PRIVACY POLICY
INTRODUCTION
1. Kuras Leadership Search is an executive search firm that specialises in international or national leadership searches, leadership capability assessments, talent sourcing, research services and related recruitment activities.
2. We are committed to securely and responsibly managing the private information of our clients and candidates, our prospective clients and candidates, and the talented individuals we work with. We have developed this Privacy Policy to let you know how we go about handling personal information and how you can go about exercising the rights you have under law with respect to your personal information.
3. This Policy applies to us, our clients or prospective clients, candidates and potential candidates from whom we have collected personal information. It also applies to those persons who are a source of information in respect of a candidate, such as referees or employees. If you have given us personal information through registering through our website, through email or by any other means, you will be consenting and are subject to this Policy.
4. This Policy is prepared and made available in compliance with the Privacy Act 1998 (Cth). It is regularly reviewed to make sure it is up-to-date.
WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION TO DO OUR JOB RIGHT
B-1 WHY WE COLLECT YOUR PERSONAL INFORMATION
5. We provide executive search services to clients around Australia and overseas. We collect and process your personal information in order to provide executive search, recruitment, assessment, coaching and other services, for either current or future employment opportunities with our clients.
6. The main purpose for collecting, holding, using and disclosing personal information is to provide services to our clients; that is, based on our clients’ needs, we will collect and disclose your personal information to our client for the purpose of assessing your suitability for employment with that client (with your consent). We will disclose personal information to clients for recruitment and related purposes, so that they can consider whether or not to engage you.
7. We collect use and disclose personal information to process job applications pursuant to our engagement with our clients. When we do so, we may pass your details to the relevant client to proceed with the application. The client might then contact you directly. We collect personal information to search for candidates for certain confidential recruitment assignments: in these circumstances, we can disclose some of your details to the client. Depending on whether you might be suitable for the client’s purposes, we may contact you to discuss the opportunity and arrange next steps towards potential recruitment, including arranging interviews by a consultant; if you are shortlisted for a client interview, the client might contact you directly based on the details we have disclosed to them.
8. We also collect personal information to establish a pool of potential candidates for future positions. We can then assess that information to determine whether the potential candidate might be right for a position as the position arises. If we do that, then we may disclose your personal information to the client for their consideration.
9. We collect and use your information for the purposes of contacting you to discuss potential employment opportunities, whether or not you have applied for a specific role, or to provide you with information on the relevant market opportunity.
10. We may also collect use and disclose your personal information to conduct mapping or research exercises for our clients.
11. We may also use and disclose personal information for the purposes of our engagement, such as where we are required to assess or coach a person.
12. Rest assured that you are under no obligation to provide us with your personal information. If we do not collect personal information about you, then the consequences will likely be that your job application cannot be processed or that your potential suitability for employment cannot fully be determined.
B-2 THE PERSONAL INFORMATION WE HOLD AND COLLECT
13. The type of information we hold and collect is that which is relevant and necessary to perform our services. That information ordinary includes information like:
(1) Contact details (name, telephone numbers, email address, residential or postal address, website addresses, social media contact details);(2) Employment history and qualifications, including your resume/curriculum vitae, details of your work history, any academic publications or research projects, awards and professional memberships;
(3) Your employment preferences, including expressions of interest in particular fields of employment;
(4) Publicly available information or information available through social media platforms, such as LinkedIn;
(5) In the case of a professional reference, we will collect the referee’s name, employment details, knowledge of a particular candidate and opinion of the potential candidate and his or her capabilities (whether or not in written form);
(6) If you have engaged us to provide services, we collect the name, role and contact details of a key contact of the client.
14. Sometimes it might be necessary for us to collect “sensitive information” (as defined in the Privacy Act 1998 (Cth). We will seek your consent to process any “sensitive information”, which includes information or opinions about your racial or ethnic origin, political opinions, religious belief, union membership, health or sexual orientation or criminal record. If it is necessary, we will talk to you about it and ask you for your consent to collect, use and disclose it for specified and limited purposes. We encourage you not to provide us with sensitive information unless we specifically request it for limited purposes and we have your express consent to collect it.
B-3 WHERE WE COLLECT PERSONAL INFORMATION FROM
15. If you are a potential candidate for a role, we will usually collect personal information about you directly from you. That can occur when you register on our website, you upload your resume/CV and details to our website or database, you email us directly or when we speak or correspond with you directly.
16. We can also collect personal information from other sources, such as named contacts, referees or employees/employers. We will ordinarily only do so with your consent. Sometimes, we can collect personal information from publicly available sources.
17. If you are a client, we will collect personal information directly from your contact.
18. If you are a referee or other contact, we may obtain information from you directly or from a potential candidate.
19. We aim to provide the best candidates for each role and to do so, we need to make sure that the information we hold about potential candidates is up to date and accurate. While we take all reasonable steps to make sure that your personal information is accurate, up-to-date and complete, we rely wholly on you to keep us updated as to any changes in your contact details or circumstances.
20. Please make sure you provide us with any updated information.
B-4 TO WHOM DO WE DISCLOSE PERSONAL INFORMATION
21. We will only disclose it to third parties with your consent, or where we are required or authorised to disclose the information by law.
22. We usually disclose personal information that we collect to our clients; that is, employers or prospective employers, for the purposes of providing executive search services, leadership assessments or talent solutions and to manage any ongoing contracts relating to a person’s engagement.
23. We also disclose your personal information to prospective clients from time to time. We will seek to obtain your consent to have third parties contact you. We do so in accordance with this Privacy Policy and in accordance with applicable privacy laws.
24. Sometimes, those clients might be overseas. We would disclose personal information to overseas recipients only where the client, proposed client and role is located overseas. Before we do that, we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles (APP) (other than APP 1) set out in the Privacy Act 1988 (Cth), in relation to the information, such as by requiring them to keep the information confidential and secure and used only for the purposes for which it was disclosed.
25. It is not practicable to set out those countries here, because personal information may be disclosed internationally subject to their being a relevant client and role from time to time.
B-5 HOW WE MANAGE PERSONAL INFORMATION
26. We manage personal information by limiting access to your information to those within Kuras Leadership Search and only to those persons whose job requires access to personal information.
27. We have systems and processes in place to protect against loss of your personal information, and from unauthorised use or disclosure. Personal information is stored securely on our own databases and sometimes on servers hosted by third parties. While we take every reasonable step to manage the security of and access to personal information, sometimes the security of these databases and systems can be impacted beyond our control. We cannot be held responsible for any unauthorised access, use, disclosure or loss of personal information that is beyond our reasonable control.
28. We will generally use and disclose your personal information with your consent, but you may withdraw your consent for us to continue to use your personal information at any time.
29. We will retain the personal information collected as part of the executive search and related services we provide so that we may contact you again in the future to discuss any employment opportunities available with our clients. If you do not wish us to retain your personal information or contact you in the future, please send us a request to remove your details form our database.
WHAT YOU CAN DO ABOUT YOUR PERSONAL INFORMATION
30. You have certain rights under privacy laws. You may:
- access personal information about yourself which we hold;
- seek the correction of your personal information; and
- make a complaint if you think that we have not complied with applicable privacy principles (the APPs).
C-1 HOW YOU CAN REQUEST ACCESS TO YOUR PERSONAL INFORMATION
31. You may access your personal information in accordance with APP 12; that is, if we hold personal information about you, we must on request, give you access to that information unless APP 12 provides an exception to that right. One exception is where to give access to such personal information would reveal evaluative information generated within the entity (such as Kuras Leadership Search) in connection with a commercially sensitive decision-making process.
32. You may request access to your personal information by making a written request to the Managing Director at the address provided below.
33. Your written request must:
(1) Set out your name and contact details;
(2) be accompanied by proof of your identity to make sure you have the right to access that information;
(3) set out what information you want access to (if you request access to specific information or documents, please describe the information or documents with as much detail as you can); and
(4) specify the format in which you would like that information to be given to you.
34. If you do make that written request, we will endeavour to respond to that as soon as possible, but always within a reasonable period having regard to all the circumstances, including the information requested.
35. If we decide to grant access to your personal information, we will give access to the information in the manner requested by you where it is reasonable and practicable to do so.
C-2 HOW YOU CAN REQUEST CORRECTION TO YOUR PERSONAL INFORMATION
36. You can ask us to correct the personal information that we hold about you. You can do so if, for example, you think the personal information we hold is not accurate, not up-to-date, nor correct, or is incomplete, irrelevant or misleading.
37. If you wish to have your personal information corrected, please make a written request directed to the Managing Director. Your written request must:
(1) set out your name and contact details;
(2) describe what is the information that needs amendment and how it should be corrected;
(3) set out whether or not you want us to notify another third party of the corrected information; if you do, we will take reasonable steps to do so (for example, if we know who they are and we provided them with your information), unless it is impracticable or unlawful for us to do so.
38. We will respond to your request as soon as reasonably practicable after receiving it. It is free of charge to make your request or to correct it.
39. We will consider the request and make a decision: if we do not correct your information, we will send you a written notice that says why we did not do so, and what you can do next.
40. You can also request to remove your details from our database. You may withdraw prior consent and request to have your personal information erased from our database (usually this means your CV/resume or application), however this means we are unable to consider you for any of our services in the future. We also reserve the right to maintain your name and email address as to ensure we do not process your personal details in the future.
C-3 HOW YOU CAN MAKE A COMPLAINT ABOUT OUR HANDLING OF PERSONAL INFORMATION
41. You can make a complaint to us if you think that we have breached an APP in relation to your personal information. You can find out information about privacy and the APPs by visiting the Office of the Australian Information Commissioner’s website at www.oaic.gov.au/privacy/your-privacy-rights/
42. You may make a complaint in writing to the Managing Director, setting out your complaint and why you consider that we have breached an APP.
43. We will respond to your complaint as soon as reasonably practicable.
44. You may also make a complaint directly to the Office of the Australian Information Commissioner. Please visit https://www.oaic.gov.au/privacy/privacy-complaints/ for more information.
HOW YOU CAN CONTACT US
45. To contact us to request access to your personal information, to correct it or to make a complaint, please contact us at:
Kuras Leadership Search
Attention: Betty Kuras, Managing Director
Lev 27, 101 Collins Street
MELBOURNE VIC 3000
betty@kurasleadershipsearch.com
+ 61 3 9653 9599
DATED: 16 April 2020
VERSION: 1.0