FaceCruit Privacy Policy

Privacy and Security Policy

Screen Recruiting Pty Ltd ACN 622 390 836 (trading as Facecruit) and its related entities (collectively, Facecruit, us, we, our) are committed to honouring the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy is intended to provide a general overview of how Facecruit will collect, use and manage “personal information”, meaning ‘information or an opinion (whether true or not) about an identified individual or an individual who is reasonably identifiable’, that is, information that allows someone to work out who you are and potentially to pretend to be you.

Facecruit views your privacy, and therefore the protection of your personal information, as an important issue and this Privacy Policy has therefore been implemented to stop your details falling into the wrong hands.

By using our website at www.Facecruit.com and/or the Facecruit Mobile Application (together and separately, the Platform) and/or providing your personal information to us, you consent to us handling your personal information in accordance with this Privacy Policy.

This Privacy Policy applies to all users of the Platform, whether or not you have registered an account with Facecruit, unless otherwise indicated.  Registered account holders are described in this Privacy Policy as ‘Members‘.

Facecruit will adhere to this Privacy Policy, although of course whatever the Privacy Policy says doesn’t change anything that the Privacy Act says we must do or not do.

Purposes of collection, holding, use and disclosure of Personal Information

If you are a Facecruit Member, we will collect, use, hold and disclose your details as far as we need to provide Facecruit’s online services to you, that is:

  • provide the Platform for you to the purposes of recruiting a candidate or seeking employment
  • create an account, or integrate, with related third party software and/or employment platforms
  • answer your questions, give you information and promote the services of Facecruit to you;
  • obtain your feedback on Facecruit, the service, and to improve Facecruit;
  • conducting direct marketing and other promotional activities; and
  • for our general business operations (like record keeping, legal compliance, stats, analysis and other stuff like that).

If you are not a Member of Facecruit, we will collect, hold, use and disclose your details as far as we need:

  • to answer your queries;
  • to provide you with information about Facecruit’s services;
  • to conduct related marketing and promotional activities; and
  • for our general business operations (like record keeping, legal compliance, stats, analysis and other stuff like that).

By providing us with your personal information, you consent to us collecting, holding, using and disclosing it for these purposes. You can opt-out of marketing and promotional communications at any time using an opt-out mechanism in one of our communications or by letting our Privacy Officer know on the details below.

If you don’t give us the information we ask for, Facecruit may not be able to do these things for you. Let us know if you don’t want to give us your details.

Collection of Personal Information

What details we need will vary, depending on why we are asking, but you can expect that Facecruit will need to know your name, address, and contact details (e.g. telephone number and email address).

Facecruit will certainly not collect any ’sensitive information’ about you. What we know about you depends on what you have told us, and what we have been told by others.

We will collect your personal information directly from you, unless it is impracticable or unreasonable to do so.  Other information sources may include surveys, online forms, emails and other communications from you, and in some cases from third parties (such as where Facecruit offers services in conjunction with other organisations) or public sources.

When Facecruit collects your details, we’ll try to make sure that you know why we need those details and the other notification information the APPs require, such as who we would usually pass that information on to and what you’ll miss out on if you don’t give us those details.

If you provide us with personal information about a third party, you represent that (and we collect it on the basis that) you have that person’s consent for us to collect and handle their personal information in accordance with this Privacy Policy.

Use and Disclosure of Personal Information

Generally, Facecruit will only use or disclose your details for the reasons set out above, and for other related things that you would expect us to.  Otherwise, Facecruit will only use your details or tell others if you have asked us to or the law tells us we can (or we must).

For example, if you give us your details (such as your name and email address) by sending an email to Facecruit or by submitting an online form, Facecruit will use this information to respond to your message (and for other related things that we know you would expect us to use them for). Otherwise, we won’t use or disclose your details without your consent.

Facecruit’s computers automatically collect information about you (for example, the IP address of your computer). While it may be possible to identify you from this information, we won’t; Facecruit will only use the information for stats and for system administration.

Facecruit uses cookies and the personal information stored in cookies may be used by Facecruit to track your use of the Facecruit Platform and to personalise the Platform for you.

Sometimes Facecruit will need to give your details to someone else so we can give you the full Facecruit experience, for example to one of our Platform Service Providers (PSP)

Facecruit will tell a PSP about you when you interact with or create an account with a PSP through the Platform but we haven’t assessed, have no control over and are not responsible for, the privacy policies of the PSPs, or the use and protection of your personal information by the PSPs, including on any website owned or controlled by a PSP for which a link is provided on Facecruit or in an email from Facecruit. From a privacy perspective, you contact and deal with a PSP at your own risk.

Other types of third parties that we may disclose your details to include our agents and contractors for the purposes set out above, and for the purposes of those parties providing services to us or performing business services or functions on our behalf (for example, our technology service providers, marketing service providers etc).

Our Platform uses Google Analytics, a service which transmits website traffic data to Google servers in the United States.  Google Analytics does not identify users or associate your IP address with any other data held by Google.  We use reports provided by Google Analytics to help us understand website traffic and webpage usage.  By using our Platform you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy at: https://www.google.com/policies/privacy/.  You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript or use the opt-out service provided by Google.

Additionally, we may use cloud-based services such as Facebook Business, HotJar and HubSpot CRM.  By using our Platform, you consent to the hosting and/or transmission of data about you to cloud based service providers based in Australia and overseas.

Facecruit will not otherwise send your details overseas unless you ask or the law says we can (or we must).

International Data Transfers

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

  • We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
  • Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

Access to, and Accuracy of, Personal Information

If you ask, Facecruit will provide you with access to whatever we know about you (unless the APPs say we don’t have to). Drop the Facecruit Privacy Officer a line (contact details below) if you want to do this. We may ask you to do this in writing. Requesting access is free, but Facecruit may charge a fee for giving access, for photocopying and for other admin.

Facecruit only wants details about you that are accurate, complete, up-to-date and not irrelevant or misleading. If you think we have dodgy information about you, contact the Facecruit Privacy Officer as set out below and we will amend our records accordingly (unless the APPs say we don’t have to). And of course let us know as soon as possible if any of your details change.

Storage and security of Personal Information

Facecruit stores your details securely and this Privacy Policy is designed to ensure that your details are not misplaced or misused. To keep your details safe, we use passwords, network and computer security, physical premises and document security and secure destruction and de-identifying of information once it is no longer required.

The Internet is not secure. The privacy, security and integrity of information being transmitted electronically, for example by email, cannot be guaranteed during its transmission. Once received, Facecruit will take reasonable steps to store that information so that unauthorised access, modification, disclosure, misuse, interference and loss are prevented.

We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT system back-up records.

Making a Complaint

You may lodge a complaint with us if you believe we have handled your personal information other than in accordance with the Privacy Act. To do so please contact our Privacy Officer via the contact details below. We will confirm receipt of your complaint and set out the time frame we require to investigate your complaint and provide you with a response. We will endeavor to respond as quickly as possible, which generally will be within 14 days of receiving your complaint.

Changes to this Privacy Policy

This Privacy Policy is current as at February 2018. Facecruit may review and update this Privacy Policy from time to time to reflect changes in the law, Facecruit’s business practices, procedures and structure, and the community’s changing privacy expectations. While it is not possible to notify you of changes to the Privacy Policy, the latest version of the Privacy Policy will be available on the Facecruit website at www.Facecruit.com.

Point of Contact

To request access to personal information held about you in Facecruit’s records, to make a privacy related complaint, to obtain more information about this Privacy Policy or to enquire about privacy matters generally, please contact the Facecruit Privacy Officer on 0428 985 145 or fill up the enquiry form or via post as follows:

Screen Recruiting Pty Ltd (Facecruit)
♦39 Rundle Street Kent Town♦
♦South Australia 5067♦