Privacy policy

Privacy Policy – V1. 31 August 2026 issued by Prosperity People Solutions Pty Ltd

Prosperity People Solutions Pty Ltd (“we”, “us”, “our”, “PPS”) its subsidiaries and related entities have established this privacy policy to outline how we manage your personal information.

About us

Prosperity People Solutions Pty Ltd (“we”, “us”, “our” or “PPS”) is a division of Prosperity Services Pty Ltd, and we have established this privacy policy to outline how we manage your personal information:

candidates and prospective candidates;
job applicants;
employees and contractors of our clients;
referees;
client contacts and representatives;
prospective clients;
suppliers and service providers;
delivery partners; and
other individuals who interact with us.

We provide recruitment, HR consulting, outsourced talent acquisition, workforce strategy, leadership and performance, and related people advisory services. These services may include permanent, contract and interim recruitment, embedded talent support, organisational and workforce advice, HR support, leadership development and related services.

We are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and other applicable laws.

We take reasonable steps to ensure that the personal information we collect, use, share and may hold is limited to what is reasonably necessary to comply with our legal obligations and functions of our firm.

Information we collect

The types of personal information we collect depend on your relationship with us and the services we provide.

Candidates and job applicants

We may collect:

name, address, telephone number and email address;
resume, curriculum vitae and cover letter;
employment and career history;
current and previous position titles;
education, qualifications, licences, memberships and professional registrations;
skills, experience and areas of expertise;
LinkedIn profile and other professional or publicly available profile information;
salary, remuneration and benefit information;
salary expectations;
location, mobility and work preferences;
preferred employment type and availability;
interview notes, screening records and assessment outcomes;
details of roles for which you have applied or been considered;
communications and records of our dealings with you;
referee names and contact details;
reference-check information;
information about your right to work in Australia;
passport, visa or other identification information where reasonably necessary;
feedback provided by prospective employers or clients; and
information you choose to provide to us.

Clients and client representatives

We may collect:

name, position title and business contact details;
information about the client’s business, workforce and organisational structure;
position descriptions, recruitment briefs and hiring requirements;
proposed salary, remuneration, incentives and benefits;
information about employees, contractors or candidates relevant to an engagement;
workforce planning, organisational design and succession information;
HR, performance, workplace and employee-relations information supplied for an engagement;
billing, contractual and engagement information;
complaints, feedback and service records; and
communications and records created during the client relationship.

The internal operating model anticipates that recruitment briefs may include remuneration, benefits and job-description information and that HR engagements may involve broader employee information held within a client’s own systems.

Sensitive information

In limited circumstances, we may collect sensitive information where:

it is reasonably necessary for our functions or activities;
you have consented;
it is required or authorised by law; or
another exception under applicable privacy law applies.

Sensitive information may include:

health information relevant to a role or workplace engagement;
criminal-history or background-check information;
professional association or trade-union membership;
information about racial or ethnic origin where lawfully required for a specific purpose;
disability or workplace-adjustment information;
biometric information, if expressly required and lawfully collected; or
other sensitive information disclosed during an HR consulting, workplace investigation, mediation or related engagement.

We will not ordinarily seek sensitive information unless it is relevant to a specific role, service or legal requirement.

Identity and right-to-work information

Where requested by a client or required for a recruitment process, we may collect information necessary to verify identity or work rights. This may include:

citizenship or residency status;
visa details;
work entitlements;
passport details;
a copy of an identity document; or
the outcome of a work-rights verification.

We will limit the collection of identity documents to what is reasonably necessary. Where we no longer require a copy of an identity document, we will take reasonable steps to securely destroy or de-identify it, subject to any legal or record-retention obligation.

In some cases, we may collect sensitive information, including;

Identity verification data
Biometric information used for biometric identity verification or identification
Biometric checks are based on a photograph ‘selfie’ of your face. We will always ask you separately for your expressed consent prior to collecting your ‘selfie’. Your photograph will be shared with our identity service providers for the purpose of performing the relevant identity check.

How we collect

We may collect personal information:

directly from you;
when you apply for a position;
through our website, application forms or job advertisements;
by email, telephone, video conference, interview or meeting;
through LinkedIn or other professional networking platforms;
when we directly approach you about an opportunity;
from a client or prospective employer;
from referees nominated by you;
from recruitment platforms and job boards;
through an applicant tracking system or candidate database;
from our related entities and cross-servicing referrals;
through approved delivery partners and service providers;
from professional advisers;
from publicly available professional sources;
from government registers or verification services where permitted; or
as otherwise authorised or required by law.

If you provide personal information about another person, such as a referee, employee or client contact, you should ensure that you are authorised to provide it and that the person is aware of the relevant circumstances of collection.

Where practicable, we will collect personal information directly from the individual concerned.

Unsolicited personal information

We may receive information about you that we did not request, including a resume sent by a third party or information supplied in a referral.

Where we receive unsolicited personal information, we will consider whether we could lawfully have collected it ourselves.

If we could not lawfully collect it, or it is not reasonably necessary for our functions or activities, we will take reasonable steps to destroy or de-identify it, where lawful and practicable.

We do not retain personal information merely because it might become useful at an unspecified future time.

Purpose of collection

We collect, hold, use and disclose personal information that is necessary for us to provide you with a product or service such as:

provide recruitment and people advisory services;
register and maintain candidate profiles;
assess a candidate’s qualifications, experience, skills, suitability and availability;
identify current or future employment and contracting opportunities;
communicate with candidates about relevant opportunities;
present authorised candidate information to clients or prospective employers;
arrange and conduct interviews;
conduct reference, qualification, identity and work-rights checks;
manage recruitment, placement and onboarding activities;
perform HR consulting and outsourced talent-acquisition services;
provide workforce strategy, organisational design, leadership and performance services;
conduct workplace reviews, investigations, mediations or other agreed HR services;
respond to enquiries and requests;
prepare proposals, scopes, engagement documents and service agreements;
administer our relationship with clients, candidates and service providers;
provide updates about our services where permitted;
manage complaints, disputes, incidents and feedback;
carry out quality assurance, risk management, business analysis and training;
maintain and improve our services, processes and technology;
prevent or investigate fraud, misconduct, security incidents or unlawful activity;
comply with legal, regulatory, professional and contractual obligations; and
establish, exercise or defend legal claims.

If you do not provide information that is reasonably required, we may be unable to:

assess you for an opportunity;
represent you to a prospective employer;
complete a placement or verification process;
provide an agreed client service; or
respond fully to your enquiry.

Candidate representation

We will ordinarily seek your authority before disclosing your identifiable resume or candidate profile to a prospective employer for a particular opportunity.

Authority may be obtained in writing, by email, through an online process or through another appropriate recorded method.

Where practical, we will explain:

the position or type of opportunity;
the prospective employer or class of prospective employers;
the information proposed to be disclosed; and
the purpose of the disclosure.

We may disclose information without further authority where the disclosure is required or authorised by law, or where another permitted basis under applicable privacy law applies.

Disclosure of information

As part of the service delivery and to manage risk and compliance, we may disclose your personal information within our group. We hold offices in Australia and Manila and the broader Asia Pacific region. We may also disclose your personal information to:

clients and prospective employers;
companies considering engaging a candidate or contractor;
referees;
related entities within Prosperity Services Pty Ltd;
approved recruitment, HR, technology service providers, third party providers;
approved delivery partners performing services for or on our behalf;
applicant tracking, candidate management and recruitment-platform providers;
job-advertising platforms and professional networking services;
background, identity, qualification and work-rights verification providers;
payroll, onboarding or contractor-management providers;
cloud, hosting, cyber security, email, document-management and IT providers;
professional advisers, insurers, auditors and consultants;
regulators, courts, law-enforcement bodies and government agencies;
a purchaser, successor or adviser involved in a proposed or actual business transaction; and
other recipients with your consent or where required or authorised by law.

We will only disclose information to the extent reasonably necessary for the relevant purpose.

In some instances, we may link to or embed content from third party providers (for example, external websites or applications). These third parties may independently use cookies or similar technologies when you interact with their services. We do not control these technologies and are not responsible for their use. We encourage you to review the privacy policies of any third party providers you engage with.

Where we outsource services that require the disclosure of your Personal Information to an overseas recipient, we will take reasonable steps to ensure, by contract or otherwise, the recipient complies with the Australian Privacy Principles. We do not accept responsibility for any act or omission by those providers this is outside of our control.

Delivery partners

Some services may be performed with the assistance of an approved delivery partner. A delivery partner may interact directly with a client or individual while providing services for or on behalf of Prosperity People Solutions.

Where a delivery partner handles personal information in connection with our services, we will take reasonable steps appropriate to the circumstances to require that it:

uses the information only for the agreed services;
restricts access to authorised personnel;
protects the information against unauthorised access, use, loss and disclosure;
does not subcontract, offshore or materially change its processing arrangements without approval;
notifies us promptly of actual or suspected privacy or security incidents;
assists us to respond to access, correction, complaint and data-breach matters; and
returns or securely destroys information when it is no longer required.

The current approved-provider agreement treats the provider as an independent service provider, requires compliance with Prosperity policies, and prohibits unapproved subcontracting or offshoring.

Related entities

We may share personal information with related entities within Prosperity Advisers Group where reasonably necessary to:

manage a client or candidate relationship;
provide coordinated services;
make an appropriate internal referral;
administer systems and business operations;
manage risk, compliance and quality;
obtain specialist assistance; or
otherwise provide the services requested.

Where a client receives coordinated services across Prosperity, we will seek to ensure that information is shared only with personnel who need it for an authorised purpose.

Overseas disclosure

We may use third-party software, cloud, recruitment, communications and technology providers whose systems, support personnel or related entities are located outside Australia.

Some of these service providers may store or process data outside Australia, including the Philippines, the United States, Europe, the United Kingdom and other countries in which our technology providers operate.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that the recipient handles the information in a manner consistent with Australian privacy laws unless an exception applies.

Access and correction

If you believe or become aware, that any personal information we hold is incorrect, incomplete or inaccurate, you should contact our office and request amendments to your details. You may request correction of the personal information that we hold about you at any time by contacting us.

In some circumstances, we may not be able to provide access, as permitted by law. We will provide you with a written notice that sets out the reasons for the refusal.

You have the option to opt out or unsubscribe, to receiving direct marketing communications from us at any time.

Anonymously

Where lawful and practicable, you may interact with us anonymously or by using a pseudonym.

However, in most recruitment, candidate representation, employment verification and client service situations, we will need to know your identity to provide the requested service.

Website cookies

Our website may use cookies and similar technologies to:

operate website functionality;
remember preferences;
understand website use and performance;
support security;
manage application and enquiry forms; and
support advertising or remarketing, where implemented.

We may link to or embed third-party websites, job boards, professional networks, maps, videos or applications. Those third parties have their own privacy practices, and we encourage you to review their policies.

Direct marketing and talent communications

We may contact you about:

roles or opportunities that may be relevant to your experience;
recruitment-market information;
events, insights or services;
updates relevant to an existing relationship; or
other communications permitted by law.

You may ask us not to send direct marketing communications at any time by:

using the unsubscribe option in the communication; or
contacting us using the details below.

Opting out of marketing will not prevent us from contacting you about an active application, placement, engagement or service matter.

Storage and security

Our staff are trained in line with Australian privacy laws and our internal policies to ensure your personal information is handled safely and securely. We use secure systems, facilities and data centres located within Australia and The United States of America to store and protect your information.

We take reasonable steps to protect your personal information from misuse, leaks, interference and loss, and from unauthorised access, modification or disclosure.

This includes but not limited to:

secure systems and access controls
role-based permissions
encryption and multi-factor authentication
confidentiality obligations and staff training
monitoring and security governance processes

Our commitment to complying with the Australian Privacy Principles helps reduce the risk of unauthorised access to, misuse of, or loss of personal information throughout its lifecycle, including its collection, storage, use, disclosure, and disposal.

Despite the safeguards we have in place, no method of transmitting or storing information is completely secure. In the unlikely event of a data breach involving personal information that is likely to result in serious harm, we will respond in accordance with our Data Breach Response Plan and applicable legal obligations, including the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth). Where required, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) and provide information about steps that may be taken to reduce the risk of harm.

We may hold personal information in:

Prosperity systems;
email and document-management systems;
secure cloud services;
applicant tracking and candidate-management systems;
approved delivery-partner systems;
client systems, where we are engaged to work within those systems; and
limited physical records where required.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

These measures may include:

access controls and role-based permissions;
multi-factor authentication;
encryption and secure information transfer;
approved systems and data locations;
confidentially obligations;
privacy and cyber security training;
incident monitoring and escalation;
supplier and delivery-partner due diligence;
contractual privacy and security requirements; and
secure destruction or de-identification processes.

Despite the safeguards we have in place, no method of transmitting or storing information is completely secure. In the unlikely event of a data breach involving personal information that is likely to result in serious harm, we will respond in accordance with our Data Breach Response Plan and applicable legal obligations, including the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth). Where required, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) and provide information about steps that may be taken to reduce the risk of harm.

Retention and deletion

We retain personal information only for as long as reasonably necessary for:

the purpose for which it was collected;
an ongoing candidate, placement or client relationship;
a reasonable future recruitment purpose;
legal, regulatory, insurance or professional obligations;
dispute or complaint management; or
another lawful business requirement.

Retention periods may differ according to the information and the relationship concerned.

When personal information is no longer required, we will take reasonable steps to securely destroy or de-identify it, unless retention is required or authorised by law.

Copies of identity documents and highly sensitive verification material should not be retained longer than necessary to complete the relevant check, subject to documented legal and operational requirements.

Use of AI tools

We may use automated systems, including artificial intelligence (AI) and data analytics tools, to support productivity, processes and record-keeping. This may involve the recording of meetings via our provider, to generate transcripts, summaries, or written minutes. Further use may be assisting with communications, summarising notes and automating workflows.

We maintain practices, procedures, and systems designed to ensure compliance with privacy obligations, including the responsible use of AI technologies. In line with APP 5, you will be notified, or otherwise made aware, when your personal information is being collected and recorded for documentation purposes.

Where AI systems may collect sensitive information, consent will be obtained prior to recording wherever practicable.

These tools may be used to support:

resume parsing and data extraction;
candidate database searches;
matching candidates with position requirements;
identifying potentially relevant candidates;
sorting or prioritising applications for review;
drafting communications;
summarising notes;
scheduling and workflow administration;
record keeping;
risk, fraud or compliance monitoring; and
improving our services and processes.

Information extracted or generated by these systems may include a candidate’s contact details, employment history, qualifications, skills and other information contained in a resume or professional profile.

Automated outputs are intended to support, not replace, professional review. We will take reasonable steps to ensure that material recruitment and employment-related decisions remain subject to appropriate human review and professional judgement.

We take reasonable steps to ensure these technologies are used responsibly, securely and in accordance with applicable laws.

Digital and website information

When you visit our website or use our digital services, we may collect:

IP address;
browser and device information;
date and time of access;
pages visited and actions taken;
enquiry-form information;
cookie and similar technology information; and
records generated through online applications or communications

Confidential information

At times we are required to disclose your personal information

where disclosure is expressly permitted under this Policy
to the extent either party is bound to comply with any law; or
where confidential information has entered the public domain other then as a result of a breach of this Policy.

Complaints and contact details

If you feel we have breached your rights under the Privacy Act 1988 (Cth) (in particular the Australian Privacy Principles) or we have not abided by this Privacy Policy you can contact us, as listed under the contact details below. Your complaint will be considered within 7 days and responded to within 30days.

We request complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint.

It is our intention to use our best endeavors to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Consent

This policy is issued in accordance with applicable laws and regulatory requirements.

This policy explains our general personal-information handling practices. It is not intended to constitute a legally binding contract between you and us.

Where consent is required for a particular collection, use or disclosure, we may seek it separately through:

an application or registration form;
a collection notice;
written or email authority;
an online acknowledgment;
a client engagement document;
a recorded verbal process; or
another appropriate method.

If you withdraw a consent that is required for a service, we may be unable to continue that service or represent you in relation to an opportunity.

Additional privacy information

Further information on privacy in Australia may be obtained by visiting the web site of the Office of the Australian Privacy Commissioner at www.oaic.gov.au.

We may update this Privacy Policy from time to time. The latest version will be available on our website.

Contact details

If you have any questions about this Privacy Policy or any concerns, they may contact our Privacy Officer using the details set out below. Individuals can write to:

Prosperity Services Pty Ltd

Attn: Privacy Officer
E: compliance@prosperity.com.au
PO Box 234
Newcastle NSW 2300
T: (02) 4907 7222
F: (02) 4929 6759