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:

1. online websites operated by People 2.0, which are used to provide access to information about our services and products;
2. ‘Entity Online’ (online Portal service);
3. ‘Entity Mobile’ (mobile phone application) which allows users to provide information and conduct certain transactions using electronic means;
4. Internal information management of Individuals; and
5. 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:

1. apply for an available position;
2. are requested to provide Personal Information during an interview;
3. complete forms and provide documents when onboarding;
4. request information from People 2.0;
5. provide any Personal Information to People 2.0;
6. download certain documents and information;
7. register for a demonstration of certain products or services;
8. sign up or subscribe to a newsletter; or
9. 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:

1. To discharge any statutory or reporting obligations;
2. To provide information to you about People 2.0’s products and/or services;
3. To contact you and respond to your queries;
4. To enforce rights and to fulfil obligations under any agreement between People 2.0 and its clients;
5. To enforce rights and to fulfil obligations under any agreement between you and People 2.0;
6. To record statistical data for marketing analysis;
7. Any other purpose which is permitted under any agreement between you and People 2.0.
8. Any purpose related to or in connection with employment of any Individuals;
9. For internal operational purposes of People 2.0 or its clients such as record keeping, accounting and compliance with applicable taxation laws;
10. To comply with applicable law; and
11. 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:

1. 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);
2. On a confidential basis to agents and service providers that People 2.0 uses in the ordinary operation of its business;
3. 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.
4. To other third parties where you consent to the use or disclosure; or
5. 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:

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.

Contact People 2.0

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