INTRODUCTION

First Advantage Australia Pty Ltd ACN 101 863 209 ("First Advantage", "we", "us" or "our") provides a background screening service for its clients (the Clients), to assist them in considering candidates for employment, change in the level of responsibility, other circumstances where an individual's background is relevant, or to determine if further verification or investigation is necessary.

As part of our services, we receive information about candidates for the purposes of conducting our checks. Some of this information may be "personal information" for the purposes of the Privacy Act 1988 (Cth) (the Act).

"Personal information" is defined as, "information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion."

We recognise the importance of privacy issues and respect the confidentiality of the personal information candidates provide to us.

We will deal with personal and sensitive information in accordance with the Privacy Act 1988 (Cth), and our Privacy Statement and this Privacy Policy (both as amended from time to time).

This Privacy Policy is to be read in conjunction with the Privacy Statement. Should there be any difference between them, the provisions of the Privacy Policy will prevail.

SENSITIVE INFORMATION

We may collect other personal information which is sensitive information (e.g. criminal records, membership of a political association, health). Sensitive information is given a greater level of protection under the Privacy Act. The Privacy Act imposes greater obligations on us regarding any collection, use or disclosure we make of a candidate's sensitive information. Any sensitive information we collect will be done in accordance with the Privacy Act.

MAIN PURPOSES FOR WHICH WE COLLECT INFORMATION

When engaged by a Client, First Advantage verifies a candidate's information and responses by carrying out verification checks for the purposes of enabling the Client to assess a candidate's suitability for employment, promotion, provision of services, or other purposes in accordance with their legal obligations and internal risk management policy.

In certain circumstances, First Advantage may be engaged by a Client because they are required by law to determine a candidate’s suitability for a position of employment, for example under the Corporations Act 2001 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

In order to process and verify information for a Client's request, the Client and First Advantage may collect a candidate's personal information (including but not limited to information relating to background, character and personal reputation) from the candidate and, if necessary, use some or all of the collected personal information to collect additional personal information from various other entities (the Sources). Examples of Sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, ratings agencies, educational institutions, and regulatory and licensing bodies.

Depending on the background checks required by the Client and information candidates supply to us, we may also conduct background checks and collect information regarding employment history and references (with the exception of a candidate's current employer, unless the candidate has authorised such contact or commences employment with the Client), education, professional qualifications, residency, sanctions, immigration status, criminal records, claims, judgments, current and previous directorships, character, personal reputation, and such other checks and enquiries as the Client considers necessary to verify information provided by a candidate.

We may, from time to time, need to collect information about a candidate from a third party a candidate refers us to. In these circumstances, we will assume that the candidate has referred First Advantage to them and informed them of the purposes involved in the collection, use and disclosure of the relevant personal or other information.

HOW WE STORE AND USE PERSONAL INFORMATION

We may use and disclose the information and responses a candidate has provided to us to apply to the Sources for verification of a candidate's personal and other information a candidate or a third party has provided, and to conduct public record searches.

The personal information provided to us by a candidate and any other personal information provided by the Sources as a result of the verification process will be processed and provided by us.

First Advantage may then report the findings of its investigations to the Client via a secure means. The Client may then use that information to consider a candidate's suitability for employment, or change in the level of responsibility, other circumstances where an individual's background is relevant or to determine if further verification or investigation is necessary.

We store the personal information we receive in hard copy files and/or in electronic format in a database. We take precautions to store personal information securely. We may, from time to time, need to retain personal information collected from a candidate and the Sources to comply with our contractual, statutory or other legal obligations even after the employment or other application process is completed or terminated.

IDENTIFIERS

An "identifier" is a unique identification number assigned to a candidate by the Commonwealth Government or a Commonwealth Government Agency. Examples of identifiers include a Tax File Number (TFN) or a Medicare number. First Advantage does not use identifiers to identify a candidate's personal information in our systems.

OVERSEAS TRANSFERS OF PERSONAL INFORMATION

From time to time, we will need to transfer personal information overseas in order to liaise with the Sources, the Employer and/or our offshore related entities. We will transfer personal information overseas if:

• we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles similar to the Australian Privacy Legislation;
• the candidate has consented to the transfer;
• the transfer is necessary for us to provide the Client with their requested service;
• it is not practical to obtain a candidate's consent, the transfer is for the candidate's benefit and the candidate's consent would likely be given; and
• we have taken reasonable steps to ensure that a candidate's personal information will not be held, used or disclosed by the recipient in a manner inconsistent with this Privacy Policy and the Privacy Act.

ACCESS AND CORRECTION OF INFORMATION

A candidate may apply to obtain details of their personal information which is held by us. A candidate may apply for that information by contacting the Privacy Officer at the contact details set out in this Privacy Policy.

We will handle requests for access to a candidate’s personal information in accordance with the Privacy Act. However, in some circumstances permitted under the Privacy Act we may not be required to give a candidate access to the information we hold about them.

It is also important to us that the information we hold about a candidate is accurate, complete and up to date. If a candidate becomes aware that this is not the case and would like to correct their personal information, they may lodge a correction request by contacting the Privacy Officer at the contact details listed in this Privacy Policy. First Advantage will make all reasonable efforts to correct the information.

Any complaints about a breach of privacy will be dealt with in accordance with our Privacy Policy. If a candidate has a complaint about the way First Advantage has dealt with their personal information, a candidate may contact our Privacy Officer at:

The Privacy Officer
First Advantage
PO Box 455
North Sydney NSW 2059
Tel: + 61 2 9017 4300

Details of our Privacy Policy are also available at www.FADV.com.au

If a candidate is unsatisfied with the outcome, they may refer the matter to the Privacy Commissioner at:

Website: www.privacy.gov.au
Tel: 1300 363 992