Introduction
This privacy policy applies to First Advantage Australia Pty Ltd ABN 67 101 863 209 and First Advantage New Zealand Limited [NZBN 9429034295540] (“First Advantage”, “we”, “us” or “our”). First Advantage provides a background screening service for its clients to assist them in making important decisions about their customers, employees, job applicants and other stakeholders in line with the Australian Privacy Principles and/or the New Zealand Information Privacy Principles.
Protecting your privacy is important to us. This policy sets out how we manage your personal information. It also sets out your rights in relation to the personal information we hold about you when you deal with us in Australia or New Zealand.
Types of Personal Information We Collect
We collect different types of personal information depending on how you interact with us. If we are conducting background screening, the personal information we collect will depend on the type of background screening we are performing and the location where you live. In some circumstances, we may also collect sensitive personal information about you. The kinds of personal information that we collect about you may include:
- Identifying information – such as your name, gender, photograph and date of birth.
- Contact information – such as your postal address, email address and telephone number.
- Financial information – such as credit card, bank account or other payment details.
- Background-check information – such as your employment history, reference information, education, professional qualifications, residency, sanctions, criminal records, immigration status, claims, judgments, insolvency, current and previous directorships, character and personal reputation (including social media information) and medical assessments.
- Usage information – information we collect when you use our website, such as server log information (your IP address, browser type, operating system, browser language, time zone, access times and any referring addresses).
- Other information – this includes information about any products or services that we provide using your information, communications with you (including any messages you send us) and other information you voluntarily provide to us.
Without this information listed above, we may not be able to provide our services. We also require this information to offer the features and functionality of our website and other online products, and to respond to queries or requests that you submit to us.
How We Collect Your Personal Information
We collect personal information about you:
- directly from you, including as part of background screening, when you submit a query or request to us or when you apply for a job with us;
- from our clients, including where we are engaged to periodically screen a client’s employees or contractors;
- when we are engaged to provide background screening services:
- from third parties who are entitled to disclose that information to us, such as government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, insolvency registers, educational institutions, current and/or previous employers, regulatory and licensing bodies and medical assessment providers; and
- from public sources, such as social media and through search engine searches; and
- by tracking your use of our website.
If we are conducting background screening on you, we will inform you of our background screening process and the types of information we collect when conducting a background check. In some cases, we will ask for your express consent for the collection of sensitive personal information.
How We Use Your Personal Information
We use the personal information that we collect about you for the following purposes:
- to verify your identity when you are dealing with us;
- to enable us to provide our products and services to you or one of our clients, including our background screening services;
- to answer your queries and requests;
- to comply with our legal and regulatory obligations;
- to assess, maintain, upgrade and improve our products and services;
- to carry out education and training programs for our staff;
- to manage and resolve any legal or commercial complaints or issues; and
- to keep you informed about our activities, including by sending out newsletters.
We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at privacy.sapac@fadv.com or following the “unsubscribe” link in the communication.
We may also use your information for other purposes if you ask or tell us to do so.
Who We Share Your Personal Information With
We may share personal information about you with:
- our clients when we report back to them after we complete a background check on you;
- your representatives, advisers and others you have authorised to interact with us on your behalf;
- our staff who need the information to discharge their duties;
- related entities within our corporate group;
- our business partners, agents and service providers;
- prospective purchasers of all or part of our business or shares in our company or a related entity;
- professional advisers who we engage to provide advice on our business;
- government authorities who ask us to disclose that information, or to other people as required by law; and
- third parties who we use to help us provide our background screening services, such as government agencies, law enforcement bodies, educational institutions, current and/or previous employers and medical assessment providers
If we need to disclose personal information to third parties in a different country to where the information was collected, we will take steps to ensure that there is a lawful basis for the disclosure and that the disclosure complies with all applicable laws. This may include entering into a legally binding contract with the recipient under which they are obliged to handle your information in accordance with applicable laws.
How We Store and Protect Your Personal Information
We use various secure computer systems located both within and outside of Australia and New Zealand to store your personal information. Our employees located outside Australia and New Zealand may undertake various components of background checks. As a result, we may transfer your personal information to our affiliates located in countries including Australia, Canada, India, the Netherlands, New Zealand, the Philippines, the USA or the UK.
We store personal information for as long as it is needed for the purpose for which it was collected, or as required by law. We generally store the personal information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal information in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats.
We ensure that our staff are aware of and properly trained in their obligations for managing your privacy. We limit access to personal information to those of our employees who require access in order to carry out their job responsibilities.
Access and Correction of Your Personal Information
We take reasonable steps to ensure that any personal information which we hold about you is accurate, complete and up-to-date, including promptly updating personal information when we are advised that the information has changed.
If you want to access any of the personal information that we hold about you or to correct some aspect of it (e.g. because you think it is incomplete or incorrect), please contact us using the details below.
There is no charge if you request access to your personal information, but we may require you to pay our reasonable costs in actually providing you with access. We will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality obligations. In these cases, we will let you know why we cannot comply with your request.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information if you so request. We may be unable to correct information about you if doing so would be contrary to law or impact the integrity of a product or service that we provide.
Updates To This Policy
This policy will be updated where necessary to reflect changes in applicable laws or in our privacy compliance practices. The latest version of this policy will always be available on our website
How You Can Contact Us
If you are concerned about the way in which we are managing your personal information, please contact our Privacy Officer at:
The Privacy Officer
First Advantage
PO Box R1783
Royal Exchange NSW 1225
Australia
Email: privacy.sapac@fadv.com
Complaints must be lodged in writing. We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.
If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You are also entitled to make a complaint to the Privacy Commissioner in your country:
For Australia
Website: www.privacy.gov.au
Email: enquiries@oaic.gov.au
Telephone: 1300 363 992 or +61 2 9284 9749
For New Zealand
Website: www.privacy.org.au
Email: enquiries@privacy.org.nz
Telephone: 0800 803 909 or +64 4 474 7590