At Coles, we respect the privacy of your personal information in our care. Personal information means information which identifies you as an individual or from which you can be reasonably identified.
This Policy outlines:
- our commitment to securely manage your personal information in a fair and transparent manner;
- why we collect your personal information, what personal information we collect, how we handle your information and when it may be disclosed outside of Coles; and
- your responsibilities and obligations when you handle any other team member’s personal information.
2. Policy Application
Business needs means those functions or duties requiring access to team members’ personal information that are necessary to carry out Coles business functions to comply with applicable laws, or to administer People and Culture related functions. Examples of business needs include:
- administration of Coles workforce, such as team member records maintenance, training administration, transfer, employment terminations, issuing of pay, etc.;
- a requirement by law (statute, regulation or court ruling) or contract; or
- an emergency, which is reasonably believed by Coles to pose a risk of harm to a person, property, or the business interests of Coles.
Candidate refers to anyone who applies for a job role, or who otherwise seeks to work with or for us (whether on a permanent or non-permanent basis).
Coles refers to all Coles group companies and divisions including Supermarkets (Coles Supermarkets, Coles Online, Coles Financial Services, Coles Local), Coles Liquor (Liquorland, First Choice, Vintage Cellars, First Choice Liquor Market), and Coles Convenience (Coles Express).
Personal information (PI) means any information or opinion relating to an identified current team member or previous team member who is reasonably identifiable. Examples of a team member’s personal information include, but are not limited to:
- name; date of birth; email or postal address; telephone number; employee number;
- education qualifications; professional licenses; memberships of professional associations;
- referee details and reference notes;
- right to work checking (including work visa, passport information, declared conflicts of interest, security checks including police);
- interview transcripts or recordings;
- medical checks;
- letters of offer, acceptance of employment, and contract details;
- payroll information (including banking details, salary, Tax File Number); wage and benefit information; or
- family information including emergency contact details.
Team member means an individual who is or was employed on a permanent, fixed term or casual basis by Coles, including contractors.
4. Policy Requirements
Coles is subject to the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Privacy Act). The APPs set the minimum standards which relate to the collection, security, storage, use, correction and disclosure of personal information and access to that information. This policy tells you in general terms what our commitment is for recruitment-related information: why we need to collect personal information, what personal information we collect, how we handle it and who we may disclose it to (outside of Coles).
(a) How does Coles collect personal information?
Coles collects and maintains different types of personal information, including but not limited to:
- name, date of birth, email address, phone number, contact details;
- resumes that may include employment history, education qualifications, professional licenses, membership of professional associations;
- interview notes, photographs and videos;
- results of aptitude and psychometric tests;
- letters of offer and acceptance of employment;
- pre-employment checks (including working rights, pre-employment medicals, character/criminal record checks etc.).
Your personal information (including sensitive information) may be collected via your application form, resume, cover letter, recruitment agency reports during interviews and telephone calls, written correspondence, and sometimes from publicly available sources such as LinkedIn or other social media sites.
We may also collect information from third parties (e.g. the completion of employment reference checks). These third parties may have their own privacy policies that address how they handle personal information.
(b) Use of personal information
Personal information is typically collected and used for business needs associated with your recruitment and pre-employment relationship with Coles. This may include determining eligibility for initial employment, including the verification of references and qualifications.
(c) How does Coles protect the personal information that it holds?
We hold personal information electronically and in hard copy, both at our own premises and with the assistance of our service providers. We implement a range of measures, including people, process and technology controls, to protect the security of your personal information. Our security controls are continually reviewed to ensure that the protection of your personal information is maintained. Examples of these measures include:
- access to personal information is controlled through access and identity management systems;
- internal information security policies requiring Coles team members and third party service providers to keep personal information secure at all times;
- taking steps to protect personal information in accordance with the Office of the Information Commissioner’s (OAIC) Guide to Securing Personal Information; and
- taking measures in respect of destroying or de-identifying personal information that is no longer needed for any lawful purpose.
(d) What if I choose not to provide the information requested?
If you choose not to provide certain personal information, we may not be able to progress your application, or provide you with direct correspondence regarding employment opportunities at Coles.
(e) Workplace privacy
(f) Disclosure of personal information
Your personal information will be shared with Coles team members, recruitment agencies, and other third parties who are engaged to provide recruitment services on our behalf.
Some of the technology service providers that hold and process candidates’ personal information may have data centres located outside Australia. While it is not reasonably practicable to list all countries to which your personal information may be disclosed from time to time, it is likely that such countries may include the Germany, New Zealand, the Philippines, Singapore, and the United States.
When we disclose your information overseas, we take steps to ensure that our technology service providers are obliged to protect the privacy and security of your personal information in accordance to the standards that apply in Australia, including that they only use personal information for the purpose for which it is disclosed.
(g) Access to or correction of personal information
You agree to provide your personal information, which is in all respects true, accurate and up to date and is not, in any respect, misleading, deceptive or inaccurate or likely to be misleading or deceptive. You are encouraged to help us keep your personal information accurate, complete, and up-to-date by updating your profile on our Coles careers website when applying for an advertised vacancy, or when updating your expression of interest registration preferences.
Coles will provide a candidate access to records containing personal information about them upon written request by the candidate, except where the request is frivolous or vexatious, or where providing access would:
- pose a serious and imminent threat to the life or health of any individual;
- compromise the integrity of the talent, performance management and succession planning process;
- have an unreasonable impact upon the privacy of other individuals;
- reveal the intentions of Coles in relation to negotiations with the candidate in such a way as to prejudice those negotiations;
- be inconsistent with any law or regulation; or
- be likely to prejudice the outcome of an internal investigation or be contrary to Coles interests.
Under the Privacy Act and other relevant laws, we are required to provide a written response outlining our reasons if we refuse your request.
If you are still not satisfied, you can contact the Office of the Australian Information Commissioner, whose contact details are set out below. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.
5. Candidate privacy enquiries and complaints
If you have any queries or concerns relating to the handling of your personal information, please contact firstname.lastname@example.org. If you are not satisfied with their response, please contact the Privacy Officer at email@example.com or details set out below.
The Privacy Officer will oversee the management of any enquiry and complaint and be in contact with you within 30 days of receipt.
If you are still not satisfied, you can contact the Office of the Australian Information Commissioner, whose contact details are set out below.
Queries regarding privacy should be directed to the Coles Privacy Officer:
Phone: 1800 061 562
Post: 800 Toorak Road, Hawthorn East VIC 3123
Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
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