Privacy Policy — Seers Digital

Our approach to privacy

Seers Group Australia Pty Ltd ("Seers Digital") is committed to protecting the privacy of its employees and meeting any privacy obligations set out in the Privacy Act 1988 (Cth) ("the Privacy Act") that might apply to it. The Privacy Act generally only applies to an organisation that has an annual turnover of more than $3 million. Any organisation covered by the Privacy Act must have a privacy policy in place which deals with the collection and use of individuals' personal information.

Seers Digital collects personal information in order to conduct its business and comply with a range of legislative requirements. The purpose of this policy is to explain how Seers Digital handles personal information of those who work with and for Seers Digital, and for job applicants. Seers Digital may also have a separate privacy policy that deals with the collection and use of personal information from clients, customers and other parties.

This policy covers two audiences. The first section below applies to website visitors and enquirers — anyone who browses seersdigital.au or submits an enquiry through our contact form, email, or phone. The remaining sections apply to employees, contractors and job applicants.

Website visitors and enquirers

This section explains how Seers Digital handles personal information collected through our website (seersdigital.au), contact forms, and related business enquiries. It is provided in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

What we collect

When you visit our website or contact us, we may collect:

Contact form and enquiry data — your name, work email address, phone number, company/organisation, job title, and the contents of any message or enquiry you submit. Our contact form is hosted via Microsoft Dynamics 365 Marketing, which processes form submissions on our behalf.
Correspondence — emails, call notes, meeting notes and any documents you share with us during the course of an enquiry, proposal, or engagement.
Technical and usage data — IP address, device and browser type, referring URL, pages viewed, and approximate location (derived from IP). This is collected via standard server logs and privacy-respecting analytics, and is used in aggregate to understand site performance and improve content.
Cookies and similar technologies — strictly necessary cookies required to operate the site, and limited analytics cookies. We do not use advertising or cross-site tracking cookies. You can disable cookies in your browser settings; some site features may not function without them.

We do not knowingly collect sensitive information (as defined in the Privacy Act) through the website, and we ask that you do not include sensitive information in contact form submissions.

How we use it

We use website visitor and enquirer information to:

respond to your enquiry, proposal request or question;
qualify, scope and follow up on potential engagements, including sending relevant information about our services;
issue and manage contracts, statements of work, invoices and related business records if we go on to work together;
operate, secure, monitor and improve the website and our services;
send service or relationship communications you have asked for or that relate to an active engagement;
comply with our legal, regulatory and contractual obligations.

We do not sell your personal information, and we do not use website enquiry data for unrelated marketing. We will only send marketing communications where you have opted in or where it is permitted under the Spam Act 2003 (Cth), and every such message includes an unsubscribe option.

Who we share it with

We share visitor and enquirer information only with parties who help us run our business and only to the extent necessary, including:

Microsoft (Dynamics 365, Microsoft 365, Azure) for form intake, CRM, email, file storage and hosting;
other technology service providers (e.g. website hosting, analytics, security tooling) under confidentiality obligations;
professional advisers (legal, accounting, insurance) where relevant;
government agencies, regulators or law enforcement where required or authorised by law.

Some of these providers may store or process data outside Australia (for example, in Microsoft data centres in other regions). Where this occurs, we take reasonable steps to ensure the recipient handles your personal information consistent with the Australian Privacy Principles.

How long we keep it

Contact form submissions and enquiries that do not progress to an engagement are retained for up to 24 months from last contact, after which they are deleted or anonymised.
Records relating to active or past client engagements (proposals, contracts, correspondence, deliverables and invoices) are retained for up to 7 years after the end of the engagement to meet contractual, tax and professional record-keeping obligations.
Website server logs and analytics are retained for up to 14 months in identifiable form, then aggregated or deleted.

Your rights — access, correction and deletion

You can ask us at any time to:

confirm what personal information we hold about you;
provide a copy of that information;
correct information that is inaccurate or out of date;
delete your information, or unsubscribe from any marketing communications.

To make a request, email privacy@seers.digital (or it@seers.digital) with the subject line "Privacy request" and enough detail for us to identify you and the information concerned. We will respond within a reasonable period (typically within 30 days). We may need to verify your identity before acting on a request, and we may refuse or partly refuse a request where the Privacy Act or another law permits or requires us to retain the information (for example, records we must keep for tax or contractual purposes).

Security

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure — including access controls, encryption in transit, and use of reputable cloud providers. No internet transmission is ever completely secure, and we ask that you do not send highly sensitive information through the contact form.

Children

Our website and services are directed at businesses and government organisations and are not intended for children. We do not knowingly collect personal information from anyone under 16.

Complaints

If you believe we have mishandled your personal information, please contact us first at privacy@seers.digital. We will acknowledge your complaint and aim to provide a substantive response within 30 days. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Employees, contractors and job applicants

The sections below set out how Seers Digital handles personal information of people who work with and for Seers Digital, and of job applicants.

Personal information is information relating to an individual which personally identifies an individual or makes the person's identity reasonably apparent.

Personal information may also include "sensitive information". Sensitive information is information or an opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record, health and biometric information or similar such information.

Sensitive information may be required to be collected in some circumstances. Seers Digital will only collect sensitive information if it is necessary for business purposes. Seers Digital will generally only collect sensitive information with your consent (unless otherwise permitted or required by law).

All information collected will be used and disclosed by Seers Digital only in accordance with this policy and the law. Seers Digital will take reasonable steps to ensure that all personal information is held securely.

Collection of personal information

Seers Digital will only collect personal information from individuals if it is reasonably necessary for Seers Digital's functions or activities.

Information provided by an individual

It is Seers Digital's usual practice to collect personal information from those who work with and for Seers Digital. In addition, as part of the recruitment process, Seers Digital may obtain information directly from a candidate as a result of their application to a job advertisement.

Furthermore, if a candidate's application is successful, as a condition of employment with Seers Digital, the successful candidate will likely be asked to provide evidence of their identity and legal entitlement to work in Australia. It is likely a successful candidate will also be asked to provide personal information, such as emergency contact details, tax file number, superannuation and bank account details, which will form part of an employee file.

Specifically, Seers Digital may collect personal information directly from an individual including:

recruitment and on-boarding information such as an application form and resume, emergency contact details, and details of previous employment;
contact details, including address, email address and phone number;
date of birth;
details of next of kin and emergency contact details;
gender;
identification documents including passport and driver's licence;
marital status and family details, including in relation to personal leave;
bank details (including bank name and location, BSB and account number) and information in relation to tax status; and
details of share and option plans.

Information provided by a third party

As part of the recruitment process, where relevant, and with the candidate's consent, Seers Digital may seek information about a candidate through a third party such as a recruitment service provider or a former employer. With the candidate's consent, Seers Digital may also seek information regarding:

prior employment history through reference checks;
eligibility to work in Australia through a visa status check;
educational qualifications by requesting confirmation of qualifications or results from an academic institution;
interview records and details of any pre-employment assessments, including aptitude or other psychometric testing; and
ability to perform the inherent requirements of the role, through medical and other allied health professionals, or criminal history check and/or working with children check.

Seers Digital may also access personal information through publicly available networking sites such as Facebook or LinkedIn.

Information collected during the course of employment

Seers Digital may also collect information about an individual and their work over the course of their employment with Seers Digital (or, for contractors, during the performance of a contract with Seers Digital). Such information may include:

details of any contract of employment (or contract for services) including start and end dates, department, role and location, reporting lines, title (including details of previous titles), working days and hours, details of promotions, details of bonuses, remuneration and salary (including details of previous remuneration), benefits and entitlements;
any information relating to disciplinary or grievance investigations and proceedings, including any warnings and related correspondence;
information relating to performance and behaviour at work, including appraisals, ratings, performance reviews, objectives, goals, and performance improvement plans;
details of attendance at work and absences, including annual and personal leave;
training records including training needs;
details of any expenses claimed; and
details of the use of Company property and equipment (including computers, swipe cards and telephone systems), emails and software.

Seers Digital may also collect other personal information if required or authorised to do so by law.

Use of personal information

The purposes for which Seers Digital may collect, use, and disclose personal information include (but are not limited to):

to establish, maintain and manage relationships, including to serve functions such as recruitment, payroll, appraisals, and any disciplinary action (including any termination of any employment or engagement) and managing employees' work and any claim in relation to any injuries or illnesses;
to assess or respond to claims, complaints, or conduct, or co-operate with investigations when required;
to obtain professional services as required including legal, human resources, industrial relations, accounting and insurance services;
work-related administrative purposes;
to finalise the terms of a contract, including pay rates;
to confirm eligibility to work in Australia;
to carry out a contract including, where relevant, its termination; to pay and provide other benefits in accordance with a contract;
to make travel bookings on an individual's behalf;
to allow you access to Seers Digital's buildings, and to ensure the security of Company buildings, confidential information and other Company property;
to reimburse expenses claimed;
to operate any share scheme including the granting of share options;
to operate schemes relating to sick leave, maternity leave, paternity leave, adoption leave, and parental leave;
deducting and paying appropriate tax and superannuation contributions;
to monitor and protect workplace health and safety;
to provide a reference upon request from another employer;
monitoring compliance with Company policies and Seers Digital's contractual obligations;
to comply with all applicable law; to liaise with any insurers in respect of any insurance policies that relate to you;
running Seers Digital's business and planning for the future;
the prevention and detection of fraud or other criminal offences;
to defend Seers Digital in respect of any investigation or litigation and to comply with any court or tribunal orders for disclosure;
otherwise as permitted or required by law; or
otherwise with your consent.

Use of your personal information on the Seers Digital website, for marketing purposes etc.

Seers Digital may use your personal information (for example, your name, image, job title and work contact details) on its website or in other publicly available resources where this is necessary for legitimate business purposes.

Seers Digital may also use this personal information for other marketing purposes, such as for displaying photos of staff on its website and in other marketing materials. In some circumstances it will be necessary to continue to use certain personal information (such as photos of you) on the Seers Digital website or in other marketing materials even after your employment has come to an end.

Seers Digital will always only use such personal information in a reasonable manner, taking into account your position within Seers Digital and the nature of your role. If you have any concerns about such use of your personal information, you should discuss this with your manager. Seers Digital will consider any such points raised.

Disclosure of personal information

Seers Digital may disclose personal information to third parties including:

other companies within Seers Digital's group;
employees and contractors working for Seers Digital, to the extent this is necessary for the operation of Seers Digital's business;
technology service providers, including internet service providers, cloud hosting service providers, software suppliers, maintenance and support service providers, and security services, on a confidential basis so that they can provide services to Seers Digital;
service providers such as banks;
external consultants such as legal, human resources, industrial relations, accounting, and insurance;
travel agents and suppliers of accommodation and travel services;
government agencies such as the ATO, Fair Work Ombudsman, WorkCover, etc.;
superannuation funds; and
other third parties as allowed by law or with your consent.

Accuracy and storage of personal information

Seers Digital will always endeavour to maintain an accurate record of all personal information it holds. Individuals should ensure that all personal information provided to Seers Digital is accurate and up to date and notify Seers Digital of any changes where required.

In addition, in order to ensure personal information is handled appropriately, individuals should:

only access personal data if they need to do so for the proper performance of their role;
not share personal data unless this is necessary for the proper performance of their role;
keep personal data secure and protected, and regularly review and update personal data as necessary;
not make unnecessary copies of personal data, and keep and dispose of any copies securely;
consider using strong passwords when protecting documents with personal data on them;
lock unattended computer screens and devices;
never leave computers, devices, electronic storage systems, files, paperwork or other things containing personal data in a manner that risks their unauthorised access or theft;
where appropriate, ensure that highly sensitive personal data is encrypted before being transferred electronically to authorised external contacts (where necessary, please speak to your manager or the IT department for more information on how to do this);
consider anonymising data or using separate keys/codes so that the data subject cannot be identified;
not save personal data to personal computers or other devices;
not take personal data away from the Company's premises unless required to do so for the proper performance of your role;
shred and/or securely dispose of personal data when finished with;
ask for help from your manager if unsure about data protection, or if any areas of data protection or security can be improved; and
immediately report any loss, unauthorised access, security risk or other issue that arises in respect of personal information to your manager.

Access to personal information

Personal information held by Seers Digital in respect of employees is subject to the "employee records exemption" under the Privacy Act and does not have to be disclosed on request.

Other persons, such as job applicants, can request copies of their personal information by contacting it@seers.digital.

Seers Digital may make reasonable charges for access to personal information and may refuse to provide access to, or delete, information where this is required or authorised by the Privacy Act or another law.

If personal information is incorrect, individuals may request that Seers Digital amend its records and Seers Digital will take reasonable steps to do so. Employees can do this by contacting their manager; other persons, such as job applicants, should use the contact details referred to above.

Raising a concern or a complaint

If you have any concerns about the use of your personal information (or of any other person's personal information) you should discuss this with your manager. Other persons, such as job applicants, should use the contact details above.

Seers Digital will generally ask for your concern or complaint to be put in writing and it will endeavour to provide a reply within 21 days.