Introduction

This Global Candidate Privacy Notice (“Notice”) describes how Medibase Health Pty Ltd and The Proactive Health Company Pty Ltd and its subsidiaries and/or related entities (collectively, “we,” “our,” “us” or the “Company”) will collect, use, store, and disclose the personal information about any individuals who apply to an open position with us, who we contact for or who express interest in employment with us, who attend a recruitment event or who undergo an interview or assessment with us, whether online or offline (“Candidate Personal Information”).

In general, personal information (also known as personal data) is any information that can identify who you are, either directly (for example, your name or identification number) or indirectly in combination with other information we may have about you. Some laws define “personal information” differently, and we use those definitions when they are applicable. In addition, many countries have specific legal requirements governing the use of personal information, including Candidate Personal Information. We will comply with all applicable laws and regulations and will implement additional policies and procedures when needed to meet these requirements. Accordingly, the actual Candidate Personal Information collected and/or accessed by the Company may differ from jurisdiction to jurisdiction to comply with local laws.

Candidate Personal Information We Collect and Process

We try to minimize the types and amount of Candidate Personal Information the Company may collect from or about you. The collection of information and access to such information will vary depending on country-specific legal and/or business requirements. We will notify you at the point of collection when the Candidate Personal Information that we request is voluntary (rather than required) to proceed with your recruitment process.

Type of Candidate Personal Information

Why We Collect and Process

Contact Information

Full name or previous names (such as maiden names)

Honorifics and titles, including preferred name and salutation

Mailing address

Email address

Telephone and/or Mobile number

To provide you with news and updates about our careers and roles by email, and/or text message. To initiate your employment application and contact you with necessary actions and updates.

This data is used throughout the remainder of the recruitment process to communicate with you. If you consent, we may also send you automated updates via text or text messaging applications (e.g., a reminder to complete necessary documentation).

Professional Data

Resume or CV

Prior work history, including references

Data from LinkedIn profiles and/or similar platforms

Academic data, including education and degree data

Professional licenses, certifications, and affiliations

Personal and professional skills

To assess your skills, qualifications, and interests against our career opportunities. To help us evaluate you against the specific requirements of the role(s) you are applying for.

Digital Identification Data

IP address

Digital Signature

To deliver digital services through our recruiting website and applications, to provide you with relevant updates about Company careers and roles you may be interested in, to improve your experience when visiting our websites, to remember your preferences (such as a language or a region), to identify and resolve errors, and to analyse how well our websites are performing. To allow you to authorize and submit employment application forms in a digital format as applicable.

Government ID/Work Eligibility Information

National ID

Citizenship

Residency

Nationality

Country of Birth

Military and/or veteran status

To determine your work eligibility for the specific role you are applying for.

Test Results

The scores from any tests that you complete as part of the recruitment process

To determine your qualification and suitability for the relevant role prior to entering an employment relationship.

Personal Characteristics*

Gender

Disability

Military and/or veteran status

Ethnicity and/or race

*Collection of these types of Personal Information may vary depending on geographic location and applicable law. Such data may not be requested in all locations.

To assess and support our diversity recruitment and staffing efforts and for legal reporting purposes, subject to applicable law. Disability data is also collected to ensure that we provide (at your request) any reasonable accommodation during your recruitment process.

Relationship to individuals who work for the Company or similar companies

To screen your application against potential conflicts of interest.

Medical or Health Information

To determine if you can safely perform the duties of your role and to determine if you need any reasonable accommodation to do so, subject to applicable law and only if required for your role.

Any other information required by law for employment compliance or voluntarily provided to us by Candidates

Sources of Candidate Personal Information

We may collect Candidate Personal Information from sources that include the following:

Information you provide to us directly. We primarily obtain Candidate Personal Information from you. For example, when you create or submit a job application or provide personal data to us as part of the interview process.

Information collected from other individuals. We may collect personal information from other individuals. For instance, references during the application process or if you are referred for a role by someone else, as permissible.

External Sources. We may collect personal information from third parties such as job references, public databases and background check services, professional or sanctions registries, academic institutions and training or certification providers, information made publicly available on a social network or webpage (where permitted), and recruiting or executive search agencies.

We may combine information that we receive from the various sources described in this Notice and use or disclose it for the purposes described in this Notice.

Legal Basis for Processing Your Candidate Personal Information

Certain jurisdictions require us to have a legal basis for processing your personal information. Where applicable law requires us to justify our processing activities, our legal basis for collecting and using Candidate Personal Information as described in this Notice will depend on the personal information concerned and the specific context in which we collect it.

In general, we will normally collect Candidate Personal Information from you where we have your consent to do so and where we need your personal information to process your application. By accessing our website/career portal or applying for one of our roles, you provide your consent to us to collect and further process the personal information described above for the purposes described in this Notice. You may withdraw your consent at any time by submitting a request to the contacts below.

Legitimate Interests. In our legitimate interests, namely the recruitment, selection, evaluation, and appointment of new employees, the management and administration of the recruitment and HR processes, ensuring the recruitment of a diverse workforce and the safety of our workforce, to the extent our legitimate interests are not overridden by your fundamental rights and freedoms.

Legal Obligations. Compliance with our legal obligations where employment laws or other laws require the processing of Candidate Personal Information.
Vital Interests. We may also need Candidate Personal Information to protect your vital interests or those of another natural person.

We generally do not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU General Data Protection Regulation. In the event we rely on automated decision-making that could have a significant impact on you, we will provide you an opportunity to express your views and will provide any other safeguards required by law.

Artificial Intelligence (AI)

AI technology is used to identify, extract and structure information coming from the text of the CV/resume you upload. It compares the data we hold about you and other candidates, to create a ranked a list of suitable candidates for a particular job. No automated decisions are made that produce any legal or similarly significant effects on you - all decisions are made by a human recruiter.

Transfer and Sharing of Candidate Personal Information

We are a Global organisation As such, some Candidate Personal Information may be transferred to or accessible by parties located outside of the country in which you reside, in accordance with applicable law:

Inside our group

We may transfer Candidate Personal Information to other members of our group of companies, including but not limited to talent acquisition, human resources, and related hiring managers for the purposes of facilitating the recruiting and hiring process. Certain members of our group of companies may also carry out IT-related or HR related tasks as data processors, i.e., on behalf and by instruction of other members of our group of companies.

Outside our group

We may also share Candidate Personal Information with service providers that support our talent acquisition teams during the recruiting and hiring process.
We may also share Candidate Personal Information with governmental agencies and regulators, courts, external advisors, and social insurance carriers to comply with our legal obligations or enforce our rights.
We may also share Candidate Personal Information with third parties if we transfer, purchase, merge or sell any part of our business or the business of a third party.
We contract with third-party service providers (e.g., banks, IT providers, payroll service providers, benefits providers), and your Candidate Personal Information may be disclosed to these to carry out certain business functions, such as IT support, payroll processing and administrative functions.

When Candidate Personal Information is transferred to or accessed from countries outside your home country, we implement appropriate safeguards as well as any legally required administrative, technical, and/or contractual requirements to protect your Candidate Personal Information. We perform transfers of data from the European Union and United Kingdom to outside the European Union and the United Kingdom, we utilize contractual protections (such as Standard Contractual Clauses). You may find these clauses here, or ask the contacts below for the applicable contracts.

Retention of Candidate Personal Information

We will only retain Candidate Personal Information for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory or internal policy requirements, whichever is longer. In general, although there may be exceptions, data relating to potential candidates for roles within the Company is kept for 12 months. Any maximum storage term set forth by applicable local law will prevail. If your application is successful, your application will be retained as part of your personnel record.

How We Protect Candidate Personal Information

We implement appropriate physical, administrative, contractual, and technical measures, such as encryption and access controls, designed to protect Candidate Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access or use, and all other unlawful forms of processing.

Your Rights

Subject to applicable law, you may have the following rights in relation to your Candidate Personal Information that we hold:

Right of access: To request information about the Candidate Personal Information stored about you.
Right to rectification: To request incorrect Candidate Personal Information be rectified.
Right to erasure (right to be forgotten): To request your Candidate Personal Information be deleted.
Right to restriction of processing: To request the restriction of processing of your Candidate Personal Information in certain cases.
Right to data portability: To request the data provided by you be provided in a structured, common and machine-readable format.
Right to object. To object to the processing of your Candidate Personal Information in certain circumstances. In such case, the controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Please note that the above rights may be limited under applicable data protection law. Depending on your location, you may have other or additional privacy rights.

Where our processing of your Candidate Personal Information is based on your consent, you have the right to withdraw your consent at any time. If you decide to withdraw your consent, we will stop processing your Candidate Personal Information, unless there is another lawful basis on which we can rely.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. You may submit a request through the applicable contacts below. If you have a complaint regarding the Company’s processing of your Candidate Personal Information, you may also lodge such complaints with the data protection authority in your country as applicable.

Changes to this Notice

We may modify this Notice to comply with changes in legal, regulatory, or operational requirements, our practices, and other factors. Where such changes materially affect our processing of your Candidate Personal Information or is otherwise required under applicable law, we will notify you accordingly.

Questions and Contacts

In most cases, the entity identified as the recruiting Company is the controller of your Candidate Personal Information, either solely or jointly with its affiliates within our group of companies. If you have any questions about controllership, please contact us using the contact information provided below.

If you have questions about your Candidate Personal Information or specific subsidiaries and affiliates that may have access to your Personal Information, please email us at the contacts below. If you have any questions concerning this Privacy Notice or wish to exercise your rights noted above, please contact one of data protection contacts below.

For All Proactive Health and Medibase Health Entities:

For Proactive Health and Medibase Health Entities Data Privacy – Peter@ptandco.com.au