Last Revised: 30 October 2023
Notice to Users
In this Privacy Policy “we“, “us“, “our“, “iWS” or “Integrated Workforce Solutions” means Integrated Workforce Solutions Pty Ltd (ABN 48 603 190 781) trading as Integrated Workforce Solutions. Integrated Workforce Solutions is committed to complying with applicable privacy laws in relation to any personal information that is provided to us and stored on the Integrated Workforce Solutions Platform (“Platform“).
By accessing the Platform and providing personal information to us or consenting to a third party (such as your employer) providing personal information to us, you agree to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.
This Privacy Policy forms part of our Terms of Use which can be found here [https://www.iwsaustralia.com.au/legal].
Scope of Application
This Privacy Policy applies to the following individuals:
- Visitors of the Site with whom iWS does not have a contractual relationship
- Clients who use our Services, including client representatives
- Employees who use our Services
- Suppliers who provide products or services to iWS
- Participants of webinars, conferences, trade events, surveys, etc.
By using our Site and/or our Services as well as engaging with iWS in any way, you agree to the collection and use of your information in accordance with this Privacy Policy.
How We Collect Personal Information
In order to access certain information, features, products, services or other offerings (“Services“) through the Platform, you may be required to provide personal information.
We collect personal information about you from the following sources:
- When you establish an account or register to access and use the Platform or use any of the Services available through the Platform.
- If you provide us with comments or suggestions, request information about our Services, or contact our customer service department via phone, email, or other forms of communication.
- If you choose to use or participate in one of our various programs (such as our referral service).
- From your transactions and other interactions with us, our affiliates, and others, including our marketing partners and third-party service providers.
- When you access products and services from our business partners through the Platform. For example, if you select to use the Flare HR service provided by Flare HR Pty Ltd (or its subsidiaries) (“Flare HR“) for registering your superannuation details and providing you with superannuation services.
- When you use certain features of the Platform including where you voluntarily submit personal information, for example, in connection with requesting a price quote or registering to receive a newsletter.
- From consumer and business reporting agencies.
- From a third party (where you have consented) such as your employer, where your employer provides information about you to the Platform for the purpose of using our Services, or where personal information is collected by our third-party service providers who are permitted to disclose that information to us. We may also collect information from you through our related bodies corporate.
- As otherwise required to manage and deliver the Platform and/or Services.
Types Of Personal Information We Collect
When you access or use the Platform or Services, we may collect the following types of personal information:
- Name, address, date of birth, email address and telephone numbers.
- Gender
- Bank details, superannuation details and tax details (including Tax File Numbers or TFN).
- Emergency contact details.
If you provide your TFN to us, you consent to us storing and using your TFN as authorised by law. Due to the sensitivity of TFNs and the legal restraints on the use and disclosure of TFNs, if you lose or forget your TFN, we will not be able to provide it to you. You will have to ask the ATO for a copy of it.
How We Use Personal Information
Generally, we use personal information for the following purposes:
- To operate the Platform and provide the Services that we offer to you (including improving or developing the Platform and/or Services).
- To cross-reference it with information we receive from other third parties including our marketing partners and business partners in order to provide you with an enhanced and more personalized experience on the Platform.
- To respond to your comments or inquiries, resolve disputes, contact you when necessary, in connection with the operation of the Platform and/or our Services, or for matters involving any product or service transactions, to address problems on the Platform or with the Services and to enforce our agreements with you.
- For other third-party service providers to perform tasks for us, such as providing marketing assistance and data analysis, or to perform other services offered to users of the Platform, when that information is necessary for them to perform such services.
- So that we can detect and prevent any fraudulent or malicious activity, and make sure that you are accessing and using our Platform and Services fairly and in accordance with our Terms of Use.
- To comply with our legal obligations and assist government and law enforcement agencies or regulators.
Information Use
Below is a list of the ways that we may use your Personal Information together with the legal basis of processing, where applicable under data protection law.
Purposes for which we use your Personal Information | Legal basis | Our reasons |
Management of the contractual relationship with you to provide you with our Services | ● Performance of the contract
● Compliance with our legal obligations |
● Clients
● Employees ● Suppliers |
Secure access to our Services, including but not limited to performing the necessary identification and verification of our users prior to granting access to our Services | ● Performance of the contract
● Legitimate interest Our legitimate interest is to safeguard access to our Services to authorized only users who have gone through identification and verification processes |
● Clients
● Employees |
Marketing and events-related communications, including but not limited to inviting you to participate in events, surveys or otherwise communicating with you for marketing purposes to promote our Services | ● Consent
● Legitimate interest Our legitimate interest is to tailor our marketing communications to the preferences and interests of our audience and provide a personalized and engaging experience for our customers |
● Visitors of the Site
● Clients ● Participants of webinars, conferences, trade events, surveys etc. |
Protect the security or integrity of us, our Site and our Services | ● Legal Obligation
Our legitimate interest is to maintain the reliability and availability of our services by detecting and preventing security threats, fraud, money laundering and other crime, unauthorized access, risk and other activities that could harm our business, Site, or Services. |
● Visitors of the Site
● Clients ● Participants of webinars, conferences, trade events, surveys etc. |
Communicate with you about our Site and Services, such as to notify of changes and updates and to provide you with customer support and troubleshooting | ● Performance of the contract
Our legitimate interest is grounded in our commitment to delivering a seamless and informative user experience and to provide assistance when needed |
● Visitors of the Site
● Clients ● Employees |
Meet our legal, regulatory, and tax reporting obligations | ● Legal obligation | ● Clients
● Employees ● Suppliers |
In cases where we need to process personal data for the performance of the contract with you or as required by law and you refuse to provide your information, we may not be able to perform the contract with you and consequently, we may not be able to provide certain services to you.
Disclosure Of Personal Information
We may disclose your personal information to:
- Our related entities.
- Your employer.
- Any third parties to whom you have directed or permitted us to disclose your personal information, for example Flare HR in relation to your superannuation choice.
- Third party service providers that provide us with technical and support services.
- Our audit, legal and other professional advisers.
If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
Where we disclose your personal information to third parties, we take reasonable steps to ensure that the security of your personal information is subject to appropriate safeguards. If you direct or permit us to disclose your personal information to a third party through use of the Platform, then please refer to that third party provider’s Privacy Policy to understand the manner in which that third party treats your personal information.
How we use Non-personal Information
We may at times use the non-personally identifiable information we collect:
- to improve the design and content of our Platform;
- to enable us to personalise your user experience;
- to analyse Platform usage; and
- to offer you Services.
Use of Aggregate Information: From time to time, we may collect general, non-personal, statistical information about the users of the Platform and Services. We collect this information to determine information regarding the use of our Platform, Services, and general information about our customers. We may also group this information into aggregate data in order to describe the use of our Platform and to provide general aggregated information. The aggregated data will not personally identify you or any users or visitors to the Platform.
Overseas Transfers of Personal Information
We may disclose your information to recipients located outside Australia in order to assist us in providing the Platform and/or Services to you.
We may also engage overseas service providers to provide services to us (like cloud storage services or other types of network or electronic systems) from time to time which may not necessarily always involve a disclosure of your information to that overseas service provider.
By providing us with your personal information, you agree that information collected while you use the iWS Site and/or Service, including your Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Direct Marketing
We may use your personal information to offer you products and services we believe may be of interest to you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners, or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication or by contacting our support team.
Protection Of Personal Information
- We use technical and organisational measures to keep your personal information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. These technical and organisational measures include:
- the use of identity and access management technologies to control access to systems on which information is processed and stored;
- storing your information on secure servers;
- encryption technologies;
- requiring all employees to comply with internal information security policies and keep information secure;
- requiring all employees to complete training about information security;
- monitoring and regularly reviewing our practice against our own policies and against industry best practice.
We will also take reasonable steps to destroy or de-identify personal information if it is no longer required for legal or operational reasons.
Access To and Correction Of Personal Information
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information. In circumstances where we refuse access, we will provide you with a written notice stating our reasons for refusing access.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date.
Links To Third Party Sites
The Platform, including all Services provided through the Platform, may contain links to other websites operated by third parties. We are not responsible for any third party websites and we make no representations or warranties in relation to the privacy practices of those third party websites. We encourage you to read the Privacy Policy of any third party website that we may provide a link to on our Platform and/or as part our Services.
Your rights
Under applicable privacy regulation, you may have some or all of the following rights in respect of your Personal Information:
- to obtain a copy of your Personal Information together with information about how your Personal Information is processed;
- to rectify inaccurate Personal Information;
- to erase your Personal Information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
- to restrict processing of your Personal Information
- to object to the processing of your Personal Information where we’re relying on a legitimate interest;
- to object to decisions that are based solely on automated processing or profiling;
- to obtain a portable copy of your Personal Information, or to have a copy transferred to a third party controller; or
- to withdraw your consent, at any time, where you may have provided it for the collection, processing and transfer of your Personal Information for a specific purpose;
Region-Specific Privacy Terms
iWS is a global company and as such, our approach to privacy compliance is a global one. No matter where you are located, whether in the United States, the European Economic Area (EEA), the United Kingdom (UK), Latin America, or the Asia-Pacific region, we remain committed to abiding by all applicable data protection laws. Below you’ll find region-specific privacy terms that might apply to you in addition to the general terms of this Privacy Policy, depending on the country where you’re based.
EEA/UK/Switzerland
This section applies to residents of the EEA, Switzerland and the UK, using our Site and/or Services and addresses the specific requirements under the General Data Protection Regulation (GDPR), the UK GDPR and the Swiss Federal Data Protection Act (FADP).
Legal Basis
If you are a resident in the EEA, UK and Switzerland, we collect and process information about you only where we have a legal basis for doing so under applicable laws. For information about the legal bases we rely on when processing your Personal Information under GDPR, please refer to the section “Information Use” of our Privacy Policy.
Changes To Our Privacy Policy
This Privacy Policy is effective as of the “Last Revised” date specified at the top of this Privacy Policy. We may update our Privacy Policy from time to time and the changes will be effective immediately upon being made public on our Platform. Through your continued use of the platform, are deemed to have accepted the terms of thisPrivacy Policy on your first use of the Platform following the alterations.
Contact Us
If you have any questions about our Privacy Policy, or would like to raise a complaint, you can contact our support team via the details below:
Email: support@iwsaustralia.com.au
Post: Level 9, 440 Collins Street, Melbourne VIC 3000
When contacting us, please provide full details of your question, concern, or complaint. We take all complaints very seriously and we will take steps to investigate and resolve complaints within a reasonable period. Please note, we may require further information from you in order to investigate and resolve any complaints.
If we cannot resolve your complaint or you dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner (OAIC):
Email: enquiries@oaic.gov.au
Post: GPO Box 5218, Sydney NSW 2001
Fax: 02 9284 9666
Enquiries Line: 1300 363 992