Privacy Policy

  1. Last updated

7 May 2024

 

  1. Privacy Policy

This Privacy Policy describes how Affinity Nursing Recruitment Ltd Pty Affinity Trust (“we”, “us”, or “our”) and all reporting entities, hereby collectively known as Affinity, complies with both the Privacy Policy 1998 (Cth) and the Information Privacy Act 2009 (Qld) with regards to the collection, management, protection, access, storage, and use of Personal Information and how this relates to our primary business functions.  

For the purposes of the Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a candidate, client, website visitor, or other individual whose information is collected pursuant to the Privacy Policy.

Affinity is committed to ensuring that the privacy and security of all Personal Information collected through the course of our Services complies with all relevant legislation and regulations.

Please read this Privacy Policy carefully.  By using and accessing any of Affinity’s Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of our Services.

 

  1. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices for other operational, legal, or regulatory reasons.  We will post the revised Privacy Policy, update the “Last updated” date, and take any other steps required by applicable law.

 

  1. About Affinity

Affinity’s primary business function (also known as “Services”) is the supply of healthcare solutions (nurses, midwives, medical practitioners, collectively known as “Candidates”) to government and private health care facilities under a range of supply arrangements.

All entities under Affinity Nursing Recruitment are subject to this policy. 

Affinity considers its Services as related to this policy where we collect, store and share identified Personal Information, which includes, but is not limited to:

    • Recruitment, selection, and onboarding functions
    • Role matching and fulfilment
    • Client, candidate, and employee relationship management functions
    • Marketing and branding functions
    • Invoicing, payroll, and accounts payable functions
    • Accessing and making online purchases via our Learning Management System (Affinity Clinical Education).
    • Any activity related to the engagement of external vendors and suppliers to provide Services and products to Affinity.

 

  1. Why we collect Personal Information

The nature of Personal Information collected by Affinity is that which is required to perform our Services and to ensure we comply with various contractual, legislative and government reporting requirements. Healthcare Candidates are subject to stringent compliance and regulatory requirements to ensure that the risk of providing healthcare to vulnerable individuals and groups in our community is known and managed.   

For example, we are contractually obligated to provide Personal Information to clients to ensure Candidates have the training, skills, workplace checks and regulatory licences to undertake work with them.

It is entirely your choice to provide the information that we have requested of you. If you do not provide us with the information we request, we may not be able to fulfil our primary business function and provide you the Service that you require.

 

  1. What information is collected by Affinity?

The type of Personal Information we obtain about you depends on how you interact with us, our Site, how you use our Services, and the relationship we have with you. 

We collect the following information:

Health information about the individual relating to health, disabilities, used for reporting purposes, and to make assessments of the physical capability of an individual to perform a particular role.

Personal Information refers to information that identifies, relates to, describes, or can be associated with you. 

Sensitive information includes information about an individual’s criminal record, sexual orientation, racial or ethnic origin.  Affinity will only collect Sensitive information that is necessary, for due diligence or other reporting reasons and not for the purposes of discrimination of any kind.

All information will be hereby described as Personal Information.

The following sections describe the categories and specific types of Personal Information we collect. Affinity will only request and collect essential Personal Information to be shared with us that we deem essential to fulfil our Services, and we will only share the minimum amount of Personal Information where it relates to our Services. 

 

6.1 Information we collect directly from you

Information that you directly submit to us through our Services may include:

    • Basic contact details including your name, address, phone number, email, date of birth.
    • Identification documents
    • References
    • Working rights information
    • Information about prior employment, including resume and Statements of Service.
    • Professional association or regulation information
    • Worker screening checks, including criminal history check
    • Qualifications, evidence of training and professional development
    • Banking, payslips, superannuation, and taxation information
    • Order and purchase information including items you view, put in your cart, or add to your Wishlist.
    • Online purchase account information including your username, password, and security questions.
    • Sensitive or Health Information, for example Indigenous status, fitness for work information.

You are not obligated or required to supply any Personal Information with Affinity that is not specifically requested.  If you provide Affinity with unnecessary/unrequested Personal Information, Affinity may choose to destroy this Personal Information as per our Data Disposal Policy. 

 

6.2 Information we collect through cookies

We also automatically collect certain information about your interaction with the online and web-based Services (“Usage Data”). To do this, we may use cookies, pixels, and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

 

6.3 Information we obtain from third parties

Finally, we may obtain information about you from third parties, including from government agencies, vendors and Service providers who may collect information on our behalf, such as:

    • Healthcare facilities, prior/current employers
    • Australian Health Practitioner Regulation Agency
    • Australian Taxation Office
    • Government agencies
    • Department of Foreign Affairs
    • Work Cover agencies
    • Companies who host, support, or provide Sites and Services.
    • Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your wages/invoices, or your payment to fulfill your orders and provide you with products or Services you have requested, in order to perform our contract with you.
    • When you visit our Site, open, or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.

 

  1. How we use your Personal Information

Your Personal Information is utilized for the express purpose of fulfilling our Services:

Recruitment, selection, onboarding, and role matching Services: We use your Personal Information to undertake due diligence to ensure you have the skills, qualifications, screening, and experience to fulfill the requirements of a role.  This includes contacting referees, sharing your employment history and worker screening checks with clients.

Providing products and Services: We use your Personal Information to provide you with the Services in order to perform our contract with you, including processing your payments or wages, fulfill your orders, sending notifications to you related to your timesheet, account, purchases, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for travel or shipping, facilitate any exchanges and to enable you to post reviews.

Marketing and advertising: We use your Personal Information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or Services. This may include using your Personal Information to better tailor the Services and advertising on our Site and other websites.

Security and fraud prevention: We use your Personal Information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

Communicating with you: We use your Personal Information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective Services to you, and to maintain our business relationship with you.

 

8.1 Cookies

Like many websites, we use Cookies on our Sites. We use Cookies to power and improve our Site and our Services (including tracking your actions and preferences across our Services), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and Services providers to use Cookies on our Site to better tailor the Services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

 

  1. How we disclose Personal Information

In certain circumstances, we may disclose your Personal Information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

    • Undertaking worker screening checks.
    • Collecting references which validate your clinical competence and professional conduct.
    • With vendors or other third parties who perform Services on our behalf (e.g., customer relationship management systems, IT management, payment processing, data analytics, customer support, cloud storage, fulfillment, and shipping).
    • With business and marketing partners to provide Services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
    • When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to arrange travel and accommodation, ship you products or through your use of social media widgets or login integrations, with your consent.
    • With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
    • In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations or enforcement request (including to respond to subpoenas, search warrants, court orders, and similar requests), to enforce any applicable terms of Service, and to protect or defend the Services, our rights, and the rights of our users or others.
    • Where we or another party are obligated to make a mandatory notification to a relevant health regulation agency about the performance/conduct of a registered health practitioner.

 

  1. User generated content

The Services may enable you to post product and Service reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

 

  1. Third party websites and links

Our Services or Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

 

  1. No services for minors

The Services are not intended to be used by minors, and we do not knowingly collect any Personal Information about minors. If you are the parent or guardian of a minor who has provided us with their Personal Information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) Personal Information of individuals under 18 years of age.

 

  1. Security and retention of your Personal Information

Personal Information collected by us will be managed confidentially and securely with Affinity employing appropriate and reasonable security controls and monitoring to prevent the loss, misuse, or alteration of Personal Information.  These processes are described in Affinity’s relevant data and cyber security policies.  Despite taking all reasonable and appropriate controls and protections, we cannot provide an absolute security guarantee.    

We will retain personal information for as long as you account remains active, are engaged with our services, as long as legally/contractually required, or as long as is necessary to fulfil the purposes for which the Personal Information was collected to provide the Service. Personal information that does not meet any of these requirements will be disposed of as per our Data Disposal Policy.

 

  1. Your rights and choices

Depending on where you live, you may have some or all of the rights listed below in relation to your Personal Information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

Right to access / know You may have a right to request access to Personal Information that we hold about you, including details relating to the ways in which we use and share your information.

Right to delete You may have a right to request that we delete Personal Information we maintain about you.

Right to correct You may have a right to request that we correct inaccurate Personal Information we maintain about you. We require up-to-date relevant Personal Information so may ask for updated information from time to time, in which case out of date Personal Information will be disposed.

Right of portability You may have a right to receive a copy of the Personal Information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

Right to limit use and disclosure of Sensitive Personal Information You may have a right to direct us to limit our use and/or disclosure of Sensitive Personal Information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.

Withdrawal of consent. Where we rely on consent to process your Personal Information, you may have the right to withdraw this consent. Please note that while you may withdraw consent at any time, this will restrict or inhibit the way we provide our Services to you.

Appeal You have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.

Managing communication preferences We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. 

We will respond to your request in a timely manner as required under applicable law.

Our Service may include links to other websites whose privacy practices may differ to ours as described in this Privacy Policy. If you submit Personal Information to any of these sites, your information will be governed by the applicable third party’s privacy policies and we are not responsible for it. We therefore encourage you to read any notices provided by any website you visit and raise questions directly with these other providers.

 

  1. Complaints

If you have complaints about how we process your Personal Information as described in this Privacy Policy, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.

 

  1. International users

We may disclose or transfer your Personal Information with/to suppliers and service providers located overseas for the purposes listed above.  When doing so we will take reasonable steps to ensure that the overseas recipients do not breach the privacy obligations relating to your Personal Information.

We may disclose your information to our external IT and data providers and centres located in and outside of Australia but not limited to the following:

    • Our data hosting and other IT service providers located in Australia, the US, France, Japan, and Germany.

 

  1. Disclaimer

Our Services and websites are governed in accordance with the laws of Australia. The Australian courts shall have exclusive justification over any dispute arising out of use of this website. The Affinity Nursing Recruitment website is owned by Affinity Nursing Recruitment Pty Ltd.

 

  1. Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, email us at info@affinitynursing.com.au, or PO Box 8368, Woolloongabba, QLD, 4102.