HUB24 Group Recruitment Privacy Collection Notice
HUB24 Group Recruitment Privacy Collection Notice current as of 06 October 2023.
1. Overview
1.1. HUB24 Limited is a financial services company listed on the Australian Securities Exchange that was established in 2007 and is a leading provider of integrated platform, technology and data solutions to Australia’s wealth industry.
1.2. The businesses lines of HUB24 Limited include the HUB24 platform, the Xplore platform, the Class businesses, HUBconnect and myprosperity business.
1.3. HUB24 Limited operates via two core revenue generating segments, a Platform segment and Tech Solutions segment and a Corporate segment as shown below.
Platform segment
1.4. The Platform segment comprises the HUB24 investment and superannuation platform (HUB24 platform), the Xplore Wealth investment and superannuation platform (Xplore platform), Portfolio & Reporting Services (PARS) and myprosperity.
1.5. The HUB24 platform and Xplore platform are used by financial professionals to administer their clients’ investments which are held through a superannuation and investment product under custodial arrangements. The Xplore platform provides complementary capabilities including high net worth product features, managed accounts, superannuation services and PARS capability. In addition, HUB24 also offers PARS, a non-custody portfolio service which provides administration, corporate action management and tax reporting services for financial professionals and their clients. myprosperity, acquired by HUB24 in May 2023, is a provider of client portals for accountants and financial advisers. Its all-in-one portal delivers a total view of household wealth.
Tech Solutions segment
1.6. The Tech Solutions segment comprises the following sub-segments, being Class and HUBconnect.
1.7. Class’ core offering is self-managed superannuation fund administration software. Class also operates in the document and corporate compliance segment through the service offerings provided under the NowInfinity brand.
1.8. HUBconnect provides technology and data services to the wealth industry, delivering solutions to enable financial professionals to efficiently run their businesses and service their clients.
Corporate Services
1.9. HUB24 Management Services Pty Ltd is the primary services provider within the HUB24 Ltd Group of companies (HUB24 Group) and is the entity that typically employs our people and engages any contractors.
2. This Privacy Policy Collection Notice
2.1. This is the Personal Information Collection Statement of HUB24 Management Services Pty Ltd (referred to as HUB24, we, our and us in this document) for candidates and contractors seeking to be engaged by HUB24 and should be read with the HUB24 Limited Group Privacy Statement. The HUB24 Group Limited Privacy Policy is available at: www.hub24.com.au/privacy-policy/
3. The type of personal information that we collect and hold
3.1. We collect information about you and from you, when you apply for a role with HUB24. We may also collect personal information from other sources.
3.2. Please note that not all the data types referred to below are requested or obtained for every candidate. The types of data requested or obtained may depend on matters such as the nature of the role, and stage of the recruitment process.
3.3. The different types of personal information we collect and hold about you may include the following:
3.3.1. Contact details such as your name, address, phone number and email address.
3.3.2. Employment details and qualifications such as your employment history, your qualifications. For example, your university education, professional certifications, professional memberships and other educational qualifications.
3.3.3. Sensitive personal information that you may choose to provide, including:
3.3.3.1. health such as any physical or mental condition that you choose to provide to us so that we can confirm your ability to perform a role and to ensure that we make reasonable adjustments for your interviews and assessments where required.
3.3.3.2. diversity and inclusion information such as gender identity, ethnicity, and disability information. This information is not used to determine your suitability for a role and is only used on a de-identified basis for statistical reporting only.
3.3.4. Subject to our legal obligations, anything that you choose to tell us before or during interviews or assessments (e.g. psychological and aptitude assessment) whether face-to-face, by phone, email, online or otherwise.
3.3.5. Identity information such as you’re your photo ID, passport information, birth certificate, drivers licence details or date of birth.
3.3.6. Background check information such as criminal history details, APRA and ASIC regulatory checks, a pre-employment medical declaration, visa status and eligibility to work and professional references.
3.3.7. Financial information such as your Tax File Number (TFN), Tax residency status and bank account details. We collect this information in case your application for a role is successful.
4. Why we collect and hold your personal information
4.1. We collect and hold your personal information so we can:
4.1.1. Process and manage your application for employment.
4.1.2. Determine your eligibility for employment.
4.1.3. Communicate with you, including about role opportunities.
4.1.4. Enter into a contract with you.
4.1.5. Manage our relationship with you. For example, scheduling interviews and to perform assessments.
4.1.6. Consider you for future applications (unless you ask us not to).
4.1.7. Protect our legal rights and resolve disputes or complaints.
4.1.8. Comply with our legal obligations.
4.1.9. Manage our risks such as business continuity and security.
4.1.10. Understand how website and services are being used and to help us address website technical problems.
4.1.11. Undertake statistical analysis. For example, to monitor diversity and equal opportunities.
4.2. When you apply for a role with us, you may also be added to our Talent Data Base. Where we add your personal information and other information that you provide to us e.g. your resume, we may then contact you to discuss relevant future opportunities that may arise with us. If you do not wish for your information to be retained in our Talent data Base, please let us know.
5. How we collect your personal information
5.1.1. The main ways we may collect personal information are as follows:
5.1.1.1. You provide the relevant data to us directly.
5.1.1.2. Your representative (which may be a friend or colleague or other acquaintance) provides it to us.
5.1.1.3. Recruitment agencies (who we have engaged) may provide it to us.
5.1.1.4. We obtain it from publicly available information platforms, such as LinkedIn.
5.1.1.5. Information as verified by external parties such as via background or criminal checks where you provide consent for us to undertake those checks.
6. Where we collect your personal information from someone else
6.1. Where anyone else refers you to us as a prospective candidate, we use all reasonable efforts to ensure that the relevant person is required to make you aware that they will be providing your personal information to us, obtains your consent and give you a copy of this Collection Notice.
7. How we hold your personal information
7.1. Your information is generally held electronically but may also be held in a physical format. We implement a range of measures to protect the security and integrity of your personal information.
7.2. These measures may include one or more of the following:
7.2.1. Access to our physical environment and information systems being controlled through identity and access management controls.
7.2.2. Employees being bound by internal information security policies and are required to keep personal information secure.
7.2.3. Employees being required to complete Privacy Act compliance training and information security training.
7.3. We regularly assess our information security measures against industry best practice.
8. How long do we hold your personal information
8.1. How long we hold your personal information may vary depending on whether your application has been successful or not and, if not, whether or not you have asked us not to keep your personal information so we can contact you about future role opportunities.
8.2. If your application is successful, your personal information will be included in your employee profile with us.
8.3. If you are unsuccessful, we will retain any personal information about you as long as we are required to under applicable laws or otherwise for a period of two years from the date your last application was formally rejected unless you ask us to remove your personal information sooner than that.
9. Who we disclose your personal information to
9.1. We may disclose your personal information in the following circumstances:
9.1.1. where we have your consent.
9.1.2. where we have engaged the relevant person or organisation to help assess your suitability for employment, to help manage our recruitment process or to conduct surveys.
9.1.3. where we are required or authorised to so by law. For example, to assist with detecting or preventing fraud, tax evasion, money laundering and financial crime.
9.1.4. where we have legitimate business reasons for doing so. For example, to manage risk, verify your identity, assess your suitability for a role or to defend our legal rights and interests.
9.1.5. to comply with laws and assist government and law enforcement agencies.
9.2. We may disclose your personal information in the circumstances described above to:
9.2.1. persons consented to by you.
9.2.2. our employees, contractors, directors and officers, including of our related bodies corporate.
9.2.3. service providers. For example, recruitment agencies, IT service providers (e.g. data storage, hosting and service providers, IT service providers, vetting and background check providers and identification and document validation agencies.
9.2.4. law enforcement and government agencies, courts and tribunals and any party appointed or requested by our regulators to carry out investigations.
9.2.5. professional advisers, auditors or business partners.
9.2.6. natural or legal persons as part of a potential or actual corporate restructuring, merger, acquisition or takeover.
10. Disclosure of personal information overseas
10.1. We operate our business in Australia. We may, however, share your personal information with recipients outside Australia (unless we agree with you not to) to assist us with the operation of our business.
10.2. The types of recipients may include:
10.2.1. Our employees and contractors working remotely and outside Australia.
10.2.2. Service providers to us that operate outside of Australia.
10.2.3. Foreign regulatory authorities, government authorities or law enforcement agencies.
10.2.4. The foreign countries where your personal information is likely to be sent include Vietnam and the Philippines.
10.3. Where we do this, we take reasonable steps to ensure that recipients are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
11. Background checks that we undertake
11.1. When you apply for a role with us, we will conduct certain background checks. These are conducted to:
11.1.1. Verify your identity.
11.1.2. Verify your right to work.
11.1.3. Verify your employment history, academic and professional qualifications.
11.1.4. Perform criminal record checks in Australia and, if applicable, overseas.
11.2. We undertake these checks to comply with our legal obligations, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
11.3. During the recruitment process, we will let you know of any relevant background checks or if the role you are applying for is subject to any specific vetting requirements.
11.4. Police checks (Australian and foreign) are undertaken once an offer of employment (which is conditional on the outcome of this check) by our service providers. These checks are retained on your employment records.
12. If you decide to not provide your personal information
12.1. You are not required to provide your personal information to us.
12.2. If, however, you wish to work with us and do not do so, we may not be able to proceed with your application for the relevant role.
13. HOW TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION
13.1. We rely on you or your representative to provide us with personal information that is accurate and up-to-date.
13.2. If your personal information changes, please let us know promptly and inform of us of your updated details.
13.3. You can request access to your personal information that we hold. You can also ask that we correct that information. To do so, please contact us using the contact details provided at the end of this Collection Notice.
13.4. We will seek to verify your identity before providing you with access, or making changes, to your personal information.
13.5. In some limited circumstances we are not required to provide you with access to your personal information. An example of where this is the case is where a Court or Tribunal order prohibits us from doing so.
13.6. There may also be circumstances where we are not required to correct your personal information. For example, where we are not satisfied that the information we hold is inaccurate, out-of-date, irrelevant or misleading.
13.7. If we do not give you access to or correct your personal information, we will notify you and explain our reasons (except to the extent it would be unreasonable or unlawful to do so). In this event, we will also provide you with information about how you can complain about such a decision.
14. HOW TO RAISE A QUESTION OR MAKE A COMPLAINT
14.1. We are committed to ensuring all applicants and potential employees of HUB24 are informed about this Privacy Collection Notice and that we respond to questions and concerns on a timely basis.
Questions
14.2. If you have a question regarding the recruitment process and/or the collection and use of your personal information, please contact the HUB24 Recruitment team at: recruitment@hub24.com.au
Complaints
14.3. If you have a complaint about how your personal information is being handled by us, please contact the Hub24 Recruitment Team at: recruitment@hub24.com.au
14.4. If your complaint relates to how a third-party handles your personal information, please contact them first using the contact details in their privacy policy. For example, if you have a complaint about how a recruitment agency is handling your personal information, you should contact them.
14.5. Our aim is to resolve your complaint as soon as possible and we will let you know the likely timeframe for doing so. If we need more time, we will also let you know.
14.6. HUB24 complaints contact details are:
HUB24 Complaints Manager
HUB24 Ltd
GPO Box 529, Sydney, NSW, 2001
Email: complaints@hub24.com.au
14.7. Under the Privacy Act 1988 (Cth) you may also complain to the Office of the Australian Information Commissioner (OAIC) if you are not satisfied with our response to, or the handling of your complaint.
14.8. OAIC’s contact details are:
The Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Phone: 1300 363 992
Online: www.oaic.gov.au
Email: enquiries@oaic.gov.au
15. UPDATES TO THIS COLLECTION NOTICE
15.1. We will review this Collection Notice at least annually or following a significant change in our processes for collecting, using, managing and disclosing personal information.
15.2. We may also need to provide you with additional information that is specific to a collection of personal information. In that case we may provide you with a Supplementary Collection Notice, instead of updating this Collection Notice.
15.3. If you are provided with a Supplementary Collection Notice, it is important that you read both it and this Collection Notice.
16. HOW TO CONTACT US
16.1. We may be contacted at:
People & Culture
HUB24 Management Services Pty Ltd
GPO Box 529, Sydney, NSW, 2001
Phone: 1300 854 994
Email: recruitment@hub24.com.au