Last updated: 25 May 2018

INTRODUCTION

We are committed to protecting the privacy and confidentiality of information we collect, and value our users and recognise their right to keep personal information private.

This statement explains our data collection policy and practices. This policy is updated from time to time without notice, so please check back regularly. All updates will be published on this site.

If you have questions about this policy, you can contact us.

COLLECTION

We may ask you for information that personally identifies you, allows us to contact you to provide a product or service, and/or carry out transactions such as providing information or acquiring our products or services. Information collected may include:

• Personal information (e.g. name, e-mail, work or home phone numbers, home address, pay details, banking information, police check information, identification verification documents and related information).
• Current and past work-related information (e.g. employment applications, engagement titles, engagement functions, contract details, employer details, workplace address, reference information and engagement reviews).
• Social media information (e.g. professional connections, communications, employment history, articles, groups, applications, endorsements and referrals).
• Website and internet information (e.g. unique identifiers, IP address, location, browser type and settings, device type, operating system, mobile network information, log-in details and referrer URL of your request).

PURPOSE OF COLLECTION

We use information that we collect to interact with you directly, to provide products or services, and/or carry out any transactions you have requested or authorised. In support of these uses, we may use personal information to provide you with a more effective engagement service, perform statistical research, review engagements and/or improve our products or services.

CONTROL OF YOUR PERSONAL INFORMATION

Except as otherwise described in this policy, personal information you provide to us will not be used or made available to third parties without your permission. As described in the following, you can access your personal information and make choices about how you wish to be contacted.

ACCESS TO YOUR PERSONAL INFORMATION

You may request access to personal information that we hold on you to:

• Request changes are made to the personal information you have already given us.
• Tell us whether you want us to send you marketing information.
• Subscribe or cancel subscriptions and/or updates about our services and products.
• Request we delete information (except where doing so will breach regulatory compliance or legal obligations).

SECURITY OF YOUR PERSONAL INFORMATION

All reasonable steps are taken to protect the information from loss, misuse, unauthorised access, disclosure, alteration, and destruction of digital, paper-based and other records.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality and privacy of any personal information held by us.

You can also play an important role in keeping your personal information secure, by maintaining the confidentiality of any password and accounts used on the Site. Please notify us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account.

SECURITY BREACHES

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure.

In the event of a data breach, Inner Circle is committed to complying with the requirements of all Australian Privacy Laws including the requirements of the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth).

If a breach causes an unauthorised intrusion into our system that materially affects you or your organisation’s information, then we will notify you as soon as possible and later report the action we took in response. Except in the case of breaches of our obligations under the Privacy Act to protect your personal information, we will not be held responsible for events arising from unauthorised access of your personal information.

DATA STORAGE

Inner Circle servers and data are securely stored in geo-redundant datacentres in the Australasia region. We rely on enterprise solutions like Microsoft Azure to safeguard the physical and technical security of your information, and have organisational controls to limit access to, and to protect your information.

COOKIES

To improve our website and communications platforms, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone and is stored on your device’s hard drive. The cookie records information relating to your internet activity (such as whether you have visited our website before).

We use three types of cookies: analytics, user-input and authentication.

• Analytics includes Google Analytics cookies that anonymously collect details on your internet browsing. This includes how you found our site, the time spent on pages, the sequence of pages you visited and the type of device you used. This information is completely anonymous and allows us to better refine our digital communications to suit browsing habits. For information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.
• User-input cookies are used to keep track of your data when completing online forms. For example, if you complete a form to access data or downloads, we need to know that you have completed the appropriate form to provide you with the correct access.
• Authentication cookies are used to verify log-ins when approved individuals log into specific sections of our site. They typically remain in place for the duration of the visit. Authentication cookies remove the need for you to log back in every time you change or refresh pages.

You can block cookies by adjusting your internet browser settings to not accept them. Your web browser’s help file should show you how to do this. You can find further information on this at https://www.aboutcookies.org, along with details on how you can delete cookies which are already stored on your device. Note, if your browser is set to reject cookies, your ability to access or us some of the functionality of our platforms may be restricted.

THIRD PARTIES

We may hire third parties to provide limited services on our behalf, such as web site hosting, software hosting, data warehousing, communications, packaging, mailing and delivering products and services, and providing functions needed to deliver, improve or promote our products and other services, and/or those needed to meet our compliance requirements.

We will only provide third parties with the personal information they need to deliver such services. Third parties are required to maintain the confidentiality of the information and are prohibited from using that information for any other purpose. Where we transfer information to persons outside Australia, we take reasonable steps to ensure they do not breach the Australian Privacy Principles in relation to that information.

MINORS

Inner Circle does not produce digital communications designed for individuals 18 years of age or younger. As such, we will never intentionally collect information about anyone under the age of 18 years.

EXCLUSIONS

This Policy does not apply to any information you may disclose publicly in any chat rooms, message boards, forums, online meetings, collaborative applications or similar online interactions, including those hosted on, or linked to, our digital communications platforms. When you publicly disclose information about yourself online on public or third-party platforms, information can be collected and used by people whom you do not know. Our privacy policy does not apply to public or third party accessible information, and we accept no responsibility for any action by third parties who collect information in this instance.

POLICY CHANGES

We regularly review and update this policy to ensure we meet and/or exceed our regulatory compliance requirements. We will not reduce your rights under this policy without your explicit consent and will always indicate the date when the last changes were published. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of policy changes).

CONTACTING US

If you have any queries concerning any aspect of this policy or our practices, or a concern or complaint please contact our Privacy Officer or write to:

Privacy Officer
Inner Circle Consulting Pty Ltd
Suite 301, 477 Collins Street
Melbourne Victoria 3000 Australia