1. About This Privacy Policy

This Privacy Policy explains how Aussie Remote Operations Pty Ltd (ABN 84 695 192 897), trading as AMOS – Australian Managed Offshore Solutions (AMOS, we, us or our), collects, holds, uses, discloses, manages and protects personal information.

This Privacy Policy applies to personal information handled by AMOS in connection with its business activities and services, including:

• the AMOS Talent Network;

• Talent Network Advertising Memberships;

• professional profile applications and publication;

• recruitment and candidate processes;

• business introduction requests;

• recruitment, onboarding and managed workforce services;

• prospective and existing client relationships;

• contractors and service providers;

• AMOS websites, forms and online services;

• verification and professional assessment activities; and

• other communications and dealings with AMOS.

Different AMOS services may involve different information, purposes, recipients and privacy considerations. AMOS may therefore provide additional privacy notices, collection notices, permissions or consent requests in connection with a particular service or activity.

Where the Privacy Act 1988 (Cth) and the Australian Privacy Principles apply to AMOS or a particular activity, AMOS will handle personal information consistently with those requirements.

Some AMOS activities, individuals or information may also be subject to privacy, data-protection or other laws outside Australia. Where applicable, those requirements will be considered according to the relevant service, individual, location and circumstances.

References in this Privacy Policy to Australian privacy requirements do not mean that every AMOS activity, transaction or individual is necessarily covered by the Privacy Act.

Where a particular statutory privacy obligation does not apply, AMOS may nevertheless adopt similar practices as part of its internal privacy and information-management standards.

This Privacy Policy describes how AMOS manages personal information. Acceptance of this Privacy Policy does not by itself constitute blanket consent to every possible collection, publication, disclosure or future use of personal information.

Where specific consent, authority or permission is required for a particular activity, AMOS may obtain that separately.

Nothing in this Privacy Policy limits any privacy, consumer or other legal right that cannot lawfully be excluded.

2. What Personal Information We May Collect

The kinds of personal information AMOS may collect depend on the person's relationship with AMOS and the services or activities involved.

AMOS may collect information including the following.

Identity and Contact Information

This may include:

• full name;

• professional or display name;

• email address;

• telephone number;

• country, region, general location or time zone;

• account or login information;

• date of birth where reasonably required for verification or another legitimate purpose;

• identity-document information where verification is undertaken; and

• other contact or identity information reasonably required to administer an AMOS service.

Professional and Career Information

This may include:

• CV or résumé information;

• employment and engagement history;

• professional experience;

• qualifications and certifications;

• professional licences or registrations;

• skills and capabilities;

• software and systems knowledge;

• industry experience;

• professional achievements;

• work availability;

• preferred working arrangements or hours;

• portfolio material;

• work samples;

• professional photographs;

• introduction videos;

• LinkedIn or other professional profile links;

• references and referee details; and

• other professional information relevant to a profile, application, verification or engagement.

Talent Network, Recruitment and Verification Information

This may include:

• Talent Network applications;

• profile information and preferences;

• publication permissions;

• selected categories, industries and roles;

• availability and opportunity preferences;

• verification records and status;

• interview information;

• professional and communication assessments;

• skills or systems assessment results;

• reference-check information;

• background-check information where applicable;

• recruitment and matching records;

• onboarding information;

• business introduction requests; and

• records relating to AMOS-managed workforce activities.

Client and Business Information

Where a person represents or operates a business, AMOS may collect:

• business or company name;

• business contact information;

• representative name and position;

• service requirements;

• proposed roles or functions;

• skill and experience requirements;

• proposed hours and working arrangements;

• introduction requests;

• enquiries and correspondence;

• service or contractual information; and

• other information reasonably required to understand or provide the requested service.

Membership, Payment and Transaction Information

This may include:

• selected membership plan;

• billing name and email;

• payment status;

• transaction identifiers;

• membership and subscription status;

• renewal information;

• cancellation information;

• refunds or payment disputes; and

• other records reasonably required to administer payments, memberships or services.

Where payments are processed directly through an authorised third-party payment provider, AMOS does not ordinarily need to receive or store the member's complete payment-card number.

Website, Device and Security Information

Depending on the technology and service being used, AMOS may collect information including:

• IP address;

• browser or device information;

• approximate location derived from technical information;

• website and form activity;

• account or login activity;

• referral information;

• security events;

• fraud-prevention information; and

• other technical information reasonably required to operate, protect or improve AMOS systems and services.

AMOS may also create administrative or operational records from its interactions with an individual, including profile categories, verification outcomes, service history, quality-control records, security records and similar internal business records.

AMOS will seek to collect information that is reasonably appropriate and proportionate to the relevant function, service or activity, and will avoid collecting personal information that is unnecessarily excessive for that purpose.

3. Sensitive Information

AMOS does not ordinarily require sensitive information simply for a person to apply for or maintain an AMOS Talent Network Advertising Membership.

Sensitive information may nevertheless be collected in limited circumstances where it is reasonably necessary and legally permitted in connection with matters such as:

• an authorised criminal-history or background check;

• verification required for a particular professional role;

• a legal, regulatory or contractual compliance requirement;

• a separate recruitment or managed workforce process;

• a particular safety, workplace or client requirement;

• establishing, exercising or defending a legal claim; or

• another legitimate activity for which sensitive information may lawfully be collected.

Sensitive information may include criminal-record information, health information and other categories treated as sensitive information under applicable law.

AMOS will not intentionally request information concerning a person's race or ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, health or other sensitive matters merely for the purpose of creating an ordinary Talent Network advertising profile where that information is not reasonably necessary.

Where consent is required for the collection of sensitive information, AMOS will seek consent appropriate to the particular information and purpose.

Sensitive information will not ordinarily be displayed in a public Talent Network profile.

Criminal-history records, identity-verification documents, health information and other designated sensitive records will generally be treated as restricted information rather than public profile information.

If AMOS receives sensitive information that it did not request, AMOS may assess whether the information could lawfully and appropriately be retained. Where appropriate, the information may be:

• securely deleted;

• de-identified;

• returned;

• access-restricted; or

• retained only for an applicable lawful purpose.

AMOS will not use sensitive information for unrelated advertising or marketing merely because the information has been supplied to AMOS.

4. How We Collect Personal Information

AMOS may collect personal information directly from an individual when they:

• submit a Talent Network application;

• create, approve or update a professional profile;

• purchase or administer a membership;

• provide a CV, résumé, photograph, portfolio, work sample or introduction video;

• participate in an interview, skills assessment or verification process;

• provide referee information;

• request or respond to a business introduction;

• apply for or express interest in an opportunity;

• enquire about recruitment, managed workforce or other AMOS services;

• become an AMOS client or represent an AMOS client;

• complete a website or online form;

• communicate with AMOS by email, telephone, website, messaging service or social media; or

• otherwise interact with AMOS.

Where reasonably appropriate and permitted, AMOS may also collect relevant personal information from other sources, including:

• referees nominated or authorised by the individual;

• prospective or existing clients involved in a relevant enquiry, application or engagement;

• businesses requesting talent;

• authorised recruitment, identity, reference or background-check providers;

• payment providers;

• AMOS technology and administration providers;

• professional networking platforms;

• publicly available professional sources; and

• another person authorised to provide information to AMOS.

Where practicable and appropriate, AMOS will collect personal information directly from the individual concerned.

Where information is obtained from a third party or publicly available source, AMOS will seek to ensure that the method and purpose of collection are lawful, fair and reasonably connected with an AMOS function or activity.

The fact that personal information is publicly available does not by itself give AMOS unrestricted permission to collect, republish, disclose, sell or otherwise use that information for any purpose.

AMOS may collect publicly available professional information where reasonably appropriate for legitimate activities such as:

• confirming professional information supplied to AMOS;

• assessing an application;

• professional research;

• fraud or identity checks;

• recruitment activities;

• identifying prospective business contacts; or

• other lawful AMOS business activities.

Any later use or disclosure remains subject to applicable law and this Privacy Policy.

AMOS may also receive personal information that it did not request. Where applicable, AMOS may determine whether that information could lawfully and appropriately be retained and whether it should be retained, restricted, destroyed or de-identified.

Where practicable and lawful, a person may make a general enquiry to AMOS without identifying themselves or may use a pseudonym.

Identification may be required where AMOS reasonably needs to establish a person's identity or where it would be impracticable to provide the relevant service without doing so, including for:

• paid memberships;

• profile publication;

• verification;

• identity or background checks;

• payments and billing;

• account administration;

• access or correction requests;

• contracts;

• recruitment or work arrangements;

• fraud or security investigations; or

• compliance with applicable law.

5. Why We Collect, Use and Disclose Personal Information

AMOS may collect, hold, use and disclose personal information where reasonably necessary for purposes connected with its business activities and services, including to:

• administer Talent Network applications and memberships;

• create, review, categorise, maintain and publish authorised professional profiles;

• administer membership payments, subscriptions, renewals and cancellations;

• verify identity and professional information;

• conduct authorised interviews, assessments, reference checks and background checks;

• assess eligibility for AMOS verification, profile status or promotional opportunities;

• facilitate authorised business contact and introduction requests;

• communicate relevant business interest to Talent Network members;

• provide recruitment, sourcing, matching, shortlisting, onboarding and managed workforce services where those services apply;

• communicate with applicants, members, clients, businesses, contractors and service providers;

• manage account administration and profile updates;

• publish and promote authorised Talent Network profile information through AMOS websites, social media and other approved promotional channels, including New Member Spotlights, Talent Spotlights, Featured Talent and other Talent Network promotional features;

• provide service, account, security and operational communications;

• communicate relevant AMOS opportunities where reasonably appropriate or authorised;

• provide customer support and respond to enquiries;

• prevent and investigate fraud, impersonation, misuse, unauthorised access and security incidents;

• investigate complaints and disputes;

• maintain appropriate business and service records;

• administer AMOS technology, systems and service providers;

• analyse, maintain and improve AMOS services, systems, website performance and business operations;

• comply with contractual, legal, regulatory, taxation, accounting and recordkeeping requirements; and

• establish, exercise or defend AMOS's lawful rights and interests.

AMOS may also use or disclose personal information for another purpose where:

• the individual would reasonably expect the use or disclosure and it is permitted by applicable law;

• appropriate consent or authorisation has been provided;

• the use or disclosure is required or authorised by law; or

• another lawful basis applies.

AMOS will not treat acceptance of this Privacy Policy as blanket consent to materially unrelated future uses or disclosures of personal information.

Where a materially different use or disclosure requires further consent, authority or notification, AMOS may obtain that consent or provide the required notice before proceeding.

Operational or transactional communications required to administer an application, account, membership, payment, introduction, recruitment process or existing service are separate from optional marketing communications.

6. Public Talent Profiles

AMOS Talent Network members may authorise approved professional information to be displayed publicly or made discoverable to businesses through the AMOS website and related Talent Network services.

Public or discoverable profile information may include:

• first name or approved professional display name;

• professional photograph;

• country, region or general location;

• professional headline or role description;

• skills and service categories;

• industry experience;

• qualifications and certifications;

• relevant professional licences or registrations;

• software and systems knowledge;

• employment or professional experience;

• professional achievements;

• work availability;

• preferred working arrangements;

• portfolio information and work samples;

• LinkedIn or other professional links;

• introduction videos;

• AMOS verification or profile status; and

• other professional information approved for publication.

Before publication, AMOS may review, format, categorise or request clarification of profile information to support accuracy, consistency, lawful publication and professional presentation.

Members remain responsible for ensuring that information they provide for public display is accurate, current, lawful and suitable for publication.

AMOS will distinguish, where reasonably practicable, between:

• information authorised for public display;

• information authorised only for restricted business access; and

• information retained privately by AMOS.

Private information such as residential addresses, identity documents, complete payment information, private verification records and other designated confidential information will not ordinarily be included in a public Talent Network profile.

A member may request correction, updating, hiding or removal of their public profile in accordance with the applicable Membership Terms and this Privacy Policy.

Removal of a profile from AMOS-controlled systems does not necessarily result in immediate removal of copies previously indexed, cached, archived or independently retained by search engines or other third parties outside AMOS's reasonable control.

Public profile publication is intended to provide professional advertising and visibility. It does not guarantee business enquiries, introductions, interviews, employment, contractor engagements, income or other paid work.

7. Private Information and Protected Contact Details

AMOS does not ordinarily publish a member's private contact or administrative information.

Private or restricted information may include personal email addresses, telephone numbers, residential addresses, dates of birth, identity documents, payment information, references, background checks, verification records, account information and private correspondence.

This information is generally kept separate from the member's public Talent Network profile.

Membership does not give AMOS blanket permission to publicly disclose private information. AMOS may use or disclose it where reasonably necessary for the purpose collected, with appropriate permission, where another lawful basis applies, or where required or authorised by law.

Businesses interested in a member will generally use the AMOS Request an Introduction process rather than receiving unrestricted access to private contact details.

AMOS may provide authorised information to a business where the member agrees or disclosure is otherwise lawfully permitted.

Restricted information may also be accessible to authorised AMOS personnel and contracted service providers where reasonably necessary to operate AMOS services.

AMOS may investigate suspected misuse of member information and restrict or terminate access where appropriate.

Once information has been lawfully provided to an independent third party, AMOS may not control every subsequent use of that information, but may impose access conditions and take reasonable action where misuse is identified.

8. Business Introduction Requests

Businesses may request contact with or an introduction to an AMOS Talent Network member.

AMOS may collect information about the requesting business, its representative, contact details, website, proposed role or support required, required skills, hours, start date and other information reasonably necessary to assess or administer the request.

AMOS may use this information to assess the request, contact the business or member, facilitate an introduction, prevent misuse, maintain records and provide information about separate AMOS services where relevant.

Submitting a request does not automatically entitle a business to a member's private contact information.

AMOS may provide relevant information about the requesting business to the member so they can decide whether to proceed.

A member may decline an introduction request.

If the member accepts, AMOS may provide the agreed contact details to both parties and facilitate the introduction.

After the introduction, the parties may communicate and make their own arrangements directly unless they separately engage AMOS for Recruitment Only, Managed Workforce or another AMOS service.

Each party is responsible for its own subsequent handling of personal information received through an accepted introduction, subject to applicable law and any AMOS access conditions.

AMOS may retain reasonable records of the request, permissions and introduction for administration, security, disputes, fraud prevention and legitimate business recordkeeping.

AMOS may refuse, delay or discontinue a request involving suspected fraud, misuse, inappropriate conduct, unlawful activity, privacy or security risk, or another legitimate concern.

An introduction request does not guarantee contact, acceptance, an interview, engagement or work.

9. Verification, References and Background Checks

AMOS may conduct identity, professional, reference, assessment or background checks in connection with Talent Network profiles, recruitment, managed workforce services or particular business requirements.

The type and extent of checks may vary according to the profile, role, service or verification status.

Information reviewed may include identity, professional and employment history, qualifications, licences, experience, portfolios, interviews, communication assessments, skills or systems assessments, references, background checks and information supporting professional claims.

AMOS may obtain information from the individual, nominated referees, authorised verification providers, professional sources and other lawful sources.

Where additional consent, authority or identification is required, AMOS may obtain it before completing the relevant check.

AMOS may use third-party providers to assist with verification activities.

AMOS may also use internal assessment frameworks, scoring methods and technology-assisted decision-support tools to help prioritise or assess profiles. These tools do not by themselves grant an AMOS verification or Featured Talent status.

Full verification reports and supporting documents are not ordinarily displayed publicly. A profile may instead show a verification status, badge, checks completed, review date or approved summary.

AMOS will not claim that a check has been completed where it has not.

Verification records may be retained privately where reasonably necessary for verification integrity, legal compliance, disputes, fraud prevention, security or legitimate business recordkeeping.

Where appropriate and lawful, AMOS may provide a relevant verification outcome to a prospective or existing client without disclosing every underlying private document.

10. Payments and Subscription Providers

AMOS may use authorised third-party payment providers to process memberships, subscriptions and other payments.

Where payment details are entered directly into a payment provider's system, AMOS does not ordinarily collect or store the member's complete payment-card number.

AMOS may receive and retain information such as customer name, billing email, selected service, payment amount and status, transaction identifier, payment date, subscription and renewal status, cancellation information, refunds, failed payments and payment disputes.

AMOS may use this information to administer memberships, process payments, recurring subscriptions, renewals, cancellations and refunds, investigate payment issues, prevent fraud and maintain accounting and taxation records.

Third-party payment providers operate under their own terms, privacy policies and security arrangements.

AMOS may exchange information with a payment provider where reasonably necessary to process or administer a transaction or subscription, investigate a dispute, prevent fraud or meet legal, accounting or recordkeeping requirements.

AMOS will not intentionally publish payment information as part of a Talent Network profile.

11. Service Providers and Technology Systems

AMOS uses third-party service providers and technology platforms to support the operation of its business, Talent Network, recruitment activities and managed workforce services.

Depending on the service being provided, these providers may assist with:

• website hosting and website forms;

• cloud storage and document management;

• email and business communications;

• customer relationship management;

• recruitment and candidate administration;

• payment and subscription processing;

• accounting and financial administration;

• identity, reference, qualification or background checking;

• marketing and social media;

• analytics and website performance;

• cybersecurity, authentication and access control;

• automation and operational systems; and

• other functions reasonably required to operate or support AMOS services.

AMOS may provide or make personal information accessible to a service provider where reasonably necessary for that provider to perform services for AMOS.

AMOS will seek to limit access to the information reasonably required for the relevant service or function.

Service providers may process information using their own systems, infrastructure and personnel and may themselves use authorised subcontractors.

Where reasonably appropriate, AMOS takes steps to select and manage service providers having regard to matters such as the nature of the information involved, security, confidentiality, privacy obligations and the services being provided.

Use of a third-party service provider does not give that provider permission from AMOS to use personal information for unrelated purposes unless another lawful basis applies.

Some service providers may be located in, or process information from, countries outside Australia. Overseas handling of personal information is addressed further in clause 12.

12. Overseas Talent and Cross-Border Information

AMOS operates an international remote workforce and talent network and may work with professionals, clients, contractors and service providers located outside Australia.

As a result, personal information may be stored, processed, accessed or disclosed outside Australia where reasonably necessary to operate AMOS services.

Overseas recipients may include:

• remote professionals involved in authorised AMOS operations;

• recruitment, verification or background-check providers;

• technology, hosting and cloud service providers;

• communications and customer-management providers;

• payment and administration providers;

• professional advisers and operational service providers; and

• other recipients reasonably required to provide an AMOS service.

The countries involved may vary depending on the particular service, individual, client and technology provider.

AMOS currently works extensively with remote professionals in the Philippines. Personal information may also be handled in other countries as AMOS services, technology providers and the Talent Network develop.

Where reasonably practicable and required, AMOS may provide additional information about likely overseas disclosures through this Privacy Policy, a collection notice, consent process or other communication.

Where applicable law imposes requirements concerning overseas disclosure or cross-border processing, AMOS will take reasonable steps appropriate to the circumstances to address those requirements.

Participation in an AMOS service or Talent Network membership does not by itself constitute unlimited consent to disclose personal information to any overseas recipient for any purpose.

AMOS may use international technology providers whose systems, support teams, data centres or subcontractors operate across multiple countries. The precise location in which information is processed may therefore vary from time to time.

13. Marketing and Communications

AMOS may communicate with applicants, members, clients, businesses, contractors and other contacts about matters reasonably connected with their relationship with AMOS.

Communications may include:

• membership administration;

• account and profile updates;

• payment, renewal and cancellation information;

• business introduction requests;

• recruitment or opportunity-related communications;

• service announcements;

• security or operational notices;

• Talent Network updates;

• AMOS services;

• events, resources, promotions and offers; and

• other communications reasonably related to AMOS activities.

Operational and transactional communications necessary to administer an application, active membership, payment, introduction, recruitment process, contract or existing service are not treated as optional marketing communications merely because they are sent electronically.

AMOS may also send promotional or commercial communications where permitted by applicable law.

Where consent is required for a particular marketing communication, AMOS will seek appropriate consent.

Marketing communications sent by AMOS will identify AMOS and, where required, provide a reasonably simple method to unsubscribe.

A person may opt out of optional marketing communications at any time using an available unsubscribe facility or by contacting AMOS.

An unsubscribe request does not prevent AMOS from sending communications reasonably necessary to:

• administer an existing membership or service;

• process a transaction;

• respond to an enquiry;

• provide requested information;

• communicate about an introduction or recruitment process;

• manage security, fraud or account matters; or

• comply with legal or contractual obligations.

AMOS may use contact and engagement information to manage communications, understand audience interest and improve the relevance and effectiveness of its services and marketing where lawfully permitted.

14. Cookies, Website Analytics and Online Activity

AMOS websites and online services may use cookies, pixels, analytics technologies and similar tools to support website operation, security, performance, functionality and measurement.

Depending on the technology used, information collected may include:

• IP address;

• browser and device information;

• operating system information;

• approximate location derived from technical information;

• pages visited;

• referral source;

• date and time of visits;

• time spent on pages;

• interactions with website features;

• form activity;

• general usage patterns; and

• other technical information associated with use of AMOS websites or online services.

AMOS may use this information to:

• operate and maintain its websites;

• improve website functionality and user experience;

• understand how visitors use AMOS websites;

• identify technical problems;

• maintain website and account security;

• detect suspicious or fraudulent activity;

• measure website and campaign performance;

• understand referral sources; and

• improve AMOS services and marketing activities.

Third-party technology, analytics, advertising or website-service providers may place or access cookies or similar technologies through AMOS websites where those services are used.

Those third parties may handle information under their own privacy policies and technical arrangements.

Where applicable law requires consent for a particular cookie, tracking technology or use, AMOS will take reasonable steps to obtain the required consent.

Visitors may be able to control or delete certain cookies through their browser or device settings.

Disabling cookies may affect the operation or availability of some website functions.

AMOS may change the technologies used on its websites as its systems and services develop.

15. Security and Storage of Personal Information

AMOS takes reasonable steps appropriate to its operations and the nature of the information involved to protect personal information from:

• misuse;

• interference;

• loss;

• unauthorised access;

• unauthorised modification; and

• unauthorised disclosure.

Security measures may include:

• controlled access to information and systems;

• password and authentication controls;

• multi-factor authentication where appropriate;

• role-based access and least-privilege practices;

• secure cloud and technology systems;

• confidentiality obligations;

• staff and contractor access restrictions;

• secure credential-management practices;

• cybersecurity and security procedures;

• record-management processes;

• system monitoring;

• backup and recovery measures; and

• other administrative, technical and organisational safeguards appropriate to AMOS operations.

Access to personal information may be limited according to business need, role and the sensitivity of the information involved.

Personal information may be stored using AMOS systems and third-party service providers, including cloud-based providers. Information may be stored or processed in Australia or overseas as described in clause 12.

AMOS may retain separate or restricted records for matters such as identity verification, payments, complaints, fraud prevention, legal compliance and security.

No internet transmission, technology platform or storage system can be guaranteed to be completely secure. AMOS does not represent that all security risks can be eliminated.

Where AMOS becomes aware of an actual or suspected security incident involving personal information, it may take steps to contain, investigate and respond to the incident in accordance with applicable requirements.

Individuals are also responsible for taking reasonable steps to protect passwords, login details and other credentials associated with their interactions with AMOS and should notify AMOS if they reasonably suspect unauthorised use.

Where personal information is no longer reasonably required for a lawful business, contractual, security or legal purpose, AMOS may take reasonable steps to destroy or de-identify that information where required or appropriate under applicable law.

16. Access to Your Personal Information

You may request access to personal information that AMOS holds about you.

To make an access request, contact AMOS using the details in clause 22 and provide enough information for AMOS to:

• identify you;

• locate the relevant information; and

• understand the scope of your request.

AMOS may take reasonable steps to verify your identity or authority before providing access, particularly where the information is sensitive, confidential or relates to another person.

Where applicable privacy law provides a right of access, AMOS will respond within the period required by law or otherwise within a reasonable period.

Where reasonable and practicable, AMOS may provide access electronically, by providing copies, by allowing inspection or through another appropriate method.

Access may be refused, restricted or provided in a modified form where permitted or required by applicable law.

Where appropriate and lawful, AMOS may provide access in another form, or redact information, where this allows access to be provided while protecting the privacy of another individual, confidentiality, security, legal rights or other interests recognised by applicable law.

Where AMOS refuses or limits access and applicable law requires an explanation, AMOS will provide the required reasons and information about available complaint options.

AMOS will not charge a fee merely for making an access request.

Where legally permitted, AMOS may charge a reasonable amount for costs associated with providing access, such as substantial retrieval, copying or delivery costs.

17. Correction of Personal Information

AMOS seeks to maintain personal information that is accurate, current, complete, relevant and not misleading having regard to the purposes for which it is held.

You may ask AMOS to correct personal information that you believe is:

• inaccurate;

• out of date;

• incomplete;

• irrelevant; or

• misleading.

AMOS may request reasonable supporting information where necessary to assess a correction request.

Talent Network members are responsible for notifying AMOS of material changes to information such as:

• professional experience;

• qualifications;

• availability;

• contact details;

• location;

• work rights;

• licences or registrations; and

• other information relevant to their profile or engagement.

Where applicable privacy law requires AMOS to correct personal information, AMOS will take reasonable steps to do so within the period required by law.

AMOS will not charge an individual for making or processing a correction request where charging is prohibited by applicable law.

If AMOS does not agree that information should be corrected, AMOS may retain the existing information where lawful.

Where required by applicable law, AMOS may:

• explain a refusal to correct information;

• provide available complaint options;

• associate a statement with the information recording that the individual disputes its accuracy; or

• take reasonable steps to notify relevant recipients of a correction where appropriate.

A correction to a public Talent Network profile does not necessarily require AMOS to alter historical records that AMOS is lawfully entitled or required to retain.

18. Data Retention, Deletion and De-identification

AMOS retains personal information for as long as it is reasonably required for the purpose for which it was collected, another lawful purpose or an applicable business, contractual, security or legal requirement.

Retention periods may vary depending on the information and circumstances.

AMOS may retain information in connection with:

• active or previous Talent Network memberships;

• applications and professional profiles;

• recruitment and workforce relationships;

• business introduction records;

• client relationships;

• contracts and commercial records;

• payment, accounting and taxation requirements;

• verification, reference and background-check records;

• complaints and disputes;

• fraud prevention and security;

• regulatory or legal requirements;

• actual or anticipated legal claims;

• enforcement of AMOS agreements or rights;

• system backups and disaster recovery; and

• legitimate business recordkeeping.

The end of a membership, removal of a public profile or completion of a recruitment process does not necessarily require immediate deletion of all information associated with that person.

Public profile information may be removed from active AMOS-controlled publication while restricted administrative, legal, payment, verification, security or historical records continue to be retained where reasonably required.

Individuals may contact AMOS to request deletion of personal information.

A deletion request does not guarantee that all information will be deleted.

AMOS may refuse or limit a deletion request where information is reasonably required or lawfully retained for purposes including:

• compliance with law;

• taxation, accounting or financial records;

• contractual records;

• fraud prevention;

• security;

• complaints or disputes;

• legal claims;

• verification integrity; or

• another legitimate and lawful purpose.

Where personal information is no longer required for a purpose for which AMOS may lawfully retain, use or disclose it, AMOS may take reasonable steps to destroy or de-identify the information where required or appropriate under applicable law.

Deletion from active systems may not immediately remove information from secure backups, system archives, search-engine caches or independent third-party systems outside AMOS's reasonable control.

19. Privacy Complaints

If you believe AMOS has mishandled your personal information or has not complied with an applicable privacy obligation, you may make a privacy complaint.

Privacy complaints should be sent using the contact details in clause 22.

To help AMOS investigate the matter, a complaint should where reasonably possible include:

• your name and contact details;

• sufficient information to identify you;

• a description of what occurred;

• when the issue occurred;

• the personal information involved;

• your concerns;

• any relevant supporting information; and

• the outcome you are seeking.

AMOS may request additional information where reasonably necessary to investigate a complaint.

AMOS will aim to acknowledge privacy complaints promptly and investigate them fairly within a reasonable period.

Where additional time is reasonably required because of complexity, third-party involvement, security concerns, legal requirements or the need for further information, AMOS may provide an update and continue the investigation.

AMOS may take action in response to a substantiated complaint including:

• providing an explanation;

• correcting information;

• restricting or removing information;

• changing an internal process;

• addressing inappropriate access or disclosure;

• taking security or remedial action; or

• providing another appropriate resolution.

Where the Australian Privacy Act applies, an individual may have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC) after first raising the matter with AMOS.

Nothing in this Privacy Policy prevents an individual from contacting another regulator, authority or dispute-resolution body where they have a lawful right to do so.

20. Data Breaches and Security Incidents

AMOS maintains processes for identifying, containing, assessing and responding to actual or suspected security incidents involving personal information.

Where a security incident occurs, AMOS may take steps including:

• containing or limiting the incident;

• securing affected systems or accounts;

• investigating what occurred;

• identifying affected information and individuals;

• assessing the likelihood and seriousness of potential harm;

• preserving relevant evidence;

• taking remedial action;

• resetting or restricting system access;

• reviewing security controls;

• obtaining assistance from technology, cybersecurity, legal or other advisers; and

• notifying affected individuals, regulators, service providers, insurers or other parties where appropriate or required.

Not every security incident constitutes a legally notifiable data breach.

Where the Notifiable Data Breaches scheme applies and AMOS has reasonable grounds to suspect that an eligible data breach may have occurred, AMOS will undertake the assessment required by applicable law.

Where required, AMOS will take reasonable steps to complete that assessment within the applicable statutory timeframe.

If an eligible data breach has occurred and notification is required, AMOS will make the notifications required by applicable law.

AMOS may take remedial action before notification where reasonably possible. If effective remedial action removes the relevant risk of serious harm and the law does not require notification, AMOS may not be required to notify the incident.

AMOS may maintain confidential records of security incidents, investigations, remedial action and notifications for legal, security, insurance, audit and risk-management purposes.