Transformd Privacy Policy

Transformd Internal Privacy Policy

1.0 Purpose 

The purpose of this policy is to satisfy the regulatory notification requirements as well as to demonstrate our commitment to safeguarding and appropriately handling our employees’ and contractors’ personal information. 

This Internal Privacy policy ensures that Transformd:

• Complies with data privacy requirements and follows good practices
• Informs employees and contractors of their privacy rights and Transformd’s information handling practices.

2.0 Scope 

The Internal Privacy Policy applies to all employees, workers and contractors of Transformd (collectively referred to as “Individuals”). It applies to all data that the company holds relating to identifiable individuals and it describes how Transformd collects and uses personal information during and after their working relationship with Transformd, in accordance with the following applicable information protection legislation:

• For Australian-based employees:
  • applicable provisions of the Privacy Act 1988 (Cth). 
  • applicable provisions of the Fair Work Act 2009 (Cth).

Transformd has decided to apply the highest regulatory standards in dealing with personal information uniformly across all our offices, regardless of regulatory requirements, while at the same time complying with any specific, local privacy requirements.

3.0 What personally identifiable information (PII) we collect

Personally identifiable information (PII) means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous information).

We collect, store and use the following categories of personal information:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Personal identity details such as date of birth, marital status, sex, gender identity, veteran status, and ethnicity. 
• Dependent details such as name, Tax File Number, date of birth, gender, marital status, student status, address, and phone number.
• Next of kin, emergency contact and death benefit nominee(s) information.
• Tax File Number and other government/state-issued IDs. 
• Payroll records and tax status information.
• Salary, annual leave, and benefits information.
• Start date, leaving date.
• Location of employment or workplace.
• Relevant proof of identification to verify your identity and eligibility to work (e.g., passport, driving license).
• Recruitment information (including copies of right to work documentation, references and other information included in a resumé or cover letter or as part of the application process).
• Compensation history.
• Performance and appraisal information.
• Disciplinary and grievance information.
• Information about the use of our information and communications systems.
• Photographs, videos.
• Incident register, first aid records, injury at work and third party accident information.
• Information about convictions/allegations of criminal behaviour.

Transformd typically collects personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. 

Transformd will sometimes collect additional information from third parties, including former employers, credit reference agencies or other background check agencies.

Transformd collects additional personal information in the course of job-related activities throughout the employment period or life of the contract.

Transformd limits the collection of personal information to what is strictly necessary to establish, manage or terminate the employment or contractual relationship with its workers. If Transformd needs to collect additional personal information for reasons outside establishing, managing or terminating the employment or contractual relationships, we will notify the appropriate individuals in advance and obtain their consent. 

Applicable privacy legislation may allow us to collect personal information about individuals without their consent in specific circumstances, such as investigations or legal proceedings. 

4.0 Individual's responsibility to inform Transformd of changes

It is important that the personal information we hold about our workers is accurate and current. Individuals are responsible for keeping Transformd informed if their personal information changes during their working relationship with us.

5.0 How we use personal information 

Transformd will only use personal information as permitted by the applicable legislation.  

Most commonly, Transformd will use personal information in the following circumstances:

• Making a decision about recruitments or appointments.
• Determining the terms of working agreements.
• Checking that individuals are legally entitled to work in the jurisdiction.
• Paying individuals and, if applicable, deducting tax and any other social contributions.
• Providing employment-related benefits including:
  • Occupational Sick, Adoption, Maternity, Paternity, Shared Parental and Annual leave
  • Salary, including any pay awards or allowances 
  • Superannuation
  • Advances of salary
• Liaising with superannuation providers, providing information about changes to employment that may impact salaries (e.g., promotion, changes in working hours).
• General administration of the employment or work contract.
• Business management and planning, including accounting and auditing.
• Conducting performance reviews, managing performance and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job/task, including decisions about promotions.
• Gathering evidence and dealing with grievances, disciplinary matters, etc.
• Making decisions about continued employment or engagement.
• Making arrangements for the termination of working relationships.
• Education, training and development requirements.
• Dealing with legal disputes involving Transformd workers, including accidents at work.
• Ascertaining workers fitness to work, managing sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor workers' business and personal use of Transformd’s information and communication systems to ensure compliance with our IT policies, such as emails, drives, business communication platforms (like Slack, etc) laptop folders or any other resources provided.
• To ensure network and information security, including preventing unauthorised access to Transformd computer and electronic communications systems and preventing malicious software distribution.
• To conduct information analytics studies to review and better understand employee retention and attrition rates.
• Dealing with any subject rights requests.
• To provide employment references at workers' request.
• To carry Transformd’s HR-related investigations, solving internal disputes, etc.

Transformd will only use personal information to establish, manage or terminate the employment or contractual relationships.

If Transformd needs to use personal information for an unrelated or new purpose, Transformd will notify the appropriate individual and obtain their consent for the new purpose. Individuals always have the right to withdraw their consent at any time. 

Please note that Transformd will, if necessary, process personal information without the individual’s knowledge or consent as allowed by the applicable privacy legislation in specific circumstances, such as investigations or legal proceedings. 

6.0 How we share personal information 

Transformd will, in some circumstances, have to share information with third parties, including third-party service providers.

Transformd’s third-party service providers are required by contractual obligations to take appropriate security measures to protect personal information in line with applicable privacy legislation. 

Transformd does not allow third-party service providers to use personal information for their own purposes. Transformd only permits them to process personal information for specified purposes and in accordance with instructions.

Transformd will in some circumstances transfer personal information outside the jurisdiction the individual works in. In those cases, individuals can expect a similar degree of protection in respect of their personal information as that provided under the applicable privacy legislation. 

We share your personal information with third parties if it’s:

• required by law, and
• necessary to establish, manage or terminate the working relationship

Transformd does not sell the personal information of any employees or contractors.

6.1 Third-party Service Providers Transformd Uses 

These are entities which Transformd contracts to support activities for HR and payroll purposes:

Australia

• Payroll (Monocle Bookkeeping /Xero)
• IT services (Rawtech name of vendor/application)
• Recruitment agencies (Jobfitts name of vendor/application)

7.0 Information Security

Transformd has put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

In addition, Transformd limits access to personal information to those employees, contractors and other third parties who have a business need to know. They will only process personal information on Transformd instructions. 

Transformd has put in place procedures to deal with any suspected information security breach and will notify affected individuals and any applicable regulator of a suspected breach where legally required to do so.

8.0 Information Retention

Transformd will only retain personal information for as long as necessary to fulfil the purposes it was collected for, including to satisfy any legal, accounting or reporting requirements. 

To determine the appropriate retention period for personal information, Transformd considers the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process personal information and whether those purposes can be achieved through other means, and the applicable legal requirements.

Transformd will retain and securely destroy the personal information of former employees, workers or contractors in accordance with defined timelines or applicable laws and regulations.

9.0 Individual Rights in Connection with Personal Information

Under certain circumstances, by law, individuals have the right to:

• Request access to personal information. This enables individuals to receive a copy of the personal information Transformd holds about individuals and to check that Transformd is lawfully processing it.
• Request correction of the personal information that Transformd holds. This enables individuals to have any incomplete or inaccurate information Transformd holds corrected.
• Request erasure of personal information. This enables individuals to ask Transformd to delete or remove personal information where there is no good reason for continuing to process it.
• Right to withdraw consent. In the limited circumstances where individuals have provided consent to the collection, use and transfer of personal information for a specific purpose, individuals have the right to withdraw consent at any time. Once Transformd has received notification of consent withdrawn, Transformd will no longer process information for the purpose or purposes the individual originally agreed to.

Individuals also have the right to lodge a complaint to the responsible authority in their jurisdiction. Please see their contact details below.

• Office of the Australian Information Commissioner (OAIC) 
  
  • https://www.oaic.gov.au/

10.0 Changes to this Privacy Notice

Transformd may update this policy at any time and will provide individuals with a new policy when substantial updates are made. Transformd will also notify individuals in other ways from time to time about the collection, use and sharing of personal information.

Any questions about this policy should be directed to direct supervisors.