Introduction
The protection of privacy is important to us at People Check Pty Ltd (wholly owned by HireRight AU Pty Ltd, together referred to as “PeopleCheck”).We treat all personal information as confidential and handle in accordance with the Australian Privacy Principles the Privacy Act 1988 (Cth), the Australian Crime Commission Act 2002 (Cth) and other data protection legislation, both global (eg the European Union General Data Protection Regulation – “GDPR”) and local (eg Singapore Personal Data Protection Act 2012), where relevant.
PeopleCheck provides reference, background checking and validation services and is engaged by its clients to validate the skills, qualifications, experience, background and identity of potential employees. We are under an obligation to keep personal information confidential and not to use it for any other purpose other than background screening and validation.
The reason for the background and reference checks being undertaken is to enable our client to assess an individual’s (“the candidate”) suitability for employment or appointment; this may be for new employment, a role change within an existing employer and/or for compliance purposes.
Why We Collect Personal Information
PeopleCheck collects personal information about you because:
- You have provided it to us, for instance:
- you are a candidate applying for a role with one of our clients;
- you are a client of our company;
- you have provided information to us about one of our candidates; and/or
- you contact us to make comments, complaints or to ask us questions;
- We need it to provide a product or service that you or one of our clients have requested from us for instance, you are applying for a new job and our client requires you to complete a background check;
- We need it to conduct a nationally coordinated criminal history check on request by one of our clients, an individual or for a role within PeopleCheck (as relevant);
- We would like to improve our services; for instance, through the collection and analysis of statistical and research data, in internal processes such as audits, quality control and IT system updates and use of cookies;
- You work for us, or apply to us for a job or work experience;
- You or your company provides services to us; and/or
- For purposes directly related to any of the above.
What Kinds of Personal Information do we Collect, Use, Disclose and Store?
PeopleCheck will only request, collect, use, disclose and store information that is needed in order for us to carry out our services and this may include personal and/or sensitive information, including your IP address. If you are a candidate undergoing background checking, the information collected about you may include:
| Type of Personal Data | Reason for Collecting |
| Name (and former names) | This is how we are able to identify you when performing the Services. We ask for your name as it appears on your government issued ID and also any names that you may also be known as, or have been formerly known by. This is important particularly where you may be known professionally by a name other than that shown on your government ID document. |
| Date of Birth | Collecting this information increases the accuracy of results provided by sources. |
| Contact Details | This is to ensure that PeopleCheck can keep in touch with you during the provision of the Services. PeopleCheck do not use your contact details for any other purpose and these details are deleted from the Services Platform in accordance with retention polices set by our Client. |
| Address History | Your prospective employer/employer will ask PeopleCheck to perform verifications over a certain period of time (the “Search Depth”). Therefore PeopleCheck needs your address history covering the search depth to identify in which locations certain searches are to be conducted. Collecting address history also increases the accuracy of results returned from sources. |
| Employment History | Your prospective employer/employer requires that this information be verified in accordance with the Search Depth. |
| Education History | Your prospective employer/employer requires that this information be verified and in most cases requires the highest level of education achieved. |
| Referees | To support the verification of your employment history you may be asked to provide the contact details of a referee. You must always ensure that you have the referee’s consent to do so. These contact details are not shared with any third party. |
| ID Number | This may be required by sources from which information is obtained as the records kept by that source are associated with a government ID Number. |
| Gender | Some sources require that this information is provided in order to return results. Please note that our system provides options where the preference is not to specify. |
| Position applied for and prospective employer | For some checks, including a nationally coordinated criminal history check in Australia, it is a requirement of the source to collect the position you are applying for and the name of your prospective employer. |
| Type of employment “purpose field data” | For some checks, including a nationally coordinated criminal history check in Australia, it is a requirement of the source that they understand the type of role that you are applying for e.g. contact with vulnerable persons or work in the financial sector in order to provide appropriately filtered results in accordance with relevant legislation. |
| Supporting Documents | You may be asked to provide supporting documents during the course of the Services. These supporting documents may include a number of items and will be dependent on the type of Services requested by PeopleCheck’s Client. By way of example you may be asked to upload (where lawful to do so) a copy of your government issued ID; certificates showing professional qualifications; documents that verify any gaps in your employment history; and biometric data which can include photographs included on any government issued ID. |
We will never knowingly send you unsolicited commercial electronic messages. Our email newsletters and updates comply with the Spam Act 2003 (Cth) for express and implied consent.
You may elect to no longer receive our newsletters at any time by clicking the unsubscribe link at the bottom of the email or replying to the newsletter with a request to unsubscribe. If you subscribe to our email newsletter we will not sell, rent, share or disclose your details to any third party without your consent.
Personal Information
Personal information is any information or an opinion (whether true or not) about a person. It may range from the very sensitive (e.g. criminal history) to the everyday (e.g. address and telephone number). If you are a candidate, the type of information provided in connection with your background checking will depend on the background checks that are being undertaken on behalf of your employer
When PeopleCheck validates a candidate’s background, it may receive additional information relevant to the employment application which verifies or adds to the information already held regarding the candidate. Personal information would include the opinions of others about a candidate’s work performance (whether true or not), work experience and qualifications and other information obtained by PeopleCheck in connection with a candidate’s background.
Should PeopleCheck receive unsolicited personal information that could not have been collected by PeopleCheck under the Australian Privacy Principles detailed in the Privacy Act 1988 (Cth) and it is not relevant to our background checking, PeopleCheck will destroy this information.
Sensitive Information
Sensitive information is a special category of personal information. Sensitive information can, in most cases, only be disclosed with an individual’s specific consent. It is information or opinion about an individual’s:
- Racial or ethnic origin;
- Political opinion;
- Membership of a political association or religious beliefs, affiliations or philosophical beliefs;
- Membership of a professional or trade association or membership of a trade union;
- Sexual preferences or practices;
- Criminal record; and
- Health or disability (at any time).
PeopleCheck does not collect sensitive information other than criminal record information or health information associated with a pre-employment medical assessment and/or alcohol & drug screening requested by our client as part of a background check.
Our Background and Reference Checking Service
Depending on the background checks required, PeopleCheck may validate and/or collect the one or all of the following types of information regarding a candidate:
- Employment history (such as HR or Payroll) and references (such as former managers or nominated referees);
- Education, professional qualifications and memberships;
- Identity (including obtaining/confirming national identity numbers);
- Work rights;
- Driving history;
- Any police/criminal history information recorded about them;
- Medical history (including drug and alcohol); and
- Claims, judgements, bankruptcies, current and previous directorships and other public records.
Our criminal records check via the Australian Criminal Intelligence Commission (the National Police Checking Service (NPCS))
To learn more about this service please click on this link [FAQ] which covers:
- Process
- ID checks required to support the criminal check
- Timing of checks
- Information on further investigation/enquiries
- An overview of the Australian Criminal Intelligence Commission
- How long the check lasts for
- Whether the check can be used for other jobs
- Different types of checks and the spent convictions scheme
- Disclosable and non-disclosable results
- Who sees the criminal check results
- How long criminal checks are retained for
- Disputes process
and other relevant information.
When conducting this check you will also be asked to complete and sign a standalone Application and Informed Consent Form which contains a separate privacy notice and guidance notes which you must read. These notes cover both requirements under the Australian Privacy Principles and the Australian Criminal Intelligence Commission.
Data gathered for the purposes of the Service will be retained for no less than 12 months, but no greater than 15 months, following collection. Results of Nationally Coordinated Criminal History Checks will be disposed of within 12 months of receipt.
PeopleCheck is an accredited body and its relationship with the Australian Criminal Intelligence Commission is determined and governed by the Agreement for Controlled Access by Duly Accredited Bodies to Nationally Coordinated Criminal History Checks, including Annexure B to that Agreement which PeopleCheck must adhere to regarding information security controls.
If you should wish to contact the National Police Checking Service you may do so by emailing npcs@acic.gov.au or calling on 02 6268 7900.
Disclosure of Personal Information to Third Parties
PeopleCheck does not share or sell personal information for promotional purposes. We confirm that the collection, use and disclosure of personal information is solely for the purpose of carrying out our background checking services.
Specifically, PeopleCheck may disclose your personal information to third parties for the following purposes:
- To provide the service we have been engaged to undertake (e.g. Background and Reference checking);
- For research purposes relating to the performance, quality, maintenance and improvement of PeopleCheck’s services and products;
- To inform you of information which may be of interest to you;
- To provide technical support to you to use PeopleCheck’s services;
- If permitted or required by law; or
- Otherwise, with your express consent.
Where your consent is requested it is important that you fully understand the implications of providing such consent. Your consent must be freely given and you are able to refuse or withdraw your consent at any time. In some circumstances, there may be implications for refusing consent. If at any time you wish to withdraw your consent in part or full, you should contact us immediately and, if possible, in writing to ensure your request is actioned promptly.
PeopleCheck is assisted by a variety of third parties to deliver the services offered by us and operate our business on a day-to-day basis. To the extent necessary to perform its research and verification, PeopleCheck may provide some of your personal information to third parties as part of the background checking process. These third parties are organisations, institutions, agencies or individuals from which information is collected for the purposes of fulfilling the services only and may include local vendors, employers, educational establishments, referees, government agencies, courts, data providers or repositories or PeopleCheck’s representatives (“Representatives”) who are performing specific research in connection with your background checking (together “Third Parties”).
PeopleCheck may transfer your Personal Data to such third parties, if required to complete the verification and that such third parties will provide responses, including personal information, requested of them.
Third parties will vary on a case-by-case basis and may include:
- Identity verification providers such as the Document Verification Service or GBG;
- Technology service providers;
- Data storage partners;
- Website host such as Go Daddy;
- Software development firms such as Accio Data, located in Dripping Springs, Texas, United States of America;
- Government departments (direct and through brokers) such as ASIC, AFSA, The Australian Criminal Intelligence Commission (ACIC) etc; and
- Medical assessment service providers.
Wherever possible, PeopleCheck engages Australian third parties that are subject to the same Australian Privacy Principles detailed in the Privacy Act 1988 (Cth) as PeopleCheck and/or impose equivalent contractual restrictions.
In some cases, such as when undertaking validations (with a former employer, educational institutes, government departments, for example), PeopleCheck’s ability to impose adherence to Australian Privacy Principles is limited. In those circumstances, PeopleCheck will carefully consider the risks to the protection of personal information when releasing information. We use all reasonable means to verify the accuracy and completeness of information, statements and opinions made available to us during our enquiries.
Some organisations we contact may have their own processes for releasing information; these are mandatory and often in line with data protection legislation outside of Australia. As a result, some organisations may request you provide very specific consent and/or may only release information directly to you, which in turn you can provide to your employer or PeopleCheck to finalise your background checking. This can be the case even when you freely sign PeopleCheck’s Consent Form to act on your behalf. Additional consent may be requested in the form of another consent form, telephone call, through an online platform or other methods. PeopleCheck understand that these additional requirements can be frustrating, but they are in place to protect your privacy and it is important that we follow them.
Cross-Border Disclosure of Personal Information
Personal information collected as a part of our background and reference checking service is collected via PeopleCheck’s online platform, PRIVI. PRIVI, or PeopleCheck Research, Investigation and Validation Interface is hosted by Accio Data, a United States of America-based software development firm located in Dripping Springs, Texas. You need to be aware that your information will be stored in the USA on PRIVI.
Additionally, PeopleCheck may utilise our global network of our parent company, HireRight, in undertaking verifications and/or public record checks as part of the background checking process (eg checks in international locations). The HireRight Global (HRG) system that would securely store and process personal information in this instance is located on a server in the United Kingdom.
Undertaking background checks may involve Representatives located in Australia and in various locations around the world, such as the Philippines and India. The Representatives are tasked with processing verifications, references and databases searches based on where a candidate has lived previously and to provide support in local geographies and languages by contacting employers, schools and governmental agencies globally during the course of completing a background check. Representatives work from the HireRight Global Portal with access from a Virtual Desktop Infrastructure which sits on the HireRight UK server network. Representatives are prohibited from copying personal information by any means. This means that all personal information will remain within the technical environment of the online system where the personal information is collected and stored.
In addition to storing your information on PRIVI (and possibly HRG), in some cases, it may also be necessary to collect and release your information outside of Australia and we will require your express consent to do this. In most cases, this will generally be because you have resided overseas and background and reference checking is required to be undertaken in this particular region. Sometimes, our client may be based overseas and your information will be provided to them. You have the option to nominate the countries we may disclose your information to or you can elect to withhold your consent to such disclosure. If you have any questions as to whether your information will be disclosed overseas, please contact us so we may discuss your specific circumstances.
If you or our client have resided, or currently reside in the state of California, United States of America, or the EU Union, some specific requirements may apply to the transfer of your information. If you have any restrictions or conditions regarding the release of your information, be sure to advise us as soon as possible.
How Do We Collect and Store Personal Information?
PeopleCheck collects personal information through a variety of means, such as (but not limited to), in person at PeopleCheck’s offices, verbally over the phone, in writing via email or fax, or through online sources, including PRIVI (PeopleCheck’s client and candidate management system) and HireRight Global (HRG), in instances where we utilise our global network of our parent company, HireRight in undertaking verifications and/or public record checks as part of your background checking.
PeopleCheck will take all reasonable and practicable steps to ensure that your personal information is properly protected from misuse or loss and unauthorised access, modification or disclosure. Data is transferred from PRIVI and HRG securely using encryption and stored on secure servers. Additionally, further information security measures are in place, including access controls, physical security and robust information collection, storage and processing practices. We ensure that where electronic transfer of personal information to/from its representatives takes place that such transfers are also appropriately protected and are in compliance with relevant data protection legislation, including the Australian Privacy Act and the GDPR and in accordance with any instructions provided by a data source.
We encourage you to be vigilant about the protection of your own personal information when providing your information to PeopleCheck and choose the delivery avenue that best meets your own data disclosure expectations.
We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse, interference or alteration during its collection, use, disclosure and storage. We limit access to personal information to individuals with a business need consistent with the reason the information was provided. PeopleCheck has internal policies surrounding the management of personal information and is committed to training its people to ensure compliance with these policies. We keep personal information only for as long as it is required for business purposes or as required by law.
It is necessary for us to store your information and this may be done through a variety of means, such as (but not limited to): electronically on PeopleCheck’s web-based document management and storage system, PRIVI (hosted in the USA), HRG (hosted in the UK); and backups; and hard copies onsite at PeopleCheck offices.
Should we utilise our global network of our parent company, HireRight in undertaking verifications and/or public record checks as part of your background checking, your personal information will be stored on HRG for a maximum period of 6 months after completion of the background checks and will then be securely deleted.
How You Can Access, Correct and Remove your Personal Information
Subject to some exceptions which are set out in the Australian Privacy Principles (Principle 12 – Access to, and correction of, personal information), you have a right to see and obtain a copy of personal and sensitive information about you held by PeopleCheck. We will require you to put your request in writing and we will respond to such a request within a reasonable period after the request is made. We will provide access to the information in the manner you request it, providing it is reasonable and practicable to do so. If it is not possible to provide you with access in the manner you request, we will take steps to give you access in a way that meets the needs of both parties.
If we have undertaken a Nationally Coordinated Criminal History Check through the Australian Criminal Intelligence Commission (the National Police Checking Service (NPCS)) or the Australian Federal Police and you do not agree with the results, you can contact us to dispute the result. PeopleCheck accepts and escalates all disputes. Please see our FAQs for further information.
We will take reasonable steps to correct personal information collected about you where: PeopleCheck is satisfied that, having regard to its purpose is inaccurate, out of date, incomplete, irrelevant or misleading; or you request we correct information. If PeopleCheck is unable to agree that personal or sensitive information held about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will advise you in writing of the reasons for the refusal. You may request that a statement is included with the information that claims that particular information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you wish to exercise your rights of access and correction, or would like to complain about a refusal, you should contact our Privacy Officer using the contact details below. Personal information will only be released to individuals directly, unless we are provided with a written, signed authority to provide it to a third party.
In some cases, PeopleCheck may impose a moderate charge for providing access to personal or sensitive information; however, PeopleCheck will not impose a charge where it is not permissible under relevant legislation or simply because you lodge a request for access.
Unless there is an exception, you may have the right to request we destroy your data or have it de-identified. This may apply where the information is no longer necessary for the purpose for which it was collected, or where you withdraw your consent and there is no other legal reason for processing your data. If you would like to exercise your rights in this respect, please contact us.
How Suspected Privacy Breaches are Handled
PeopleCheck handles all suspected Data Breaches in accordance with the Privacy Act 1988 (Cth). If you suspect your information has been breached, please contact us via the details below and we will investigate this for you.
Alternatively, if you wish to complain about a breach of the Australian Privacy Principles, or a registered APP code (if any) that binds PeopleCheck, you can contact us via the details below. We will request that you put your complaint in writing. Your complaint will be assigned to a data privacy officer for investigation. They may contact you for additional information or to discuss your complaint with you. We will respond to your request within a reasonable period after the request is made and, where appropriate, ensure that a response is issued in writing for your records.
You can also make a complaint to the Office of the Australian Information Commissioner (OAIC) on 1300 363 992 or via other means available on their website: www.oaic.gov.au. Before making a complaint with the OAIC, you should make your complaint with us first.
Our Websites Use Google AdWords and Cookies
Our websites, including www.peoplecheck.com.au, use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the PeopleCheck website. Any data collected will be used in accordance with our own Privacy Policy and Google’s Privacy Policy.
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
You can opt-out of remarketing by visiting this link: https://support.google.com/ads/answer/2662922?hl=en
PeopleCheck’s website may use the standard technology called a “cookie” to collect information about how you use the web site.
A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer’s IP address (i.e., the Internet address of your computer) and domain type (e.g., .com.au or .org.au, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our website with a PeopleCheck account login and password. In addition, PeopleCheck’s web site does not allow other parties to collect personally identifiable information about an individual’s online activities over time and across different Websites when an individual uses the PeopleCheck website.
If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so.
Contact Us
If you wish to contact us about your personal or sensitive information, make a complaint or you wish to dispute a Nationally Coordinated Criminal History Check through the Australian Criminal Intelligence Commission or a National Police Check undertaken through the Australian Federal Police you should contact our Privacy Officer in writing.
| Privacy Officer
People Check Pty Ltd PO Box 40 Boolaroo, NSW 2284 |
T: 02 4023 0603 F: 02 4957 7441
|