GENERAL PRIVACY POLICY

Carlyle Kingswood Global makes every effort to comply with the Australian Privacy Amendment (Private Sector) Act 2000 and other applicable national legislation on data privacy. As part of this effort we have implemented a firm-wide data privacy policy relating to the way in which we process the information provided by clients, candidates and anybody else on whom we hold data.

Following is a summary of our policy and procedures:

• We make every effort to ensure that any information held is accurate and kept as up-to-date as possible. We do not obtain information under false pretences.
• As a matter of policy, we do not solicit sensitive information (e.g., data on racial/ethnic origin, health, sexual orientation, political opinions, religious/philosophical beliefs, trade union membership). If an individual provides this information, he or she will be required to give explicit consent for us to hold such information. All information collected / provided to us is entered into our proprietary database. Only Carlyle Kingswood Global employees have access to this data, which is used only for the purposes of executive recruitment and related services.
• Any individual who sends us an unsolicited resume or provides his or her personal data via our Enquiries system should be aware that this information might be added to our database. If an individual does not wish this to happen, we regret that we will be unable to assist him or her in efforts to find a new challenge.

Type of Personal Information Held

Personal information that we collect and hold usually falls into the following categories:

• Candidate Information submitted and obtained from the candidate and other sources in connection with applications for work
• Work performance information
• Information about incidents in the workplace
• Staff information
• Information submitted and obtained in relation to absences from work due to leave, illness or other causes
• Information obtained to assist in managing client and business relationships

What Is Your ‘Personal Information’?

Personal information is any information or an opinion (whether true or not) about you. It may range from the very sensitive (e.g. medical history or condition) to the everyday (e.g. address and phone number). It would include the opinions of others about your work performance (whether true or not), your work experience and qualifications, aptitude test results and other information obtained by us in connection with your possible work placements. Personal information includes ‘sensitive information’.

What is ‘sensitive information’?

Sensitive information is a special category of personal information. It is information or opinion about your: 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; health or disability (at any time); expressed wishes about the future provision of health services.

Purposes For Which We Hold Personal Information

We primarily hold personal information for the following:

• Recruitment & Placement operations
• Staff management
• Training
• Client and business relationship management
• Marketing

Who Will Be Collecting Your Personal and Sensitive Information?

Your personal and sensitive information will be collected by Carlyle Kingswood Global for its own use as required.

How Will Your Information Be Collected?

Personal and sensitive information will be collected from you directly when you speak with one of our consultants and/or submit a resume and/or provide any other information in connection with your application to us.

Personal and sensitive information will also be collected when:

• we receive any reference about you
• we receive any results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body
• we receive the results of any competency, behavioral or medical test
• we receive performance feedback (whether positive or negative)
• we receive any complaint from or about you in the workplace
• we receive any information about a workplace accident in which you are involved
• we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved
• you provide us with any additional information about yourself

Disclosures

We will not disclose personal information to persons outside of Carlyle Kingswood Global Search without your permission, except that we may disclose your personal information where we are under a legal duty to do so, including circumstances where we are under a lawful duty of care to disclose information.

Information Security

Carlyle Kingswood Global takes appropriate technical and organisational measures to protect against the loss, misuse, unauthorised access, disclosure, alteration or destruction of personal information under our control (e.g., multiple levels of user authentication, industry standard security).

All Carlyle Kingswood Global employees undergo training on data privacy and security and are required to comply with our strict internal standards in these areas.
All documents provided to clients contain a statement reminding them of the confidential nature of the information they receive as well as their obligation to comply with applicable national data privacy legislation.

Your Rights

In accordance with applicable national data privacy legislation, an individual may have the right to contact Carlyle Kingswood Global in his or her country of residence to establish whether or not we hold personal data on him or her and the names of any people or organisations that may have received a copy of this data.

Any individual with a record in our database has the right to request a copy of any of his or her personal information accessible by means of a search on his or her name in our systems.
Any individual with a record in our database has the right to request that we rectify any inaccuracies in his or her personal data or that his or her record be removed from our database and other systems.
If for good reason we are unable to comply with such a request, we will let the individual know.

An individual may direct any such requests or any questions relating to data privacy to the Data Privacy Officer at the Carlyle Kingswood Global office. We may need to ask the individual to provide appropriate confirmation of identity before processing a request.

All requests will be acknowledged and dealt with as quickly as possible and within the timeframe stipulated by the applicable data privacy legislation for the individual’s country of residence.