The Divy Group of companies (“Divy”) recognises the importance of privacy and we are committed to protecting your personal information. Divy is required to comply with the Privacy Act 1988 (Cth) which provides for the fair handling of personal information, and sets standards for the collection, access, storage and use of personal information. Our policy for dealing with any personal information that you disclose to us is explained below.
What personal information does Divy collect?
The type of personal information we collect depends on the nature of your dealings with us and the reason for collecting it.
Personal information means information or an opinion about you. The personal information we collect about you may include your name and contact details, your employment details and work experience, industry expertise, areas of interest, qualifications, aptitude test results, opinions about your work performance (e.g. references), incidents at the workplace, and other information obtained or received by us in connection with your possible and actual work placements, details of your dealings with us, and any other information reasonably necessary to provide you with our services.
Sensitive information is a special category of personal information under the Privacy Act 1988 (Cth). It is information or opinion about you, including membership of a professional or trade association or membership of a trade union, criminal record, health information, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, or sexual preferences or practices. As outlined in the Australian Privacy Act, sensitive information can, in most cases, only be disclosed with your consent.
Divy may collect personal or sensitive information about you if:
- You ask us to provide you with a service;
- You instruct us to provide you with recruitment services;
- You complete one of our application forms or provide any other information in connection with your application;
- You instruct us to assist you in finding employment;
- We receive any reference about you;
- We receive results of inquiries that we might make of your former employers, work colleagues, professional associations or registration body;
- We receive the results of any competency or medical test or any background check;
- We receive any complaint or other information from or about you in the workplace;
- We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved;
- We receive any information about a workplace accident in which you are involved;
- You provide us with any additional information about you;
- You are one of our suppliers or contractors or one of their employees;
- You are a subscriber to our mailing list or newsletter;
- You attend an event or seminar organized by Divy; or
- You submit a job application.
To provide services to our clients, we may collect your name, contact details, your employment details, and your dealings with us.
To be able to provide you with certain services, we may require you to register your details through our website. Registration with Divy is completely optional, however, Divy may not be able to provide you with certain services should you not register your details through our website. Registration may include submitting your name, email address, address, telephone numbers and the option on receiving updates and promotional material and other information about Divy’s services. You may access this information at any time by logging in and going to your account.
General information collected from visitors to our website
We gather information about all our website users collectively, such as what areas users visit more frequently and what services users access the most. We only use such data anonymously and in the aggregate. This information helps us determine what is most beneficial for our users, and how we can continually create a better overall website experience for you.
In some instances we may need specific information about you, such as name, address, email address, telephone number etc. We will collect this information if you apply for a job or sign up for a service via our website. We may also ask you for other information such as the types of jobs you are interested in and your workplace concerns in order to provide you with the best possible service and internet experience.
Anonymity and pseudonymity
Given the nature of the services that we provide we generally are not able to deal with you on an anonymous or pseudonymous basis.
How does Divy collect personal information?
How we collect personal information also depends on the nature of your dealings with us.
Divy collects personal information directly from you whenever it is reasonable and practical to do so. Divy may also collect personal information from third parties in the course of providing services to you or them.
Where your personal information is provided to us by a third party, we will take reasonable steps to let you know that we have your personal information, unless it is obvious from the circumstances that you know or would expect us to have the information. Reasonable steps may include asking the person who gave us your information to let you know that we have that information.
If you are one of our suppliers or contractors, your personal information may be collected from you, your employer, employees or third parties.
If you elect not to provide some personal information to us, this may effect our ability to provide services to you.
Purposes and use for which Divy collects personal information
Divy will only collect personal and sensitive information in connection with providing services to you or carrying out business activities. Divy will only use your personal information for the purpose(s) you have provided the information, or as otherwise permitted by law.
Generally, the purpose for which Divy collects personal and sensitive information will be apparent form the way in which we collect it, or will be disclosed at the time of collection. If at any time the purpose for which we are collecting your personal information is unclear, please raise your concerns with the person you are dealing with or contact us using the contact details below.
Your personal and sensitive information may be collected to be used in connection with:
- Your actual or possible work placement;
- Career guidance or management;
- Your performance appraisals;
- Our assessment of your ongoing performance and prospects;
- Any test or assessment (including medical tests and assessments) that you might be required to undergo;
- Our identification of your training needs;
- Informing you of possible work opportunities, relevant candidates, or other events such as training or information sessions by direct mail/email/sms;
- Any workplace rehabilitation;
- Our management and resolution of any complaint, inquiry or investigation in which you are involved;
- Any insurance claim or proposal that requires disclosure of your personal or sensitive information;
- Undertaking criminal reference checks;
- For research, development, business systems and infrastructure testing, and other business purposes to assist us in providing our services to you; or
- Our direct marketing to you.
If you do not give us the information we seek:
- We may be limited in our ability to locate suitable work for you; or
- We may be limited in our ability to place you in work.
When does Divy disclose personal information?
Divy may disclose your personal information (including to trusted third parties) for the purposes for which it is primarily held or for a related secondary purpose and in some cases we may only disclose information with your consent.
Your personal and sensitive information may be disclosed to:
- Potential and actual employers, clients of Divy and trusted third parties;
- Divy employees and partners located in Australia, Philippines and India (and any other countries where Divy may provide its services or have partners in the future) regarding possible work placements or to assist us in providing our services to you;
- External providers of on-line training and induction – e.g. mandatory on-line OH&S Induction;
- Our insurers;
- A professional association or registration body that has a legitimate interest in the disclosure of your personal and sensitive information;
- A Workers Compensation body;
- Any person with a lawful entitlement to obtain the information; or
- Related service entities or third party service providers and contractors who assist in our internal and administrative operations.
Personal information disclosed to Divy may be accessed by permitted users. In most circumstances, the personal information will be disclosed to people located in Australia, Philippines and India. In some circumstances the personal information could be disclosed to people located outside of Australia and , Philippines and India.
Divy may engage third parties to provide you with goods or services on our behalf. In that circumstance, we may disclose your personal information to those third parties in order to meet your request for goods or services.
When we engage the services of a third party, we take reasonable steps to ensure they comply with the Privacy Act and maintain the confidentiality of any personal information to which they have access.
If Divy is required to disclose personal information to an overseas recipient, Divy will take reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles.
Divy does not disclose information about your individual visits to the Divy website.
Divy may use your personal information for research and development of our services or to send you information about other services offered by us which may be of interest to you. If you would prefer not to receive promotional or other material from us, please let us know by sending an email to the contact details below and we will respect your request. Alternatively, simply select the “unsubscribe” option in any of the emails that you receive from us.
Where does Divy store the personal information collected?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium.
Divy stores its documents and personal information collected from those sources on:
- secure computer storage facilities;
- paper-based files and other records;
- servers located in Australia, Singapore and the United States that are managed by either us or third party service providers;
- multiple cloud platforms operated by third party service providers that stores and manages things like, but not limited to, our email, accounting, document management systems.
We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
How does Divy ensure your personal information is correct?
Divy takes all reasonable steps to ensure that your personal information is accurate, complete and up to date. To assist, please contact us if any of the details you have provided are incorrect or have changed.
How does Divy keep your personal information secure?
Divy is committed to keeping your personal information secure. We take reasonable steps to protect your personal information from misuse, loss and from unauthorized access, modification or disclosure.
While Divy uses all reasonable endeavors to ensure that you provide personal information in a secure environment, no data transmission over the internet can be guaranteed as totally secure. Divy does not accept responsibility of information transmitted to us over the internet.
Our website may contain links or plug-ins to other sites. We are not responsible for the content of the privacy practice or policies of, those sites.
How can you access and correct your personal information?
You have the right to access your personal information held by Divy. You can also make a request for us to correct any inaccurate, incomplete or out-of-date personal information.
For security reasons, a written request may be required to access your information verifying your identity and specifying what information you require.
We may charge a small fee for the retrieval of your information. We are committed to granting you access to your personal information within a reasonable time frame if it is reasonable and practicable to do so. We will not refuse you access unless there are legal reasons for doing so. In such circumstances, we will explain those reasons to you.
Browsing the Divy website – does the website collect personal information?
Divy does not collect personal information from casual visitors to our website, unless you have voluntarily supplied us with personal information via one of our web forms or via email.
When you visit the website and browse the information it contains, you do so anonymously unless you choose to provide us with information about yourself.
If you do nothing during your visit apart from browse through the website, for example reading pages, viewing images, or downloading information without submitting any personal information, Divy will gather and store information about your visit automatically. This information does not identify you personally.
The information collected automatically may include the domain from which you access the internet, the date and time you access the website, and the internet address of the website from which you linked directly to the website. This information is used as an aggregate form to make the website more useful and attractive to its users.
Information gathered automatically is also for site management and, in the case of suspected unauthorised activity, law enforcement and possible criminal prosecution.
IP Addresses, Cookies, Applets and how Divy uses them
Does Divy use your personal information for marketing and business development purposes?
Divy may use your information for research and development of our services or to send you information about other services offered by us which may be of interest to you. If you would prefer not to receive promotional or other material from us, please let us know by sending an email to Divy and we will respect your request.
Links to other websites
Making a privacy complaint?
Your privacy is important to Divy and we will make every effort to resolve your concerns. To assist us in helping you, we ask you to follow a simple three-step process.
- Gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
- Telephone us on +61 1300 996 709, and we will review your situation and if possible, resolve it straight away.
- If you are not satisfied with our response, Divy may require you to submit your complaint in writing by email at email@example.com with your contact details. Divy will then investigate your complaint and endeavor to respond to you in writing within 30 days of receipt of your written complaint.
If at this stage the matter has not been resolved to your satisfaction, you can telephone the Australian Information Commissioner’s hotline on 1300 363 992 or, if calling from outside Australia, +61 2 9284 9749.
Contact us about privacy
Please direct your privacy related questions and feedback to the Director on +61 1300 996 709 or firstname.lastname@example.org.
Further information on privacy
Further information may be obtained on privacy issues in Australia by visiting the Australian Information Commissioner’s website at www.privacy.gov.au.