Privacy Policy

1. Introduction

Be Recruitment Group (“Be”) is committed to protecting the privacy of all individuals and organisations with whom we interact. We manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, hold, use, and disclose personal information in our capacity as an employment agency and on-hire labour firm.

2. APP Entity

Be Recruitment Group operates as an APP Entity under the Australian Privacy Principles (APPs). In some cases, where Be is contracted by a Commonwealth or State Government agency, we may collect and manage personal information under additional or alternative privacy frameworks. If this applies to you, please contact us for clarification.

3. Information Flow

When collecting your personal or organisational information, we:

• Confirm that it is necessary for our business functions or employment operations.
• Ensure it is current, accurate, and complete by cross-checking with third parties as needed.
• Record and store it in our secure systems: JobAdder, Ento/Entire, WorkPro, Referoo, and Astute.
• Retrieve and use it for specific purposes aligned with our service delivery.
• Permit access in accordance with APP 12 and correct records per APP 13.
• Destroy or de-identify personal information when no longer lawfully required.
  
  

4. Information We Collect and Hold

The personal information we collect is directly related to:

Contact details and identification information

• Employment history and qualifications
• Compliance and probity documentation
• Reference information
• Audio and/or video recordings of communications (where applicable)

For:

• Workseekers
• Clients
• Referees

4.1 Workseekers

We collect information to assess suitability for placements and manage employment, including:

• Resume and employment history
• Work preferences (type, salary, location)
• References and background checks
• Proof of identity, right to work, licences, qualifications
• Probity documents (e.g., police checks, WWCC)

4.2 Clients

We collect business information necessary to manage service delivery, including:

• Contact and organisational details
• Role briefs, team structures, and reporting lines
• Cultural fit information and feedback preferences
• Business and social milestones relevant to account management

4.3 Referees

We collect referee information to determine candidate suitability:

• Full name and relationship to the candidate
• Context and content of reference
• Contact details for verification
• Confirmation of authority to provide a reference

5. Purposes for Collecting, Holding, and Using Personal Information

• Recruitment, placement, and workforce management
• Compliance and verification activities
• Service delivery and account management
• Training, quality assurance, and service improvement

5.1 For Workseekers

• Recruitment, placement, and performance management
• Verification and compliance
• Reporting and statistical requirements

5.2 For Clients

• Service delivery, account management
• Recruitment project management
• Business development and marketing (with consent)
• Compliance and reporting obligations

5.3 For Referees

• Verification of candidate credentials
• Assessment of suitability for placement
• Record-keeping related to recruitment decisions

6. Call Recording and Monitoring

Be Recruitment may record telephone and video communications for the purposes of:

• Quality assurance and service improvement
• Staff training and development
• Compliance, dispute resolution, and record keeping

Where call recording occurs:

• Individuals will be notified at the beginning of the call or prior to recording
• Participation in the call will be taken as consent to the recording where notification has been provided

Recordings may contain personal information and will be:

• Stored securely within approved systems
• Accessed only by authorised personnel
• Retained only for as long as reasonably necessary for the stated purposes

Where recordings are accessed by offshore teams (including in the Philippines, Sri Lanka, South Africa or other disclosed locations), this will occur in accordance with our overseas disclosure provisions and appropriate safeguards will be in place.

7. Direct Marketing

We may use your information to provide updates, newsletters, or marketing about our services or those of partners. You can opt out at any time by contacting us or using the unsubscribe feature in emails.

8. Collection Methods

• Phone calls (including recorded calls where applicable)
• Video conferencing platforms
• Online platforms and applications
• Interviews and onboarding processes

8.1 For Workseekers

Information is collected via:

• Registration forms and application platforms
• Interviews and screening processes
• Public platforms (LinkedIn, Seek)
• Digital onboarding (e.g., WorkPro, Referoo, Entire)

Photos, video data or scanned IDs may be requested only if required for probity checks or onboarding compliance.

8.2 For Clients

Information is collected:

• Directly through service interactions
• From publicly available sources (e.g., websites, directories)

8.3 For Referees

Information is collected:

• Through reference-checking processes
• Publicly available sources (e.g., social media, company websites)

9. Electronic Transactions

We collect data via web-based forms, email, mobile apps, or third-party integrations. Be Recruitment uses secure cloud-based platforms but acknowledges inherent internet risks. If you prefer not to communicate online, contact us by phone or post.

10. Information Storage and Security

All personal data is stored securely within our systems (JobAdder, Ento, Entire, Astute, WorkPro, Referoo).

We apply:

• Password protection
• Access restrictions
• Secure disposal and data culling procedures
• Staff training on privacy and IT security

11. Data Breach Notifications

In the event of a data breach, Be will respond in line with the OAIC’s Notifiable Data Breaches scheme, including:

• Containing the breach
• Assessing associated risks
• Notifying affected individuals (if required)
• Preventing future recurrence

12. Disclosures

We may disclose your information:

• To clients and referees for placement purposes
• To service providers (IT, legal, payroll, insurance, screening agencies, including technology platforms that may host call recordings)
• Internally to authorised Be staff
• Where required by law

We take reasonable steps to ensure our service providers uphold privacy protections equivalent to our own.

13. Overseas Disclosures

We may disclose personal information to overseas recipients in countries where our systems or providers are hosted or where recruitment or rostering support services are provided. These countries include:

In these cases, we will seek consent where required and take steps to mitigate privacy risks. We cannot guarantee overseas recipients will uphold Australian privacy standards, and individuals are advised of this risk where relevant.

14. Access and Correction

You may request access to or correction of your personal information by contacting our Privacy Coordinator at:
[email protected]

In line with APP 12 and APP 13:

• Access may be limited to protect the privacy of others or to respect third-party confidentiality (e.g., reference materials)
• We may charge a reasonable fee for access based on time and resources used

15. Complaints

If you have concerns about how your personal information has been handled:

• Contact our Privacy Coordinator in writing
• We will acknowledge your complaint and respond within 30 days
• If unresolved, you may escalate to:
  • The Office of the Australian Information Commissioner (OAIC)
  • RCSA (our professional association)

16. Related Policies and Documents

• Be Executive Data Breach Response Plan
• Social Media Policy
• IT Security Policy

Version 5 – Updated to include call recording and monitoring practices, expanded data collection categories, and alignment with operational changes and Australian Privacy Principles.