Privacy Policy
1. Introduction
This Privacy Policy has been developed to outline People 2.0’s commitment to protect
and manage Personal Information. It describes the information that may be collected
by People 2.0, the choices an individual can make to access and correct their
Personal Information and how People 2.0 protects and discloses Personal Information.
For the purpose of this policy, People 2.0 includes all its affiliates, related
parties, employees and personnels who may be handling Personal Information of
individuals for and on behalf of People 2.0.
People 2.0 respects the Personal Information and the right to privacy of individuals
including employees, prospective employees/candidates, Independent Professionals
(IPros) and/or contractors, vendors, service provider personnels, customers, job
applicants, shareholders, investors, clients and prospective client’s contractors,
including their representatives, authorised persons and any personnel or employee who
may share their Personal Information with the company (“hereinafter referred to as
“Individuals”). Protecting privacy when handling Personal Information is very
important to People 2.0 and is fundamental to the way the company services everyone.
Personal Information means and includes any information that People 2.0 holds about
an Individual from which such Individual’s identity is either apparent or can be
reasonably determined.
This Privacy Policy applies to:
- online websites operated by People 2.0, which are used to provide access to
information about our services and products;
- ‘Entity Online’ (online Portal service);
- ‘Entity Mobile’ (mobile phone application) which allows users to provide
information and conduct certain transactions using electronic means;
- Internal information management of Individuals; and
- Any documents, agreements, forms or processes of People 2.0 to which this policy
is appended such as consent forms signed by candidates in recruitment process
etc.
By visiting the websites, Entity Online or Entity Mobile of People 2.0 or otherwise
providing us with your Personal Information, you are accepting the practices of
People 2.0 with respect to the collection, storage and use of Personal Information.
2. Privacy collection statement
Personal Information is collected in accordance with local laws and may be sought
from you when you:
- apply for an available position;
- are requested to provide Personal Information during an interview;
- complete forms and provide documents when onboarding;
- request information from People 2.0;
- provide any Personal Information to People 2.0;
- download certain documents and information;
- register for a demonstration of certain products or services;
- sign up or subscribe to a newsletter; or
- various forms of business transactions.
Examples of Personal Information or sensitive Personal Information the People 2.0
collects, includes names, addresses, email addresses, phone, emergency contacts, bank
details, superannuation, national ID, biometric information and all information
related to remuneration including bonuses and salary.
People 2.0 may also collect statistical information regarding the use of its website
or portal. The information collected includes the visitor’s computer Internet
Protocol (IP) address, the date and time of the visit, previous site visited and
browser type. This information is collected to provide People 2.0 with information
about users, to help maintain and develop, to provide better information to users of
the website, Entity Online or Entity Mobile.
People 2.0’s website and Entity Online use cookies for the purposes of session
tracking. However, People 2.0 does not collect any Personal Information from the
cookies, including any habits when accessing the website or Entity Online.
Personal Information collected by People 2.0 is for the primary purpose of providing
services, and product information to certain Individuals. Personal Information may
also be used for the following purposes:
- To discharge any statutory or reporting obligations;
- To provide information to you about People 2.0’s products and/or services;
- To contact you and respond to your queries;
- To enforce rights and to fulfil obligations under any agreement between People
2.0 and its clients;
- To enforce rights and to fulfil obligations under any agreement between you and
People 2.0;
- To record statistical data for marketing analysis;
- Any other purpose which is permitted under any agreement between you and People
2.0.
- Any purpose related to or in connection with employment of any Individuals;
- For internal operational purposes of People 2.0 or its clients such as record
keeping, accounting and compliance with applicable taxation laws;
- To comply with applicable law; and
- To investigate, prevent, or take action regarding illegal activities, suspected
fraud, situations involving potential threats to the safety of any person, or as
otherwise required by law;
While People 2.0 will endeavour to collect Personal Information directly from you,
People 2.0 may collect some of the Personal Information indirectly from others, such
as the clients or prospective clients of People 2.0, or your employer.
If at any time you provide Personal Information about another individual to People
2.0 you must ensure that the individual has read and understood this policy and
separately consented to that Personal Information being used and disclosed by People
2.0 for the purpose set out in this policy.
3. Disclosure
People 2.0 trusts your discretion and judgement to provide Personal Information, and
upholds the promise that Personal Information will not be disclosed except as follows:
- To the clients of People 2.0 (as part of an engagement or prospective engagement
in which you are involved or likely to be involved);
- On a confidential basis to agents and service providers that People 2.0 uses in
the ordinary operation of its business;
- To any of People 2.0’s agents, contractors or third party service providers that
process or will be processing your Information, on behalf of People 2.0,
including but not limited to those which provide administrative or other
services to People 2.0 such as mailing houses, telecommunication companies,
information technology companies and data centres and third parties, such as
service providers, to whom disclosure by People 2.0 is for one or more of the
purposes outlined in this policy and such third parties would in turn be
collecting and processing your Information including Personal Information for
one or more of the said purposes.
- To other third parties where you consent to the use or disclosure; or
- Where required or authorised by law.
People 2.0 may also use this information for secondary purposes closely related to
the primary purpose, in circumstances where it would be reasonable to expect such use
or disclosure.
Personal Information that is “Sensitive Information” will not be disclosed without
your consent.
4. Spam
When communicating electronically with any Individuals, People 2.0 follows all local
laws.
a – Consent
The company will only send commercial electronic messages with the addressee’s
consent either express or inferred consent.
b – Identify
The company will include clear and accurate information about the person or business
that is responsible for sending the commercial electronic message.
c – Unsubscribe
The company will ensure a functional unsubscribe facility is included in all
commercial electronic messages and deal with unsubscribe requests promptly.
Individuals can unsubscribe from mailing/marketing lists at any time; by advising
People 2.0 (see Contact People 2.0 details on this page), or by
following the steps outlined in the email communication.
5. Anonymity
Subject to an agreement to the contrary, you are not required to provide People 2.0
with your Personal Information. However, the services and products offered by People
2.0 rely on such information. If you do not provide your Personal Information, then
People 2.0 may not be able to engage you or provide services to you.
6. Security of Personal Information
Personal Information is stored in a manner that reasonably protects it from misuse,
loss, unauthorised access, modification or disclosure in compliance with the
applicable laws. The information is stored on secure servers, at a data warehouse,
onsite, or at an eternal archiving facility. People 2.0 employees are obliged to
respect the confidentiality of any Personal Information held by People 2.0.
However, security of communications cannot be guaranteed, and therefore absolute
assurance that information will be secure at all times cannot be given. To the extent
permitted by law, People 2.0 does not accept responsibility for events arising from
unauthorised access to Personal Information.
When Personal Information is no longer needed for the purpose for which it was
obtained, the company will take reasonable steps to destroy or permanently
de-identify Personal Information. However, most of the Personal Information is or
will be stored in files which will be kept by the company for a minimum of seven (7)
years.
External Service Provider
The websites Entity Online and Entity Mobile of People 2.0 and its electronic mail
servers may be managed by a third-party hosting service provider. When you access the
websites, portals or mobile application of People 2.0 or transmit electronic mail to
People 2.0, you may be communicating with a third party’s server.
People2.0 and links to other websites
People 2.0’s website may contain links to other websites. These linked sites are not
under the control of People 2.0. People 2.0 is not responsible for the information
handling practices, conduct or the content of those sites.
Unsolicited personal information
If People 2.0 receives Personal Information that the company did not solicit, the
company will as soon as possible (and only if lawful to do so), destroy the
information or ensure that the information is de-identified.
7. Access to Personal Information
People 2.0 will, upon request, and subject to applicable privacy laws, provide
Individuals access to Personal Information held by People 2.0. If making a request,
we ask that the type/s of Personal Information requested is clearly listed in writing
and sent to your relevant People 2.0 representative or by contacting the People 2.0’s
Privacy Officer (see Contact People 2.0 details on this page).
The company will deal with the request in a reasonable timeframe and in most
instances within 30 days of receipt of a request. In order to protect Personal
Information, People 2.0 will require identification before releasing such
information. Personal Information sought by spouses or other third parties requires
written authority by the individual the information is being sought for prior to
making such a request. If the evidence is insufficient People 2.0 may deny the
request.
People 2.0 will not charge for lodging a request but may recover reasonable costs
incurred in supplying the information.
Exceptions:
The right to access Personal Information is not absolute. In certain circumstances
the company may refuse a request for information, such as circumstances where:
- Access would pose a serious threat to the life or health of any individual;
- Access would have an unreasonable impact on the privacy of others;
- The request is frivolous or vexatious;
- The information relates to a commercially sensitive decision-making process;
- Access would be unlawful; or
- Access may prejudice enforcement activities, a security function or commercial;
negotiations.
8. Changes to or deletion of Personal Information
You may review, correct, update, or change your Personal Information by emailing
People 2.0 at compliance.apac@people20.com.
You
may
also
request
People
2.0
to
delete
your
Personal
Information,
and
People
2.0
will
comply
with
such
requests
within
a
reasonable
time,
unless
the
company
is
required
to
keep
certain
information
for
legal
purposes.
9. Privacy Laws
People 2.0 complies with the relevant legislation in each country it operates in:
Country |
Legislation |
Australia
|
Privacy Act (1988)
Privacy Amendment (Notifiable Data Breaches) Act 2017
|
New Zealand
|
Privacy Act 2020
|
Singapore
|
Personal Data Protection Act 2012
|
Hong Kong
|
Personal Data (Privacy) Ordinance (Cap. 484)
|
Malaysia
|
Personal Data Protection Act 2010
|
India
|
Information Technology Act, 2000 along with Information Technology
(Reasonable Security Practices and Procedures and Sensitive Personal
Data or Information) Rules, 2011
|
10. Freedom of Information Laws (for data subjects in Australia)
In Australia, in addition to Privacy Laws, individuals may have rights to access
their Personal Information contained in certain company documents. Details on how to
apply for access to these documents are contained in the Freedom of Information Act
1982 (FOI Act).
11. Quality of Personal Information
It is an important part of providing services to our clients that Personal
Information is up to date and the company takes reasonable steps to make sure that
Personal Information is accurate, complete and up-to-date.
It is important that individuals advise People 2.0 at the earliest opportunity of any
changes to Personal Information so that People 2.0’s records can be updated. This can
be done by contacting your relevant People 2.0 representative or by contacting People
2.0’s Privacy Officer (see Contact People 2.0 details on this page).
12. Consequences of Breach of Privacy and Personal/Sensitive Information
Individuals (employees, IPros and/or contractors) are expected to act in a manner
consistent with the matters set out in this policy where they have a responsibility
with respect to Personal Information. Failure to do so may subject individuals to
disciplinary action, and may result in warning letter, demotion or termination
depending on the level or seriousness of the breach.
If anyone suspects or is aware of a breach of privacy, they have an obligation to
report this breach to the People 2.0’s Privacy Officer so immediate action can be
taken to eradicate the situation. Contact details of the Privacy Officer are provided
in this policy under “Contact People 2.0”.
13. Policy Updates
This Privacy Policy may change from time to time. People 2.0’s Privacy Policy is
available at the People 2.0 offices, intranet, portal or website. People 2.0 reserves
the right to make changes to this Privacy Policy from time to time as business or
technical needs require.
14. Complaints Procedure
An individual may make a complaint if they feel their Personal Information has been
handled inappropriately by People 2.0 and is in breach of People 2.0’s privacy
obligations.
In the first instance, complaints must be directed to People 2.0’s Data Protection
Officer in writing. People 2.0 will investigate the complaint and prepare a response
to the complainant in writing within a reasonable period of time.
If the complainant is not satisfied with People 2.0’s response or the manner in which
People 2.0 has dealt with the complaint, the individual may make a formal complaint
to the relevant authority in their country.
Individuals are requested to alert People 2.0 of any practices that breach local
laws, to enable the situation to be remedied. People 2.0 is committed to obtaining
fair resolutions of any complaint or concern about privacy.
Please contact the People 2.0 Data Protection Officer with a compliment, complaint or
privacy question, via the following means:
Emailing: compliance.apac@people20.com
or
Calling: 0011 61 (03) 9600-0333;
or
Writing to:
Sabah Khan (Data Protection Officer)
Legal & Compliance
North Tower, Level 13, 80 Collins Street, Melbourne VIC 3000
Melbourne, VIC, 3000.
Australia