PRIVACY POLICY

Your privacy is extremely important to us!

As an Accredited Body through the Australian Criminal Intelligence Commission (ACIC) and through the Australian Federal Police to deliver police check applications, Clear to Work operates under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). As such, the privacy and security of your data is extremely important to us!

This Privacy Policy relates to the personal information that we collect from you through the course of your police check application, how we on-disclose this information to the relevant bodies (such as the National Police Checking Service or the Australian Federal Police), and how we treat the security of this data internally. 

Collection of Information

The personal information we collect will only ever be information essential to the requirements of the products and services we offer.

The information we collect may include but is not limited to:

• Name
• Date and place of birth
• Contact information
• Personal information
• Current and past residential addresses
• Academic credentials
• Credit card or other payment details
• Licences and operator permits
• Passports and other identification
• Credit history information

Personal information can also include any information of an applicant and ‘sensitive’ information.

Sensitive information can include information regarding the data we collected through applications and consent you submit to us as well as contact of people and agencies who may hold (or be in the public domain) information about you. We will always ask your consent to carry out the checks and obtain the data only by lawful and fair means.

We may also collect other information, some of which may be personal information, including information about your order history with us, which areas of our site you visit and records of your interactions with us.

Collection of Personal Information

Personal information is collected directly from you when you begin your police check application process, enter into arrangements with us, correspond with us, or provide feedback to us.

We will record, collect and hold information about your transactions with us. We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes.

Depending on the nature of our interaction with you, we may collect personal information from third parties. For example, when you order a check, the verified data will be collected from a third party source.

The Reason We Collect Personal Information

If you are an individual, the reasons we collect personal information about you are:

• to check and verify that the information you have provided and the personal information located from other sources is correct;
• to administer and provide our products and services to you;
• to communicate with you, our customer;
• to protect against fraud or other misuse or loss of data; and
• to ensure your security when visiting our website.

If you are a corporate user, the reasons we collect personal information about you are:

• to check and verify that the information you have provided and the personal information located from other sources is correct;
• to comply with our legal obligations to know who has access to the personal information of individuals on our system;
• to administer and provide our products and services to you and your employer;
• to better communicate with our customer;
• to understand the needs of our customers and continuously develop and improve our products and services;
• to protect against fraud or other misuse or loss of data; and
• to ensure your security when visiting our website and to learn which areas of the site are of most interest to you (see the section ‘cookies’ below).

Disclosure of Your Information

We will disclose your information in accordance with the services we provide and/or as required by law.

If you are a customer, to electronically verify your identity documents, it is necessary to disclose those identity documents to a third party supplier. To conduct a check, it is necessary to disclose some of your personal information to the entity that will verify the accuracy of your information. For a check relating to another country, that entity will be in that other country and so your information must be disclosed overseas.

In some circumstances, we are required by law to disclose your personal information to various authorities.

Access to Your Personal Information

You have a right to access your personal information held by us. There is no charge to put in a request to see your information and we can provide you with general information such as your name, address and contact details.

If you believe that any information is incorrect or out of date, you may ask us to correct it.

However, we may need to charge you a small administration fee to cover our costs if you want to access more detailed information or take copies of information on your file.

If you wish to access information or to lodge a complaint about our privacy practices, please put your request or complaint in writing and send it to:

Privacy Officer

Clear to Work

21 Nundah Street

Nundah QLD 4012

Australia

The Security of Your Information

Your information is securely stored in Australia.

We aim to ensure that any details are securely protected from misuse, loss, unauthorised access, modification, or disclosure by way of maintaining:

• physical security by preventing unauthorised access to our premises;
• offsite data storage in a Melbourne-based, Australian-owned data centre;
• computer network security including password security to prevent unauthorised access;
• communication security; and
• limiting access to authorised staff.

Standard police check application information is retained for 15 months as per our Access Agreement as an Accredited Body through the Australian Criminal Intelligene Commission (ACIC). Forms submitted to carry out checks are subject to audit in line with our Access Agreement with ACIC.

Payment details and credit card information is not stored in our system. We use a third party payment gateway provider to process credit card payments and we cannot see or access your information.

Cookies

Cookies are small data files that are downloaded from our web servers and stored on your hard drive. It is a string of letters and numbers that uniquely identify the computer you are using and the Username and password you have used to register at the site.

We use a cookie that exists only for the actual time you are logged onto our system. These cookies ensure greater security for you by authenticating and identifying your registration for the secure areas of the site, without the need for you to re-entre information.

You may configure your browser to refuse to accept cookies. You can delete cookies from your hard drive. However, doing so may hinder your access to information within our site.

Protection of Privacy

Access to the National Police Checking Service (Service) under which NCCHCs are provided is administered by the Australian Crime Commission Act 2002 (Cth). The Service also operates in accordance with all relevant Commonwealth, state and territory legislation applicable to the information collected, used and disclosed for the purposes of a police check.

Every effort has been made in the design of the Service to protect the privacy of applicants at all times. In particular, as part of our contractual arrangements with Accredited Bodies, the ACIC requires that:

• all Accredited Bodies comply with the Australian Privacy Principles (APPs), as set out in Schedule 1 to the Privacy Act 1988 (Cth); and
• each accredited body’s privacy policy adheres to the requirements in the APPs.

Retention & Disposal of Personal Information Relating to NCCHCs

In addition to the requirements set out above, the ACIC’s contract mandates that all Accredited Bodies (e.g., Clear to Work) retain each NCCHC application and any identity documents remotely presented by an applicant for a period of 12 months after the receipt of the check to which the application relates (retention period). This is for dispute, auditing, and compliance purposes. It is imperative that the ACIC undertakes these activities to ensure that Accredited Bodies are following guidelines and processes which ultimately assist in protecting the Australian community.

After the retention period has ended, Accredited Bodies are required to dispose of the application and identity documents within three months - meaning Accredited Bodies can not hold any application or identity documentation for longer than 15 months.

The contractual obligations set out in the agreement between Clear to Work and the ACIC are what govern Clear to Work’s access and use of the Service. Under these existing terms, there is no earlier applicant information disposal mechanism available and we must comply with the prescribed timeframes for the retention of applicant information.

More Information

You can request further information about the way we manage the personal information that we hold by either writing to:

Privacy Officer

Clear to Work

21 Nundah Street

Nundah QLD 4012

Australia

Or emailing info@cleartowork.com.au. 

Direct Marketing Offers & Information

The details you give us may be used to inform you about any special offers we think will be of interest to you and to update you on new products and services or changes to our website.

We may also send you details of offers or services provided by our business partners and related entities.

You may at any time choose not to receive these communications. Doing so will not cost you anything, and we will aim to ensure you stop receiving any unwanted communications as soon as possible.