PRIVACY POLICY

Version 3.0
Lastest Version Issued: 12 October 2026

1 Purpose and scope

Elite Executive Pty Ltd (we, us or our) respects the privacy of candidates, clients, referees, workers and website visitors. This policy explains how we collect, hold, use and disclose personal information in providing executive search, recruitment, placement and related services throughout Australia.

We manage personal information in accordance with the Australian Privacy Principles (APPs) in Schedule 1 to the Privacy Act 1988 (Cth). Where applicable, we also comply with the Privacy (Tax File Number) Rule 2015 and privacy obligations arising from government service arrangements. Section 12 explains our Queensland government work.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not it is true or recorded. Sensitive information receives additional protection under privacy law.

2 Information we collect and hold

We collect only information reasonably necessary for our functions and activities. Depending on your relationship with us, this may include:

  • Candidates and workers: contact details, resumes, career history, qualifications, licences, skills, availability, location and relocation preferences, remuneration expectations, work rights, interview notes, reference reports and work performance information.
  • Assessment information: selection criteria responses, competency and psychometric assessments, and photographs or video introductions where relevant and agreed.
  • Clients and referees: names, business contact details, roles, hiring or reference authority, communications and information needed to manage our services or assess suitability for a position.
  • Where we employ or pay a worker: payroll, bank, superannuation, leave and tax information lawfully required for that purpose. We do not request bank details or tax file numbers simply to register a candidate.

3 Sensitive information and identification

Sensitive information may include health information, criminal history, racial or ethnic origin, religious beliefs, political opinions, union membership and certain biometric information. We generally collect sensitive information only with your consent and where it is reasonably necessary for our services, unless a specific legal exception permits or requires collection.

Role-related health, criminal history or other screening must be relevant to the position or a lawful requirement. We explain the purpose, proposed recipients and consequences of not providing the information. We do not collect or use information for unlawful discrimination, including under applicable Queensland and Commonwealth anti-discrimination laws.

We seek permission before arranging reference checks or contacting a current employer. Where assessments or background checks are required, we explain the process and obtain the consent required for the check. We collect identity and work-rights documents only where necessary, and limit copying and retention to what the purpose requires.

We collect, use and disclose tax file numbers only as authorised by taxation, superannuation or personal assistance law. Providing a tax file number is voluntary, although tax consequences may follow if it is not supplied. We do not use government identifiers as our own candidate identifiers except as permitted by law.

4 How we collect information

We usually collect information directly from you through applications, registration forms, interviews, emails, telephone conversations, assessments and our website. Where it is unreasonable or impracticable to collect directly, we may collect relevant information from authorised referees, clients, job platforms, screening providers, professional registers or public professional profiles.

Public availability does not remove privacy obligations. We assess whether information is relevant, necessary and lawfully collected. If we receive unsolicited information, we assess whether we could lawfully have collected it. Where required, we securely destroy or de-identify it as soon as practicable, if lawful and reasonable.

At or before collection, or as soon as practicable afterwards, we take reasonable steps to tell you about the collection, its purpose, usual disclosures, any relevant legal requirement, likely overseas recipients and the consequences of not providing information. We also explain how to access or correct your information and make a complaint.

You may make a general enquiry anonymously or using a pseudonym where practicable. We normally need to identify you to assess an application, verify work rights or arrange a placement. If necessary information is withheld, we may be unable to provide some services. Contact us to discuss alternatives.

5 Use and disclosure

We use personal information to assess suitability and interest in roles, conduct executive searches and agreed checks, arrange interviews and placements, communicate with you, manage client relationships, administer employment where relevant, and meet legal obligations. We take reasonable steps to ensure information used or disclosed is accurate, current, complete and relevant.

We may disclose relevant information to prospective employers and selection panels, authorised referees, assessment and screening providers, IT and cloud service providers, and professional advisers. We seek your agreement before presenting an identifiable candidate profile, resume or video to a prospective employer. Suppliers receive access only as needed to provide their services, subject to appropriate privacy and security arrangements.

For another purpose, we disclose information only with consent or where privacy law permits, including where you would reasonably expect a related purpose (a directly related purpose for sensitive information), or disclosure is required or authorised by law. A contractual request alone does not authorise a disclosure that privacy law prohibits.

6 Overseas handling

Personal information may be handled outside Australia through cloud, recruitment, accounting, communication or support services, or disclosed to an overseas client in connection with an agreed search. Overseas storage and overseas disclosure are assessed according to the access and control arrangements.

Before disclosing personal information overseas, we take reasonable steps required by APP 8 to ensure the recipient does not breach the APPs, unless a lawful exception applies. We may remain accountable for the recipient’s handling under the Privacy Act. We do not treat agreement to this policy as a blanket waiver of those protections. Government contract restrictions also apply where relevant.

7 Security and retention

We hold information in our recruitment database, document storage, communication and business systems, and any necessary physical records. We take reasonable technical and organisational measures to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. Measures must be appropriate to the risks and include restricted access, secure authentication, staff confidentiality and training, supplier oversight and secure disposal.

We retain information only while needed for an authorised purpose or a legal retention requirement. When no longer required, we take reasonable steps to securely destroy or de-identify it, subject to applicable law and government record obligations. You may ask us to remove you from future searches and review deletion of your records. Marking a record inactive does not itself delete it. Required records may be retained with restricted use.

8 Access and correction

Contact our Privacy Coordinator to request access to or correction of your personal information. We verify identity using information proportionate to the request. We aim to acknowledge requests within five working days and respond within 30 calendar days, or otherwise within a reasonable period required by law. These are service targets, not a replacement for applicable statutory requirements.

There is no fee to make a request or to correct information. Any charge for providing access will be reasonable and explained in advance. If access or correction is refused, we provide written reasons, except where it would be unreasonable to do so, and explain complaint options. Confidential reference reports are not automatically exempt from access; we assess applicable exceptions and consider redaction or another means of access.

If you disagree with information we decline to correct, you may ask us to associate a statement with it. Where required, we take reasonable steps to notify other APP entities of a correction if you request this.

9 Websites and communications

Our website and associated platforms may collect device, IP address, browser and usage information through logs, cookies and similar technologies. Where this identifies you, we handle it as personal information. Browser settings may allow you to restrict cookies. Any analytics, advertising or tracking services actually used must be described in the relevant website notice.

We send marketing communications only where permitted by applicable law. Commercial emails and messages identify us and include a functional unsubscribe option. We action unsubscribe requests within five working days. You can also ask us to stop marketing by contacting us. Necessary communications about an active application or engagement may continue.

10 Recruitment technology

We apply this policy to personal information processed by recruitment software, assessment tools and any approved artificial intelligence systems. Technology use must have a lawful purpose, appropriate safeguards and an assessment of accuracy, relevance and privacy risks.

11 Data breaches

We promptly contain and assess suspected privacy breaches and take remedial action. Where the federal Notifiable Data Breaches scheme applies, we take all reasonable steps to complete the assessment of a suspected eligible breach within 30 calendar days of becoming aware of grounds for suspicion. If an eligible breach is established, we notify the OAIC and affected individuals as soon as practicable, subject to lawful exceptions, and provide information and recommended protective steps. The assessment period is not permission to delay notification of a known eligible breach.

12 Queensland government service arrangements

The Information Privacy Act 2009 (Qld) principally regulates Queensland government agencies, including local councils. It does not automatically make every private recruitment business an agency. Where a service arrangement binds us as a contracted service provider, we comply with the privacy requirements applicable to that arrangement and information.

The Queensland Privacy Principles (QPPs) commenced on 1 July 2025. Transitional arrangements may preserve earlier privacy requirements for some existing contracts. We check the applicable contract, including restrictions on overseas disclosure under section 33, subcontracting, secondary use, security, access assistance and return or disposal of records.

Queensland’s mandatory data breach notification scheme commenced for relevant state agencies on 1 July 2025 and local governments on 1 July 2026. It does not directly apply to contractors as such. We promptly notify the contracting agency of a suspected or actual breach in accordance with the service arrangement and assist its assessment and notification obligations where it controls the affected records. Our separate federal obligations may also apply.

Recruitment records managed for a government client may remain under that agency’s control. Access, amendment, retention and disposal may therefore need to be managed with the agency under the Right to Information Act 2009 (Qld), applicable public records legislation and the service arrangement. We do not promise confidentiality that overrides a legal disclosure requirement.

13 Complaints and contact

If you have a concern about our handling of personal information, contact our Privacy Coordinator. A written complaint helps us investigate, but we can assist you to make a complaint by another accessible method. Please describe the issue and the outcome you seek.

Privacy Coordinator | Elite Executive Pty Ltd
Email: info@eliteexecutive.com.au
Telephone: 07 4088 1571
Website: www.eliteexecutive.com.au

We aim to acknowledge complaints within five working days, investigate fairly and provide a response within 30 calendar days. If more time is needed, we explain why and keep you informed. You may complain to the Office of the Australian Information Commissioner at www.oaic.gov.au or on 1300 363 992 if unresolved. The OAIC generally expects you to first allow us 30 days to respond.

Where a complaint concerns Queensland information handled under a bound service arrangement, the Office of the Information Commissioner Queensland may be the appropriate regulator. Its complaint process generally requires first complaining to the relevant agency or bound provider and allowing 45 business days to respond. Information is available at www.oic.qld.gov.au.

14 Policy updates

We review this policy when legislation, services or information handling changes. The current adopted version will be available free of charge on our website and on request. Changes to this policy do not retrospectively authorise new uses or disclosures or replace consent where it is required.

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