Workforce Analytics Pty Ltd ACN 629 952 432 and its related entities (collectively referred to as “Workforce Analytics”, “we”, “us” or “our”) recognise the importance of data privacy and are committed to the protection of Personal Information in accordance with the Privacy Act 1988 (Cth) as updated or amended from time to time (“Privacy Act”) and the Australian Privacy Principles set out in the Privacy Act.
“Personal Information” is defined in section 6 of the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.
We only collect Personal Information that is necessary to provide our products and services and to perform our functions and activities.
The categories of Personal Information which Workforce Analytics may collect and hold will depend on the type of products or services that we provide. We may collect the following types of Personal Information:
We may collect Personal Information in a number of ways, including:
If a customer, user or individual chooses not to provide any requested Personal Information to Workforce Analytics, we may not be able to undertake certain activities such as providing the relevant customer, user or individual with requested information, products or services.
Workforce Analytics will not collect any Personal Information from you when you use our Website except when you knowingly provide it or as otherwise described below. For example, Workforce Analytics may collect Personal Information from you when you:
When you visit and browse our Website, our Website host may collect information (which may or may not include Personal Information) for statistical, reporting and maintenance purposes. The information collected by our Website host will not be used to identify any individual. The information may include:
Our Website host uses this information to administer and improve the performance of our Website.
When you use our Website, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory.
For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
Web beacons are images that originate from a third-party site to track visitor activities. Workforce Analytics may use web beacons to collect aggregate data and provide this information to our Website host to administer and improve the performance of our Website, or to our customers if they request this type of data.
Sensitive information is a specific type of personal information that includes health information and information about an individual’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.
The privacy principles under the Privacy Act impose greater obligations on us regarding any collection, use or disclosure we make of sensitive information. We will only collect sensitive information where it is reasonably necessary for or directly relates to our functions or activities and if:
Workforce Analytics uses the Personal Information it collects to provide services and for our business functions and activities, including for the following purposes (each a “Primary Purpose”):
Workforce Analytics may use Personal Information for a secondary purpose (“Secondary Purpose”) if that secondary purpose is related to any the Primary Purposes listed in the previous paragraph, and it would reasonably be expected for us to use it for that secondary purpose, or if we have the consent of the individual to whom the Personal Information relates or if otherwise provided for under the Privacy Act.
Workforce Analytics may use Personal Information to provide direct, targeted, or other marketing materials to you or our customers on an ongoing basis. Subject to and in accordance with applicable law, Workforce Analytics may provide these materials by telephone, electronic messages (e.g. email), our digital services and other means. Workforce Analytics will only provide direct marketing materials where it would reasonably be expected for us to so, or if we have the consent from the recipient to receive direct marketing materials. We will seek consent to provide direct marketing materials if we have obtained the relevant Personal Information from a third party. Direct marketing communications may include promotional material about Workforce Analytics or may relate to the products and services Workforce Analytics, and our related entities provide and other products and services which may be of interest to the recipient.
Recipients may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “Contact us” section below.
Depending on the nature of the engagement with Workforce Analytics, we may disclose the Personal Information we have collected to our shareholders, officers, employees, contractors, consultants, advisers, agents of Workforce Analytics, third parties that provide products and services to or through Workforce Analytics or our Website or Workforce Analytics Systems, directly to the individual to whom the Personal Information relates (at their request), suppliers and other third parties, or otherwise as required by law. Please also refer to the “Employee records” section below in relation to disclosure of Customer Employee Information that may be provided to us by our customers.
Workforce Analytics may also disclose Personal Information to third parties who may support the operation of our products or services (e.g. our Website host or operators of the servers on which any Workforce Analytics Systems are hosted) in certain limited circumstances, for example when any Workforce Analytics System experiences a technical problem or to ensure that it operates in an effective and secure manner.
We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.
We may disclose your Personal Information outside of Australia to our Website host, any other host of a Workforce Analytics System, cloud providers and other third party suppliers located in the United States of America.
We will only consciously transfer Personal Information overseas if:
By consenting to provide us with Personal Information (whether by using the Workforce Analytics Systems, through a Privacy Statement or otherwise), the individual who provides the consent is consenting to the disclosure of your Personal Information to third parties who reside outside Australia.
An employee record is a record of Personal Information relating to the employment of the employee. Examples include health information about the employee and information about the employee’s hours of employment, salary or wages and the employee’s terms and conditions of employment. The Customer Employee Information that our customers may provide to us when they use the Workforce Analytics Systems will be employee records.
An employer’s handling of employee records are generally exempt from the Australian Privacy Principles if the employer’s handling of those records is directly related to:
The exemption does not apply to acts or practices of an employer that are outside the scope of the employment relationship.
Individuals have a right to access their Personal Information. If you would like to access any Personal Information that you believe Workforce Analytics is holding, using or processing about you, please direct your request to Workforce Analytics by email or post using the contact details set out in the “Contact us” section below.
Sometimes, we may not be able to provide you with access to all of your Personal Information or we may first need to check with a customer before providing you with that access. This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals. If we refuse you access, we will tell you why.
We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself). We may need to verify your identity as part of this process.
We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request that your Personal Information be corrected. If you think that Personal Information we hold about you is not accurate, complete and up-to-date, please contact us using the contact details set out in the “Contact us” section below and we will take all reasonable steps to correct the information.
We understand the importance of protecting your Personal Information. We take all reasonable precautions to protect the Personal Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Workforce Analytics aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on any Workforce Analytics Systems.
If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).
If you have any questions or would like further information about our privacy policies or practices, please contact us by any one of the following means:
If you wish to report a data breach or make a complaint about the way we have collected, used, held or disclosed any Personal Information, please contact us using the contact details listed in the “Contact us” section above.
To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
We will use the information you provide to investigate and respond to your data breach report or privacy complaint. We aim to resolve all complaints as quickly as possible. Some complaints are resolved within weeks, but more complex complaints may take longer. You may withdraw your complaint at any time.
If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.