October 2018
Table of Contents
- Overview of this policy
- Who are we?
- What kinds of personal information do we collect and hold?
- How do we collect and hold personal information?
- Why do we collect, hold, use and disclose personal information?
- How do we use information collected and held about you?
- How do we use information we receive from other sources?
- How can we disclose your information to others?
- Where do we store your personal data?
- How can you enquire about, access and correct your personal information?
- How can you complain about our management of personal information?
- How do we share your personal information overseas?
- How will we update this policy?
- How to get more information?
Overview of this policy
This policy explains how we manage your personal information when you use one of our psychometric testing platforms (called “platforms” from now on), specifically:
- the kinds of personal information we collect and hold;
- how we collect and hold it;
- the purposes for which we collect, hold, use and disclose it;
- your right to access and seek correction of it;
- how you may complain about privacy matters; and
- our sharing of your personal information overseas.
By using our platforms, you give your consent to the processing of your personal data for the purposes set out below.
For the purposes of the Data Protection Act 1998 (Act) or, from 25 May 2018, the General Data Protection Regulation (GDPR), the data controller is: People Excellence Pty Ltd.
To withdraw your consent to our processing your personal data please contact our Privacy Officer, at: admin@peopleexcellence.com.au. Please also note that the withdrawal of consent shall not affect the lawfulness of processing your personal data based on consent before its withdrawal.
Please note that this Privacy Policy should be read in conjunction with our End User License Agreement, which you would have agreed to, before using our platforms.
Who are we?
In this policy, ‘we’ and ‘People Excellence’ are People Excellence Pty Ltd ABN 646 167 940 15.
What kinds of personal information do we collect and hold?
The personal information we collect and hold is what we consider reasonably necessary for our business functions and activities.
When we collect and hold personal information, it is generally of the kind we ask for to provide our services and what arises from those services, and includes your first name, surname and email address. We may also ask several optional demographic questions that are used to assist us with anonymous internal research and development purposes. That information can include gender, ethnicity, primary language, highest level of education attained, current job and age group.
It will also extend to other personal information you make available to us and to our assessments of your attitudes, traits, abilities, behaviours, preferences and likely actions. We may also collect information including your IP address, web browser, operating system and device type for assessment integrity purposes.
Given our assessments are a personalised product, it is not possible to complete them without identifying yourself. This is also essential to ensure fairness and equity across candidates and valid assessments results being produced.
How do we collect and hold personal information?
Collection of personal information: When we collect personal information about you, we do so by making a record of it. We do this when:
- You communicate with us online, for example when you engage with us for the purpose of us making assessments of you;
- You deal with us in other ways involving a need for personal information to be provided such as when you contact us.
Why do we collect, hold, use and disclose personal information?
When we collect, hold and use your personal information, we do so solely to provide assessments and present those assessment results to our business partners, resellers, subcontractors or clients. Each business partner, reseller, subcontractor or client is responsible for their own data collection and storage process.
We may de-identify your personal information. We may do this for use and disclosure of the anonymous data for various data analytics purposes.
How do we use information collected and held about you?
- Processing and reporting on an assessment completed by you, including disclosing the results of such assessment to a potential third party employer from whom you are utilising our services;
- Providing your information to our business partners, resellers, subcontractors or clients for the above purpose.
- To carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
How do we use information we receive from other sources?
We combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
How can we disclose your information to others?
You agree that we have the right to share your personal information with our business partners, clients and sub-contractors for the performance of any contract we enter with them or you, this includes any businesses that engage us to undertake an assessment of you using our services (for example a potential or current employer of you).
We will disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
- If People Excellence or substantially all its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our end user agreement; or to protect the rights, property, or safety of People Excellence, our customers, or others.
Where do we store your personal data?
All information you provide to us is stored on our secure servers. Currently these are located in England (UK) and Australia.
Where we have given you a password which enables you to access certain parts of one of our platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
People Excellence will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. We determine the appropriate periods for retaining your personal data depending on its purpose, such as proper account maintenance, facilitating client relationship management, and responding to legal claims or regulatory requests.
How can you enquire about, access and correct your personal information?
Access: We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy Officer at: admin@peopleexcellence.com.au
Before we provide you with access to your personal information we may require some proof of identity.
Correction: If you need to correct personal information we hold, please contact our Privacy Officer at one of the above contact points.
How can you complain about our management of personal information?
If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer at one of the above contact points. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate.
Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the relevant privacy regulator for further investigation and will provide you with the regulator’s contact details.
UK Residents: you have the right to complain to the UK Information Commissioner’s Office (ICO).
How do we share your personal information overseas?
We may allow your personal information to be shared with those who are in countries other than your own location. We do this:
- Where we have made a business decision to store our data with trusted partners who are in the business of processing data to provide complimentary psychometric services. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency;
- For disclosures between our group companies. Our main business location is in Australia but we do business in several countries and some of our group companies may be based in other countries from time to time; and
- When our business which collected your personal information is in a different country to your location.
How will we update this policy?
This privacy policy is current at the date below. We may change it periodically. If we propose to change this policy, we will display at least 2 weeks’ prior notice of the change on www.peopleexcellence.com.au.
How to get more information?
Please contact our Privacy Officer with any questions about this privacy policy.
More information about privacy law and privacy principles is available from the privacy regulator:
- In Australia, please see the Privacy Commissioner: oaic.gov.au (email: enquiries@oaic.gov.au).
- In the UK, please see the Information Commissioner: ico.org.uk (email: casework@ico.org.uk)
Last updated: October 2018