Preamble
Pathways International Consulting Pty Ltd (also referred to in this document as “the company”) respects individuals’ right to privacy over personal information it maintains in its possession, and it has adopted as a matter of policy and will, where appropriate, generally comply with the National Privacy Principles as set out in that Act.

The National Privacy Principles are annexed as Appendix A to this Privacy Policy.

Personal information
Pathways International Consulting Pty Ltd collects and holds information, which includes but is not limited to personal information including sensitive information, about:

  • Employees of Pathways International Consulting Pty Ltd;
  • Contractors associated with Pathways International Consulting Pty Ltd;
  • Job applicants for positions which Pathways International Consulting Pty Ltd is engaged as recruiter, selection facilitator or is conducting an executive search;
  • Job applicants who register their interest in particular positions with Pathways International Consulting Pty Ltd;
  • Clients;
  • Other people who come into contact with Pathways International Consulting Pty Ltd.

Pathways International Consulting Pty Ltd generally collects personal information of staff members, job applicants, contractors, clients and others by way of completed forms, face‐to‐face meetings, interviews, telephone calls or electronic mail. With the prior consent of the individual, Pathways International Consulting Pty Ltd may be provided with personal
information about the individual from a third party, for example, a report provided by a medical professional or references from nominated referees.

Exception
Employee records
Under the Privacy Amendment (Private Sector) Act 2000 (Commonwealth), the National Privacy Principles do not apply to an employee record. As a result, this Privacy Policy does not apply to the Pathways International Consulting Pty Ltd’s treatment of an employee record, where treatment is directly related to a current or former employment relationship between the company and employee.

Collection of information
At the time of collecting information Pathways International Consulting Pty Ltd will advise the individual about whom information is being collected, of the following:

  • The contact details of the company;
  • The individual’s right to access their own information;
  • The purpose for which the information is collected;
  • The organizations to which that information may or will be disclosed;
  • Any law which requires the collections of the information; and
  • The main consequences (if any) if the individual chooses to not provide the information to the company in the particular circumstances.

Pathways International Consulting Pty Ltd will inform individuals either directly or on the required collection proforma (e.g. Job Application Form) that information about them may be sought from other individuals not nominated as their official referees when this is considered helpful in the selection process for employment.
Use of personal information
Pathways International Consulting Pty Ltd will only use or disclose personal information it holds about an individual for the primary purpose of collection of such information and for such other secondary purposes as are related to the primary purpose of collection and which could reasonably be expected, or for which consent has been obtained.

Staff members
In relation to the personal information of staff members, Pathways International Consulting Pty Ltd’s primary purposes of collection include:

  • the discharge of its legal obligations under various state and federal statutes;
  • the administration of the individual’s employment contract;
  • insurance and Occupational Health and Safety purposes.

Job applicants and contract tenderers
In relation to personal information of job applicants and contract tenderers, Pathways International Consulting Pty Ltd’s primary purpose of collection is to assess and (if
successful) to engage the applicant or contractor, as the case may be if the position in question is with the company. Where Pathways International Consulting Pty Ltd is acting as
the recruiting agent for a third party (client) the information will be used to assist the client in the selection process. The purposes for which Pathways International Consulting Pty Ltd uses personal information of job applicants and contract tenderers therefore includes:

  • evaluation of applications and tenders;
  • satisfying legal obligations.

Clients
The company may obtain personal information about its clients who are recipients of
services. This information will be used to enable Pathways International Consulting Pty
Ltd to render a service which best matches the needs of the client and thereby allows the
company to meet the aims and objectives of its mission.

Marketing
Pathways International Consulting Pty Ltd treats marketing as an important part of its
business operation and its service to clients in order to achieve the aims and objectives of
its mission. Personal information held by Pathways International Consulting Pty Ltd may
be disclosed, where consent has been obtained, in ways that assist in Pathways
International Consulting Pty Ltd’s marketing activities.

Pathways International Consulting Pty Ltd’s publications such as newsletters and
magazines, which may include personal information from time to time (with permission),
may be used for marketing and information purposes with clients.

Disclosure of personal information
Pathways International Consulting Pty Ltd may disclose personal information, including
sensitive information, held about an individual to:
 government departments;
 medical practitioners in life threatening situations;
 people providing services to Pathways International Consulting Pty Ltd;
 recipients of company publications, such as newsletters and magazines;
 anyone appropriately authorised
 bodies with legal entitlements to the information.

When relevant, the individual’s consent will be obtained prior to the disclosure of personal
information.

Sending information overseas
Pathways International Consulting Pty Ltd will not send personal information about an
individual outside Australia without obtaining the consent of the individual (in some cases
consent will be implied) or otherwise complying with the National Privacy Principles.

The treatment of sensitive information
In referring to ‘sensitive information’, Pathways International Consulting Pty Ltd means
information or opinion about an individual’s racial or ethnic origin, political opinions,
membership of a political association, religious beliefs or affiliations, philosophical beliefs,
membership of a professional or trade association, membership of a trade union,, sexual
preferences or practices, criminal record or health information about an individual.

Sensitive information will be used and disclosed only for the purpose for which it was
provided or a directly related secondary purpose, unless the individual to whom the
information applies agrees otherwise, or the law allows the use or disclosure of the
sensitive information.

Management and security of personal information
Pathways International Consulting Pty Ltd’s staff are required to respect the confidentiality
of personal information and the privacy of individuals. The company has in place steps to
protect the personal information it holds from misuse, loss, unauthorised access,
modification or disclosure by use of various methods including locked storage of paper
records and pass worded access rights to computerised records.

Updating personal information
Pathways International Consulting Pty Ltd endeavours to ensure that personal information
it holds is accurate, complete and up‐to‐date. Individuals may seek to update their
personal information by contacting the Principal Consultant in writing at any time. The
National Privacy Principles require the company not to store personal information longer
than necessary.

The right to check what personal information is held by Pathways International
Consulting Pty Ltd
Individuals have the right to obtain access to any personal information that the company
holds about them and to advise the company of any perceived inaccuracy with some
limited exceptions. Requests to access any information the company holds should be
directed to the Principal Consultant in writing.

Pathways International Consulting Pty Ltd may verify an applicant’s identity and specify
what information it will provide. A fee may be charged to cover the cost of verifying
applications and locating, retrieving, reviewing and copying material requested. If the
information sought is extensive, the company will advise the likely cost in advance.

Dennis Doherty
Principal Consultant
Pathways International Consulting Pty Ltd
September 2013