Updated 15th June 2023
For our data processing in Australia, we continue to comply with the Australian Privacy Act including its 13 Privacy Principles. For our processing overseas, such as in Europe and especially in the UK, we adhere to both the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and also the retained version of the GDPR as it applies in the UK from 1 January 2021 (the “UK GDPR”).
Where we provide the Services to an organization that is our client (for example your employer), that organisation is the administrator of the service and controls the types of credentials, requirements and information processed by our Services. We therefore process Personal Data to provide hosted recruitment and verification services to the customer who is invariably a data controller. Any Personal Data you submit will be retained by Onboarded for a short but important period of time connected to the purpose we are holding your data for (such as a particular job campaign or series of them) which shall be set out in any data retention and disposal policy we hold from time to time be. After our purpose for holding your personal data has come to an end your data shall be completely removed and extracted from our system and back-ups. We do not seek nor want to hold anyone’s data longer than we need to.
In this case, please direct your data privacy questions to your administrator or the relevant customer representative, as your use of the Services is subject to that organisation’s policies and procedures. We are not responsible for the privacy or security practices of any of our customers which may be different from Onboarded’s privacy practices.
Onboarded does not, at any time, directly or indirectly, disclose, furnish or make accessible to any person, firm, corporation, or other entity, or make use of, any client data other than for the purpose of providing Services to the client.
For us, Personal Data means data which relates to an identified or identifiable natural living person. Importantly, it does not include data where the identity has been removed (anonymous data). Onboarded may collect, use, store different kinds of Personal Data:
We do not as a rule collect Special Categories of Personal Data about you (although on occasion your health and medical data may be relevant or indeed essential to a particular job role). We will comply with the enhanced conditions for processing special category data such as obtaining your explicit consent before we do so.
We also on occasion collect any information about criminal convictions and offences (which is not regarded as a Special Category of Personal Data). We will collect this only when absolutely necessary – where the role warrants such sensitive details to be collected and where we have a legal reason for doing so (where in the UK we shall comply with Schedule 1 of the Data Protection Act 2018).
If you fail to provide Personal Data or click and submit your forms….
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Onboarded website or software application). In this case, we may have to cancel your participation in the job application you are interested in.
HOW DO WE COLLECT PERSONAL DATA?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity, contact, profile and credentials by filling in fields on our forms and online tools, when you register as as user for the first time, or when you communicate with us
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs, and other similar technologies.
Third parties or publicly available sources. We will receive only Minimal Personal Data about you from various third parties and public sources.
Under which legal bases do we collect, use and disclose Personal Data?
We may collect, hold, use and disclose your Personal Data for the following purposes and legal bases:
Onboarded is aware of the modern practice of re-purposing (collecting Personal Data for one reason and then accidentally or not, using it for another). We will only use your Personal Data for the purposes for which we collected it (primarily for use by you, our customers and us for job campaigns and reasons related to the recruitment, vetting and onboarding process), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may also disclose your Personal Data to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymized consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
No. We do not send direct marketing communications and related promotional information about our Services or products to our end users/candidates. In Australia we shall comply with the Spam Act and the Privacy Act when it comes to sending emails, SMS, and other forms of communication. You have full rights to unsubscribe and may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
You may receive marketing communications from us if you have requested information from us or used our Saas solution and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time.
We will disclose your Personal Data to the suppliers of Integrated TPAs as reasonably necessary in connection with the integration of that third party service with our Service. Such information may include Personal Data as referred to in “What Personal Data do we collect?“, which needs to be supplied in order to integrate with the Service.
Onboarded is selective when choosing its Integrated TPAs and takes care to assess the suitability of the third party suppliers, with the goal that all integrations enhance the Services and offer benefits to you. Please note the Integrated TPAs are not owned or controlled by us and we are not responsible for their privacy practices. These third parties who have been granted access to your data may have their own policies and practices for its collection, use and sharing. Please check the Integrated TPAs’ permissions, privacy settings and notices for information about these services or contact the provider with any questions.
|Third Party Integration||Description||Website|
|FastTrack Recruitment Solution||Onboarded integrates with FastTrack360 to pull and push onboarding data for FastTrack360 users||https://fasttrack.com.au/|
|JobAdder||Onboarded integrates with JobAdder to pull and push onboarding data for JobAdder users||https://jobadder.com/|
|Bullhorn||Onboarded integrates with Bullhorn to pull and push onboarding data for Bullhorn users||https://www.bullhorn.com|
|RDB Now||Onboarded integrates with RDB Now to pull and push onboarding data for RDB Now users||https://www.rdbnow.com/|
|ECM||Onboarded integrates with Oncore to pull and push onboarding data for Oncore users||https://www.oncoreservices.com/|
|National Crime Check||Vevo and police check feature is provided by National Crime Check integration||https://www.nationalcrimecheck.com.au/|
|Referoo||Auto work reference Check feature is provided by Referoo integration||https://www.referoo.com.au/|
|Calendly||Interview booking feature is provided through Calendly integration||https://calendly.com/|
|Flare HR||Super choice feature in Onboarded is provided through Flare HR integration||https://www.flarehr.com/|
|smartAI||Onboarded integrates with smartAI to initiate onboarding process from smartAI application||https://smartai.com.au/|
|SMS Messenger||Onboarded sends SMSs to the applicants using SMS Messenger technology||https://smsmessenger.com.au/|
|Esendex||Onboarded sends SMSs to the applicants using Esendex technology||https://www.esendex.com|
|Cloud Converter||Onboarded uses cloud converter’s technology to convert documents into PDF and other formats||https://cloudconvert.com/|
|Checkmate||Onboarded integrates with checkmate to provide background checks||https://www.checkmate.tech/|
|Xero||Onboarded integrates with Xero to push payroll info of a candidate||https://www.xero.com/|
|Astute||Onboarded integrates with Astute to push payroll info of a candidate||https://www.astutepayroll.com/|
|MYOB||Onboarded integrates with MYOB to push payroll info of a candidate||https://www.myob.com/|
As a starting point, our application and servers are set up so that Personal Data is not transferred outside of its jurisdiction of origin i.e. all EU data will reside on our UK server, and all Australian and New Zealand data and any clients outside UK/EU region will reside on our Australian server. It will not be transferred to any of our other locations. Personal Data is pulled out of our clients’ CRM application and pushed back there when the applicant completes and submits the missing fields and credentials relevant to a particular job.
We do acknowledge that many of our external third parties are based outside of Australia in places such as the USA and the UK so there may be on occasions a need to move Personal Data or make it accessible from one place to another. This may involve a transfer of Personal Data outside Australia to the UK, or from the UK to a US partner or integration provider such as cloudconvert.com.
Whenever we transfer your Personal Data out of the UK or Europe from our base there, we ensure a similarly high degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where we use certain service overseas providers, we may use specific contracts approved for use in the UK or Europe which give Personal Data the same protection it has in those jurisdictions. For example in the UK we are pleased to be able to work with the International Data Transfer Agreement regime (IDTA) approved by the Information Commissioner’s Office in the UK in 2022. In Europe we shall use the Standard Contractual Clauses approved by the European Commission (and last updated in 2021).
We may collect Personal Data about you when you use and access our website regardless of which type of device you use.
Onboarded uses (i) Strictly necessary (essential) (ii) Functional (iii) Analytical (measuring performance) and (iv) Tracking/advertising types of cookies.
Cookies may be delivered by us directly to you (first-party cookies) or delivered by one of our partners. Cookies can be either session cookies or persistent cookies. Session cookies enable sites to recognise and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognise you and these are stored on your system or device until they expire, although you can delete them before the expiry date.
For our Saas Solution:
For our websites:
What other similar technologies does Onboarded use?
Onboarded uses certain tools for basic font usage and to understand email-opening statistics by recipients of our emails). These help us to gauge the effectiveness of certain communications, promotions and marketing campaigns.
How you can take control of cookies and similar technologies
You have rights to manage and turn off/on certain cookies as you wish from your browser settings but you may not be able to use our applications or features of our sites if cookies are disabled.
In light of changes to cookies practices in 2021 (with respect to the disablement of third party cookies on some browsers) we include below an updated list of the more popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:
For our Product (platform): We store information in cookies such as a user has seen our help pop up page and has acknowledge it to ensure we don’t show the same pop up again next time they log on.
For our websites: We use Google Analytics tools and we may remarket our services to you in a targeted way, by using third party remarketing services such as Google Ads or similar
For more information on the main cookies currently used, their purpose and their duration please get in touch with us at firstname.lastname@example.org
We may hold your Personal Data in either electronic or hard copy form. We take reasonable steps to protect your Personal Data from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Data. For example, we host data on Tier 1 cloud platform that provides a secure foundation across physical, infrastructure, and operational security. We have conducted successful security pen test of our application and have mitigated any high level vulnerabilities identified. However, we cannot guarantee the security of your Personal Data.
We have put in place appropriate Company policies (such as Information Security Policy, IT Policy Document and Major Incident Management policy) plus practical security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are required to do so.
As a business and employer, we will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain some Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
As a data processor and provider of an app and Saas solution, details of retention periods for the Personal Data on our Saas solution will be contained in any data retention and disposals policy we hold.
Once the data is collected, it is integrated back into a customer’s CRM solution or applicant tracking system. As a default we expunge everyone’s data after 30 days of importing it back into their CRM system or applicant tracking system.
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained.
You have the right to:
Request access to your Personal Data (increasingly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Otherwise in most cases, we have enabled a feature where a user’s Personal Data (and entire profile) can be erased from our entire Saas solution and support systems within 24 hours of approval/marking for deletion.
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can access the Personal Data we hold about you by contacting the appropriate customer or employer in the first instance. If you come to us directly, we may not be able to provide you with access to all of your Personal Data but if this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Data.
If you think that any Personal Data we hold about you is inaccurate, please contact the appropriate Onboarded customer or employer in the first place (and us at the same time if you wish) and either they or us will take reasonable steps to ensure that those records are corrected.
First Stage – If you think we have breached the Privacy Act or the GDPR, or you wish to make a complaint about the way we have handled your Personal Data, please contact us first using the contact details below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Second Stage – Should you be dissatisfied with the service we provide in the UK you have the right to file a formal complaint to the Information Commissioner’s Office at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence. The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by telephone on 0303 123 1113 or 01625 545 745.
612 101 Overton Road
Williams Landing Vic 3027
Phone: +61 411 410810