Centre for Leadership Advantage Pty Limited ACN 109 769 306 (“CLA”), including our employees, agents, contractors and associates, understands that privacy and how we collect, use, disclose and protect your information is important to you. We are committed to ensuring the privacy of your information and to complying with the Australian Privacy Principles (“APPs”), which are contained in the Privacy Act 1988 (“Privacy Act”). In summary, personal information is information or an opinion (whether true or not) about an identified, or reasonably identifiable, individual.
1. WHAT PERSONAL INFORMATION DOES CLA COLLECT AND HOLD?
CLA is one of Australia’s most progressive leadership firms, working extensively with ASX-listed, private, not-for-profit and Government organisations using science based practice to create authentic leaders. The type of personal information we collect and use will depend on various factors such as the type of service you request or use and any applicable legal and regulatory obligations. This may include, but is not limited to, collection and use of the following kinds of information:
- Contact: information that allows us to communicate with you,
- Identity: information that allows us to identify you,
- Professional: information that helps us to understand more about you including your employment history, qualifications, talents, skills and abilities,
- Financial: information that allows CLA to pay you should you be engaged as an employee or contractor,
- Other individuals: information we request, or that you provide, about an individual other than yourself such as an employer, employee, contractor, manager, etc.
The purpose for CLA collecting such information may include, but is not limited to, the following circumstances where you:
- instruct CLA to provide you with professional services;
- have business dealings with us;
- participate in a CLA offering or program;
- purchase or subscribe to a CLA’s online service or application;
- subscribe to our website (which includes our website’s sub-domains or microsites) or to one of our mailing lists;
- receive marketing communications and information relating to our services which we think may be of interest to you;
- attend a CLA event;
- arrange or provide you with competency or psychometric tests and assessments;
- apply or register your interest in employment with CLA.
The personal information we will collect from you will usually include your name, title, address, email address and contact numbers (telephone, mobile). If necessary for the purposes of providing advice to you, or for providing you with other information (such as email updates) sometimes we may collect other personal information from you, such as the areas of our business which you are interested in. We do not collect personal information that we do not need.
Please note that, while we seek to minimise the personal information we collect, if you do not provide us with the personal information we request, we may not be able to provide you with the services and other assistance you seek.
Generally, we endeavour to collect personal information directly from the individuals concerned. However, if this is not practicable, we may collect personal information about individuals from third parties, including from publicly available sources. If we do, we will take reasonable steps to ensure that the individuals concerned are made aware of the collection of their information.
As a general rule, CLA will not ask to collect sensitive information about you (such as details of your racial or ethnic origin, political affiliation, religious beliefs, sexual preferences, criminal convictions or health information) unless it is needed for the purposes of providing our professional service. However, in circumstances where CLA requires sensitive information from you, CLA will first seek your consent to collect it.
2. HOW DOES CLA USE PERSONAL INFORMATION?
CLA’S policy is only to use personal information collected from business contacts for the business purpose for which it was collected. CLA need to collect personal information so that we can provide our products and services, and
conduct our business. We also collect personal information so that we can invite you to events and communicate new industry and business developments, including advertising new products or services that we offer, to our clients and to those people who have subscribed to our website, alert services or mailing lists.
3. WILL YOUR PERSONAL INFORMATION BE GIVEN TO ANYONE ELSE?
CLA does not sell, rent or trade personal information about you to or with third parties. Personal information may be disclosed outside of CLA in the circumstances described below. CLA may disclose personal information to external service providers who provide services to you and help us operate our business. Examples of our external service providers include, but are not limited to:
- CLA’S related entities;
- CLA’S third-party suppliers or providers, including, but not limited to, organisations who provide:
- competency or psychometric tests and assessments,
- experiences for participants as part of our offerings and programs,
- data storage and archiving,
- information technology and other software and systems,
- printing services,
- advertising and marketing agencies who assist us with our campaigns and programs,
- research organisations and consultants who conduct research, on behalf of CLA.
If CLA engages external service providers, CLA takes steps to ensure that those external service providers:
- comply with the APPs when they handle personal information about you, and
- are authorised only to use personal information that we provide to them for the limited purposes specified in our agreement with them.
Otherwise, CLA will only disclose personal information if this is required by law or permitted under the Privacy Act. CLA is also bound by professional obligations of confidentiality, including in relation to personal information.
4. SECURITY OF PERSONAL INFORMATION
CLA takes reasonable steps to ensure the security of the personal information we hold from loss, unauthorised access, and misuse. The use of locks and security systems assist CLA in protecting your personal information. Your personal information may be stored in hard copy documents, or electronically on CLA’s software or systems. When no longer required, personal information is destroyed in a secure manner or deleted. In addition, all CLA employees are required, as a condition of employment, to treat personal information held by CLA as confidential.
5. ACCESS AND CORRECTION
Under the Privacy Act, you have the right to:
- seek access to your personal information handled by CLA,
- ask us to update or correct your personal
- information when it is inaccurate, incomplete or out of date, and opt-out of receiving direct marketing communications from us.
If you wish to access the personal information that CLA holds about you, please set out your request in writing, and forward this to our Office Manager; email@example.com. To provide you with access to your personal information held by us on our current records, CLA can provide you with a copy of the relevant personal information (ordinarily, an electronic print-out or a photocopy). CLA will not charge you for the cost of providing this type of access to these current records. For legal and administrative reasons, CLA may also archive non-current records containing personal information, such as back up data files and offsite storage. If you are of the view that personal information about you is inaccurate or out of date, or if you have any other queries about access and correction, please contact our Office Manager.
6. ONLINE PRIVACY ISSUES
When you visit our website, a small data file called a “cookie” is stored on your computer or mobile device by our server.
7. MAKING A COMPLAINT
If you wish to make a complaint about how CLA handles your personal information, please contact us setting out your complaint in writing, and forward it to our Office Manager; firstname.lastname@example.org.
We will deal with all requests for access to personal information or complaints as quickly as possible and will endeavour to respond to you within a reasonable timeframe.
8. HOW DO WE HANDLE THE PERSONAL INFORMATION OF JOB APPLICANTS?
CLA collects personal information about and from individuals who apply for employment with CLA or as an associate or third-party contractor. The information we collect includes, but is not limited to, the job applicant’s:
- personal contact details,
- educational and employment history, and qualifications,
- eligibility to work in Australia, and
- referee’s contact details.
We may collect this information directly from the job applicant or indirectly from a third-party, including from a recruitment agency.
If necessary, we will also collect information about applicants from referees and from professional social networking websites like LinkedIn. If the applicant proceeds to the interview stage, we will collect information about the applicant’s performance during the interview process and psychometric testing.
If you do not provide us with the information we request, we may not be able to process or assess your job application.
CLA uses the personal information we collect about job applicants to assess their eligibility and suitability for employment with our business. Generally, our assessment of applicant’s personal information will relate to a particular role. However, we may also retain and use applicant’s personal information to assess their suitability for other roles with the firm. We do not disclose the personal information we collect from applicants to any other person or entity.
9. HOW DO WE HANDLE THE PERSONAL INFORMATION OF PARTICIPANTS UNDERTAKING PSYCHOMETRIC TESTING OR ASSESSMENT?
CLA collects personal information about and from individuals who undertake psychometric testing and assessment. The information we collect includes, but is not limited to, the participant’s:
- personal contact details and gender,
- results of competency or psychometric testing and assessments conducted and provided by a third party.
We may collect this information directly from the participant or indirectly from a third-party, including from your employer or an organisation you wish to seek employment with. If you do not provide us with the information we request, we may not be able to allow you to participate in testing or assessments. CLA may provide the personal information we collect and the results of your psychometric testing and assessments to a third-party including your employer or an organisation you wish to seek employment with.
Generally, our collection of a participant’s personal information will relate to particular testing or assessments. We do not disclose the personal information we collect from participants to any other person or entity unrelated to the operating of our business. CLA use third-party providers to conduct psychometric testing and assessments. CLA may disclose your personal information to external service providers who provide services to you and help us operate our business. We also may request that you provide your personal information directly to a third-party. We suggest that you also make your own enquiries into a third-party’s use of that personal information.
10. HOW DO WE HANDLE THE PERSONAL INFORMATION OF CLA PROGRAM PARTICIPANTS?
CLA collects personal information about and from individuals who take part in an experience as part of a CLA program. The information we collect includes, but is not limited to, the participant’s:
- personal contact details and date of birth,
- next of kin or emergency contact details,
- dietary or food allergies.
We may collect this information directly from the participant or indirectly from a third-party, including from your employer. If you do not provide us with the information we request, we may not be able to allow you to participate in an offering or program. Generally, our collection of a participant’s personal information will relate to a particular offering or program. We do not disclose the personal information we collect from participants to any other person or entity unrelated to the operating of our business. CLA use third-party providers to facilitate some of our offerings or programs. CLA may disclose your personal information to external service providers who provide services to you and help us operate our business. We also may request that you provide your personal information directly to a third-party. We suggest that you also make your own enquiries into a third-party’s use of that personal information.
11. ADDITIONAL PRIVACY INFORMATION AND HOW TO CONTACT CLA
Centre for Leadership Advantage
Level 3, 480 Collins Street
03 8610 6373