CGL Retail Services (ABN 98 004 882 928) and its related group of companies and associated bodies (us, we, our) maintain a policy of strict confidence concerning your (you, your) personal information (Privacy Policy).
This Privacy Policy has been developed in accordance with the Australian Privacy Act 1988 (Cth) (Privacy Act). This Policy sets out what information we gather, how we may use it, how we may disclose it and how you may correct or change it.
This Privacy Policy applies to information provided to us whether via the Smart Recruiters system and site, accessing CGL Retail Services sites and/or website from Australia or any other means.
1. Definitions
1.1. Personal information is defined in the Privacy Act as information recorded and kept about an individual that identifies or could be used to identify the individual and information kept with identifying information.
1.2. Sensitive information is a specific type of personal information and the law provides special rules of its collection and use. Sensitive information is defined in the Privacy Act as information concerning an individual’s race or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation preferences or practices, criminal record, or health information.
1.3. Health information includes personal information about the health or disability of an individual, the provision of health services to a person and information collected for the purposes of providing a health service to that person. It also includes certain genetic information.
2. Collecting personal information
2.1. We will generally collect personal information directly from you with your consent, unless it is unreasonable or impracticable to do so. We may also collect personal information from third parties such as your representatives or external data suppliers. When we collect personal information about you, we will notify you at the point of collection, or as soon as practicable, to ensure that you are aware of such collection and its purpose.
2.2. If someone other than you provides us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. However, this notice will not be provided if doing so would be a breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy the personal information.
2.3. We will only collect sensitive information if:
• you have given express consent to us to do so, and the information is reasonably necessary for us to carry out our functions or activities; or
• the use of information is:
• required or authorised under Australian law or a court or tribunal order.
• reasonably necessary for the establishment, exercise, or defence of a legal or equitable claim.
• necessary for lessening or preventing a serious threat to health or safety.
• necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
• necessary for a diplomatic or consular function or activity or certain Defence Force activities outside Australia; or
• reasonably necessary for the purposes of a confidential alternative dispute resolution process.
3. Smart Recruiters system and site
3.1. In regard to the collection of data via the Careers page of the site, as a customer of Smart Recruiters our privacy policy covers any candidates who use the Smart Recruiters system and/or site.
3.2. If you are a user of the Smart Recruiters system and/or site from Australia, your privacy rights include the following:
• Right to access personal information. Subject to certain exceptions, you have the right to access your personal information upon request. CGL Retail Services will respond to requests within a reasonable period after the request is made.
• Right to seek correction of personal information. You have the right to have your personal information corrected.
• Right to complain to the Commissioner. You have the right to submit a complaint to the Office of the Australian Information Commissioner about our handling of your personal information in violation of applicable law.
3.3. We acknowledge that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate personal information should direct their query to the CGL Retail Services (as the data controller) by sending an email to HR.Helpdesk@cglrs.com.au.
3.4. If requested to remove personal information we will respond within a reasonable timeframe and in compliance with all applicable laws.
3.5. If your request or concern is not satisfactorily resolved by us, you may approach the Office of the Australian Information Commissioner.
4. Cookies
4.1. We may collect non-personal information about the computer, mobile telephone, smartphone or other device that you use to access our products or services. Where you allow our mobile services and products to deliver content based on your location (by enabling this feature on your mobile device) we may collect location data. This information is used only for the automated delivery of relevant content to you and for no other purpose.
4.2. We may use a cookie file containing information that can identify the computer you are working from. The cookie file is anonymous as it only gives us details of your IP address, PC platform (Windows, Linux or OS X), Browser (e.g. Internet Explorer, Google Chrome, or other, plus the version of Browser) and domain (whether you are accessing the site from Australia, or elsewhere). We may use the information generated by “cookies” to:
• track traffic patterns to and from our sites such as the pages you visit, the time you spend on each page, the date and time of your visit, where your mouse hovers, and referring pages (pages you came from or go to);
• enable you to use certain services as a member without having to log on each time and to visit member-restricted areas of the site.
4.3. You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use our websites, but you may need them for customisable areas of sites we may develop in the future. If your cookies are turned off, we will not have any control over the frequency of display of certain ad formats. This could affect your reading experience. Visit https://www.allaboutcookies.org/manage-cookies/ for a comprehensive guide on how to control and delete cookies on a wide range of web browsers and operating systems.
5. Use and disclosure of information
5.1. Your personal information may be used by us in a number of ways, including to:
• provide the products and services offered on the site and in any other forum to you;
• enhance and improve your use of the site and our products and services;
• respond to any questions, comments or queries submitted on the site or by any other means;
• disperse marketing materials and keep you informed about new products, initiatives and opportunities;
• for internal business purposes, for example, to research and develop the site and our other products and services; and
• as required or authorised by law, including under the Australian Privacy Principles.
5.2. We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. In order to deliver the products and services, we may disclose your personal information to other organisations but only in relation to providing our services to you. This disclosure may include providing your personal information to our clients in order to provide the products and services as agreed upon by you and them. We take reasonable steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information.
6. 4. Direct marketing
6.1. We may use personal information about you for the primary purpose of providing you with our services. We may also use it for other purposes for which you might reasonably expect us to use that information. This includes sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication. We may also contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases your personal information is not transferred to the third party. You authorise us to use any email address or other contact information you provide to use at any time for such above purposes.
6.2. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.
7. Accuracy of your information
7.1. We are based in Australia, any personal information that you provide to us will be collected, held and processed by us in Australia . Under the Privacy Act you have rights of access to and correction of personal information that we hold. We offer the ability to correct or change the information collected at any time and as often as necessary. Please contact the Privacy Officer of Clemenger Group if you would like to make any changes.
8. Your consent
8.1. You have the right to withdraw consent at any time.
8.2. You may sign-up to receive emails from us on some of our websites. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you.
8.3. You may opt out of certain other communications that we provide by following the instructions for opting out in those communications.
8.4. For any other withdrawals of consent not addressed above, please contact the Privacy Officer of Clemenger Group.
9. Storage and Security
9.1. We will use all reasonable endeavours to keep your personal information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your personal information being accessed by unauthorised personnel, lost or misused.
9.2. If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us (see section 10.2 below).
NB: No data transmission over the Internet can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of any information you transmit on or through our sites and you do so at your own risk.
9.3. If we no longer need your personal information, unless we are required under law or a court or tribunal order to retain it, we will take reasonable steps to destroy or securely delete your personal information in accordance with our document retention policy.
10. Changes to Policy
10.1. We reserve the right to change this policy at any time by notifying site users of the existence of a revised privacy policy.
11. Privacy breach and access to information we hold about you
11.1. If you have any questions, or if you wish to receive more information on our information practices and Privacy Policy, please contact our Privacy Officer.
11.2. If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by writing to our Privacy Officer:
Fees may be charged for the provision of this information.
11.3. When contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way or if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.
11.4. If you believe your privacy has been breached please contact our Privacy Officer.
12. How to contact our Privacy Officer
12.1. Our Privacy Officer can be contacted as follows:
Australia: James Hookway, Privacy Officer, Clemenger Group Limited, Level 12, Tower 1, Collins Square, 727 Collins Street, Melbourne VIC 3008
Email: james.hookway@clemenger.com.au
13. Children’s privacy
13.1. Protecting the privacy of the young, i.e. children under the age of 13, is especially important. For that reason, we never collect or maintain information for our services from those we know are under 13, and no part of our services are structured to attract anyone under 13.
13.2. If a child has provided us with personal information, we ask that a parent or guardian of the child contact us at HR.Helpdesk@cglrs.com.au if they would like the information submitted by the child deleted from our database. We will use all reasonable efforts to delete such information from our database.
14. More Information
14.1. For information about Australia’s privacy legislation and how they protect the personal information of individuals, please refer to the following link:
The Privacy Act 1988
Office of the Australian Information Commissioner•
Website: www.oaic.gov.au