Pass Technology is committed to complying with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act) and to being open and transparent about our personal information handling practices. Pass Technology has opted-in to be bound by the APPs, as can be confirmed on the website of the Office of the Australian Information Commissioner (OAIC). We respect the confidentiality of the personal information that we hold and take steps to safeguard that information.
1 The personal information we collect (and why)
Pass Technology needs to collect personal information (meaning ‘personal information as defined in the Privacy Act) to provide our services (PT Services) including conducting employment screening and providing probity information related to applicants (Applicants) who are seeking:
- Australian citizenship; and/or
- appointments to positions of trust.
National Police Checking Service information
Pass Technology is classified an Accredited Body by the Australian Criminal Intelligence Commission (ACIC) meaning it has been authorised to use ACIC’s National Police Checking Service (NPC Service) to help individuals apply for, and submit, a Nationally coordinated criminal history check (National Police Check).
Accredited Bodies may use the NPC Service to request National Police Checks for:
- their own employees;
- any individual; and/or
- another organisation (known as a Legal Entity Customer or Related Government Entity).
As an Accredited Body, Pass Technology may submit National Police Checks on behalf of individual Applicants or our clients (Clients) either directly or via another Legal Entity Customer of the NPC Service.
A National Police Check is a name-based search against ACIC’s database to identify any potential criminal conviction information or police information relevant to an Applicant’s application.
Personal information that may be collected using the ACIC NPC Service includes police interaction and conviction information about an individual that has been determined releasable by Australia’s police agencies.
Other PT Service information
We also need to collect personal information to effectively run our business and to provide our PT Services, including verifying the identity of Applicants. In particular, we may collect and hold the following personal information in relation to Applicants:
- contact details (including, but not limited to, full name and address);
- address history;
- identification information (including date of birth and passport information);
- biometric information (including facial biometric data from photographs);
- information relating to criminal convictions; and/or
- information relating to firearm and vehicle registration.
To provide our PT Services in relation to verifying the identity of Applicants, we use the Australian Government’s Document Verification Service (DVS) to check the identity information on Australian Government issued identity documents and we collect the results provided by the DVS.
Our explains how we handle personal information collected via this website including our Cookies Policy.
2 How we collect personal information
Where it is practicable to do so, we collect personal information directly from the individual it relates to. However, there may be circumstances where we need to collect personal information from a third party such as our Clients who are seeking our PT Services in response to an application by the Applicant, or from another ACIC Accredited Body that is a Legal Entity Customer. We may also collect personal information indirectly, for example, where it is included in a communication with us.
Some examples of how we collect personal information include:
- directly from individuals during telephone calls or meetings;
- through other forms of communication such as when individuals email us;
- through our website; and
- when we are permitted or required to collect personal information by or under law.
To provide our PT Services, we collect personal information directly from individuals via a web- based portal for our Clients to input data and upload documents, including identity documents and photographs, provided via a face-to-face interview with Applicants.
We take steps to ensure that individuals, including Applicants, provide their informed consent for the handling of their personal information by us.
3 Storage and security of personal information
We take the security of the personal information we hold seriously and take measures to ensure its protection. All Pass Technology staff handle personal information sensitively and in accordance with the APPs.
We take all reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include using electronic and physical security measures, including password protected software and hardware.
If we no longer need the personal information that we hold physical copies of we take reasonable steps to destroy or de-identify that information. It may be necessary for us to retain personal information to comply with our legal obligations, or for insurance or audit purposes. Personal information stored electronically may be stored securely for IT back up and electronic audit trail purposes.
In relation to personal information stored for the purposes of conducting National Police Checks, to meet our obligations as an Accredited Body with the ACIC we will retain the application information of an Applicant and any identity documents remotely presented by the Applicant for a minimum period of twelve (12) months after the application to use our PT Services was submitted.
4 How we use personal information and for what purposes
We use the personal information that we collect in order to provide our PT Services, such as conducting National Police Checks on behalf of Applicants and/or Clients and checking the identity information on Applicant identity documents, including via the DVS.
Where necessary, we may use personal information to comply with applicable laws (e.g. to meet obligations we may have under legislation).
We use the personal information that we hold for audit and quality assurance purposes to ensure that access to the personal information we hold is monitored, recorded and auditable. We also use the personal information that we hold to develop and train staff on system improvements and enhancements.
Access to, and use of, personal information held by us in relation to Applicants is consistent with the APPs and the Australian Government’s Protective Security Policy Framework. In order to use an Applicant’s personal information for the purposes of providing our PT Services, we take steps to ensure that the Applicant has provided informed consent for the handling of their information by us.
We only use personal information in accordance with APPs and are committed to maintaining confidentiality.
5 Disclosure of personal information
As part of providing our PT Services we may disclose the personal information that we collect:
- to the ACIC NPC Service to submit National Police Checks;
- to another ACIC Accredited Body that is a Legal Customer Entity;
- via the DVS to check identity information on identity documents; and/or
- to our Clients using our PT Services on behalf of Applicants.
In order to conduct our business and provide our PT Services, we may disclose personal information where permitted under the APPs, including:
- where the individual to whom the information relates agrees to the disclosure by providing their informed consent;
- where the disclosure is for the primary purpose that the personal information was collected;
- in circumstances where the individual about whom the personal information relates would reasonably expect this disclosure to occur; and/or
- where required to do so by law.
We do not disclose personal information overseas.
Definitions and interpretation
collectively all information that you submit to Pass Software Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
the General Data Protection Regulation (EU) 2016/679;
Pass Software Limited, or us
Pass Software Limited, a company incorporated in England and Wales with registered number 2 whose registered office is at Argon Mews, Fulham Broadway, London , SW61BJ;
UK and EU Cookie Law
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronxic Communications (EC Directive) (Amendment) Regulations 2011;
User or you
any third party that accesses the Website and is not either (i) employed by Pass Software Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Pass Software Limited and accessing the Website in connection with the provision of such services; and
the website that you are currently using, https://passtechnology.com/, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- the singular includes the plural and vice versa;
- a reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, Pass Software Limited is the “data controller”. This means that Pass Software Limited determines the purposes for which, and the manner in which, your Data is processed.
We may collect the following Data, which includes personal Data, from you:
- job title;
- contact Information such as email addresses and telephone numbers;
- IP address (automatically collected);
- web browser type and version (automatically collected);
- a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
How we collect Data
We collect Data in the following ways:
- data is given to us by you;
- data is received from other sources; and
- data is collected automatically.
- Data that is given to us by you
- Pass Software Limited will collect your Data in a number of ways, for example:
- when you contact us through the Website, by telephone, post, e-mail or through any other means;
- when you enter a competition or promotion through a social media channel;
- when you elect to receive marketing communications from us;
- When you fill in a ‘Contact Us’ form on the PASS website;
Data that is received from third parties
Pass Software Limited will receive Data about you from the following third parties:
- Lead Forensics;
Data that is received from publicly available third parties sources
We will receive Data about you from the following publicly available third party sources:
- Companies House;
Data that is collected automatically
To the extent that you access the Website, we will collect your Data automatically, for example:
- we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.
Our use of Data
Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- improvement of our products / services;
- transmission by email of marketing materials that may be of interest to you;
- contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
Who we share Data with
We may share your Data with the following groups of people for the following reasons:
- our employees, agents and/or professional advisors – to enable us to respond to your query in the most relevant and helpful manner;
Keeping Data secure
We will use technical and organisational measures to safeguard your Data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your Data on secure servers.
We are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.
Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
You have the following rights in relation to your Data:
- Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- Right to erase – the right to request that we delete or remove your Data from our systems.
- Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- Right to data portability – the right to request that we move, copy or transfer your Data.
- Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org.
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
We may also disclose Data to a prospective purchaser of our business or any part of it.
In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
You may contact Pass Software Limited by email at email@example.com.
06 July 2018