RUSELL PERFORMANCE CO
PRIVACY AND DATA RETENTION POLICY
This Privacy and Data Retention Policy (PDR) constitutes RPCo’s privacy and data retention policy. It outlines how RPCo protects your privacy rights and upholds its obligations under privacy law, when handling your personal information.
The PDR lets you know what personal information of yours we hold, what we do with it, who we will disclose it to and how you can access the personal information we hold about you. In the course of our activities, we undertake research throughout Australia, and where it is applicable, we adhere and are subject to the relevant state and territory privacy legislation.
PRIVACY
We take privacy very seriously at RPCo.
As part of our professional engagements and research, we are likely to collect your personal information. The Privacy Act defines personal information as: “information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.”
We collect different types of personal information depending on the nature of our engagement with you from a number of different sources, including:
directly from you or your authorised representatives
when you use our products or services, including our online services
from outside sources and third parties.
The primary purpose of our collecting personal information is to provide consultancy products and services. We seek to limit the amount of information we collect at all times and will only use your personal information if we have a lawful reason to do so.
HOLDING PERSONAL INFORMATION
We value the security of your personal information and have systems in place to protect it.
We hold personal information in electronic formats. RPCo will endeavour to take all reasonable steps to secure any information we hold about you and keep it accurate and current. We also require our employees, consultants, and others (such as external parties used by RPCo to deliver services) to respect the confidentiality of any personal information held by RPCo.
In some cases, we engage third parties to host electronic data (including data related to the services we provide) on our behalf. We take security measures to protect our information, including technological controls (for example, access restrictions, firewalls, encryption, passwords, and digital certificates).
PERSONAL INFORMATION WE COLLECT
The types of personal information we collect depend on the nature of our engagement with you.
Examples of personal information we may collect include:
General identification information such as names, job title, occupation, date of birth and gender.
Contact details such as address, email address, phone and mobile phone number.
Employment details.
In some circumstances, we may need to collect some forms of sensitive information about you to provide specific services. Sensitive information includes information about a person’s race, gender diversity, sexual orientation, disability, ethnic origin, political opinions, health, and religious or philosophical beliefs. We will only collect and use sensitive information with your consent, in accordance with applicable laws or in a de-identified aggregated manner. Sensitive information will only be collected if it is directly related to or reasonably necessary for our research and engagements.
It is important to be aware that if you access another party’s website or application using one of our products or services or via our website, that other party will deal with your personal information in accordance with its own Privacy Policy. You will need to review those websites to view a copy of the relevant Privacy Policy.
It is generally not practical to remain anonymous or use a pseudonym when dealing with us, as we usually need to use your personal information to provide specific services that relate to or involve you.
COLLECTING PERSONAL INFORMATION
Generally, we collect your personal information directly from you, for example, when we deal with you in person or over the phone, when you send us correspondence (including via email), or when you complete a questionnaire, form, or survey.
We may also collect personal information about you from your use of our websites and social media and the information you provide to us through contact mailboxes.
We may also occasionally receive personal and/or sensitive information about you from third parties to conduct social research on behalf of that organisation, such as your email address.
PURPOSE FOR COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION
We will only use your information if we have a lawful reason to do so such as when it’s our legal duty, if we have your consent and when it’s in our legitimate interest to do so. Reasons include:
To provide our services to you or our client per the terms of any engagement letter, service agreement or employment agreement.
Maintain contact with our clients and other contacts (including alumni) and keep them informed of our services, industry developments, seminars, and other events.
For purposes relating to the employment of our personnel (including consultants), or our Clients’ personnel, contractors and sub-contractors, including:
recruitment purposes such as pre-employment screening, contacting referees, processing applications, administering psychometric testing, assessment for suitability for future positions, background checks and ongoing analytic purposes such as ensuring we are reaching a diverse range of candidates,
providing internal services or benefits to our Partners and staff and
matters relating to the RPCo Partnership.
For development and analytics purposes to develop our expertise and know how, including:
for benchmarking purposes,
development, analytics and business intelligence functions, including website trend and performance analysis,
quality assurance and thought leadership, and
other purposes related to our business.
We may also use non-personal, de-identified and aggregated information for several purposes, including data analytics, research, submissions, and thought leadership. Any output is anonymised or aggregated so that no personal information or information relating specifically to you is reasonably identifiable.
SHARING PERSONAL INFORMATION
We will not disclose any personal information outside of the RPCo team to a third party for a purpose other than conducting our research unless we have your express prior consent or are required to do so by law or court/tribunal order.
When conducting social research, we may rely on third-party service providers to host or store the data we collect. We take all reasonable steps to ensure that third-party service providers comply with (or are substantially similar to) our PDR and the Privacy Act, and we put safeguards in place to ensure your Personal Information remains protected.
DOCUMENT RETENTION AND DISPOSAL
RPCo will destroy or de-identify your personal information as soon as reasonably practicable once it is no longer required to complete the purpose for which it was collected.
However, some personal information may be retained for varying periods to comply with legal and regulatory obligations and other legitimate business reasons. In this case, your personal information will continue to be protected in accordance with this Policy.
MISCELLANEOUS
This policy has been effective from the original date of publication, July 2024. This policy is reviewed periodically. Although we intend to observe this PDR at all times, it is not legally binding on RPCo in any way. Occasionally, we may regard it as necessary or desirable to act outside the policy. RPCo may do so, subject only to any other applicable contractual rights you have and any statutory rights you have under the Privacy Act or other applicable legislation.