of the information and services available through our website will determine the type of information that we collect about you. We only collect personal data through our website when you knowingly provide it, for example, when you complete an online form or when you send us an email. Also refer to the below section ‘Use of tracking technologies.’
Use of tracking technologies
We use tracking technologies such as cookies to recognise your browser each time it visits our site and track which pages you visit whilst on our site. Cookies are used for the purpose of optimising our site and create a better online experience for users.
Cookies are pieces of information that a website transfers to a computer’s hard disk for record keeping purposes. Most web browsers are set to accept tracking technologies such as cookies. These tracking technologies do not themselves personally identify users, although they do identify a user’s browser. However, if you do not wish to receive any cookies, you may set your browser to refuse them – information on how to do this is available at http://www.allaboutcookies.org/. Note that blocking cookies may result in your inability to access all of parts of our website.
Basis for our collection, use, disclosure and otherwise processing of your personal data
We only collect personal data that is necessary for us to conduct our business as a provider of recruitment services. We collect personal data primarily to enable the placement of job seekers and assisting job seekers in finding or obtaining work (“primary purpose”). In some cases, provision of personal data is necessary to enter into a contract with us. If you do not give us the information we request from you, we may be limited in our ability locate and place you in suitable work.
The processing (including collection) of your personal data is therefore necessary for the pursuit of our legitimate interests, which involves the provision of recruitment services to you. We carry out a balancing test to ensure our legitimate interests will not outweigh your rights and freedoms.
Special category data will be only be processed on the basis of your explicit consent. If the GDPR is applicable to you, we will not process your personal data as it pertains to any criminal convictions or offences unless such processing is authorised under the laws of the Member State in which you reside.
Some processing may also be necessary to fulfil our obligations under applicable laws.
How we process your personal data
We may process (which includes use and disclosure) your personal data for the primary purposes it was collected or for a related or ancillary purpose such as the provision of any one or more other services normally provided by us to clients or customers. In certain situations we must obtain your consent to use or disclose your personal information for a purpose other than the primary purpose.
We may disclose your personal data to:
- Potential and actual employers or employees;
- Nominated referees;
- Any person or body to which we are required by law to disclose information;
- Our insurers;
- Third party service providers or contractors who assist with the provision of our services
- In some circumstances to any competent organisation that conducts background and criminal record checks, if applicable to you, (provided that the organisation undertakes to comply with privacy laws and keep all information supplied to the organisation confidential); and
- To educational or vocational organisations to the extent necessary to verify qualifications.
Purposes for which we disclose your personal information include:
- Your actual or possible work placement;
- Career guidance or management;
- To comply with our legal obligations and rights, under contracts and at law, and to cooperate with authorities and investigations;
- Undertaking background checks; and
- If Australian privacy law is applicable to you, undertaking criminal record checks
We have offices in Sydney, Hong Kong, New York and Dubai and all of our staff use a single cloud based recruitment management platform. This means that your personal data may be accessed from or processed at a destination outside of Australia or the European Economic Area (“EEA”). Some of these countries may not have a similar standard of data protection laws to Australia or the EU (as applicable). We always require your personal data to be handled in accordance with at least EU data protection law standards (for EU residents) or Australian standards (for all other residents).
Automated decision-making or profiling is not carried out on your personal data. All of our processing involves an element of human intervention
Data Security and Storage
We will take reasonable steps to protect the personal data that we hold from misuse, loss or unauthorised access, misuse, alteration or disclosure. This includes appropriate technical and organisational security measures. Where a third party has access to or processes your data, they will be contractually obliged to protect and process it in a way that complies with this policy.
We remind you that the internet is an unsecured means of transfer and any personal data you transmit to you us by this method is at your own risk. Despite this, we will do our best to protect your personal data, including following our robust internal policies and procedures once we receive it.
Subject to the remainder of this policy, we will destroy any personal information that we hold that we no longer have any use for, other than information that we are required by law to preserve.
Right to request access to your personal information
You can request access to personal information that we hold about you. Such requests should be directed to our Privacy Officer and we will respond within a reasonable period after the request is made.
We may require you to complete a written application and verify your identity. If your request for information is complex you will need to specify the information that you wish to access in some detail.
A reasonable fee might be charged dependent on the nature of your request. Our Privacy Officer will be able to discuss this with you.
You should also anticipate that it may take some 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.
Under certain circumstances, we may refuse to provide you with access to your personal information, and will provide you with a written notice containing our reasons for the refusal, how you may complain about the refusal, and any other matters required by law.
Right to request correction of your personal data
You can request correction of the personal information that we hold about you. Such requests should be directed to our Privacy Officer and we will respond within a reasonable period after the request is made. You will not be charged a fee in relation to requests to correct your personal information.
We may require you to complete a written application and verify your identity.
If we correct your personal information, we will take reasonable steps to notify any third parties it has previously been disclosed to, unless it is impracticable or unlawful to do so.
Under certain circumstances, we may refuse to correct your personal information, and will provide you with a written notice containing our reasons for the refusal, how you may complain about the refusal, and any other matters required by law. You may request the association of a statement with it that it is inaccurate, out of date, incomplete, irrelevant or misleading. We will take reasonable steps to associate the statement in way that makes it apparent to users of the information.
Right to request deletion of your personal data
You may request deletion of your personal data and we will handle such requests in accordance with GDPR requirements. Any such requests should be directed to our Privacy Officer.
Right to request restriction on the processing of your personal data
You may request the imposition of restrictions on how your personal data is processed and we will handle such requests in accordance with GDPR requirements. Any such requests should be directed to our Privacy Officer.
You may request to receive the personal data we hold about you in a commonly used and machine-readable to allow a new controller to easily import your data. We will handle any such requests in accordance with GDPR requirements and you should direct them to our Privacy Officer.
Right to object
You may object to certain types of processing and we will consider in accordance with GDPR requirements. Any queries in relation to this should be directed to our Privacy Officer.
Right to withdrawal of consent
Under circumstances where we are processing your personal data for a specific purpose based on your consent, you have the right to withdraw your consent to that processing at any time. Such notifications should be directed to our Privacy Officer and will be handled in accordance with GDPR requirements.
Keeping your personal information up to date
If your personal information changes, please contact our Privacy Officer and we will update and correct the information that we hold, subject to the remainder of this policy. We may also contact you from time to time to check that the information you have provided is still correct, relevant, up-to-date, complete, and not misleading.
Third Party Websites
Links to third party websites are provided solely as a convenience to you. If you use these links you will leave our website. We are not responsible for any of these sites, their content or their usage of your personal information.
Changes to This Policy
We may make changes to this policy from time to time for any reason. We will publish those changes on our website at www.redpathpartners.com. Any questions or queries regarding this policy should be directed to our Privacy Officer.
Complaints – if Australian law is applicable to you
Any complaints about alleged breaches of the APPs should be directed to our Privacy Officer in writing. We will endeavour to acknowledge receipt of your complaint within 10 working days, and resolve all complaints within 30 working days. If due to the nature of your complaint it cannot be resolved during this timeframe, it will be resolved within a reasonable timeframe with periodic updates provided to you. We will notify you in writing of the outcome of our enquiries and investigations into your complaint. If you are dissatisfied with our response, you can contact the Office of the Australian Information Commissioner, for further details see https://www.oaic.gov.au/.
Complaints – if the GDPR is applicable to you
You may lodge a complaint with a supervisory authority if you believe we have processed your personal data in a way that infringes the GDPR. You are not obliged to, but encouraged by us, to contact our Privacy Officer in the first instance about such matters.