PRIVACY POLICY

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  1. Who we are

PROPHR Proprietary Limited (ACN 670 350 017; ABN 81 670 350 017) is an Australian company with its registered office at Level 1, 63-73 Ann Street, Surry Hills, NSW 2010, Australia

This Privacy Policy explains how PROPHR collects, holds, uses, discloses, stores and protects personal information.

This policy applies to website visitors, business contacts, prospective clients, clients, candidates, employees of clients, partner representatives, contractors, suppliers, referrers and other people who interact with PROPHR.

2. Privacy framework

PROPHR handles personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, applicable data breach obligations and other laws that apply to our operations.

Where another privacy law applies because of a person’s location or the nature of a service, PROPHR will address that law to the extent required.

3. Personal information we collect

Depending on your interaction with us, we may collect:

• identity and contact details, including name, email, telephone, address, country, employer, role and business contact details;
• business enquiry information, including service needs, partner model, recruitment requirements, visa or workforce issues, meeting notes and correspondence;
• candidate and migration-related information where relevant, including occupation, qualifications, work history, CV or resume, passport or identity details, visa history, family composition, language results, skills assessment details, education history, health or character information, police checks and supporting documents;
• billing and transaction information, including invoices, payment status, currency, merchant reference and accounting records;
• website and technical information, including IP address, browser type, operating system, referral page, pages viewed, device identifiers, cookie identifiers, analytics data and reCAPTCHA signals;
• marketing preference information, including consent, opt-out status, campaign interactions and event attendance;
• security and compliance records, including access logs, authority records, consent records, audit records, complaints, incidents and investigation materials;
• AI and automation interaction records where AI-supported tools are used, including prompts, outputs, metadata, review notes and user feedback      where retained.

4. Sensitive information

Some migration, recruitment, identity verification, due diligence, compliance and client onboarding work may involve sensitive information.

This may include health information, biometric information, racial or ethnic origin, criminal record information, professional memberships, government identifiers, financial information or other information that receives additional protection under law.

PROPHR collects sensitive information only where reasonably necessary for our functions or activities and where we have consent, legal authority or another lawful basis to do so.

5. How we collect information

We may collect information directly from you, from your employer or prospective employer, from a recruitment agency, migration partner, authorised representative, referrer, contractor, government body, skills assessing authority, verification provider, public register, professional adviser, website form, email, call, meeting, document upload, CRM, identity verification provider or other lawful source.

You must not provide another person’s personal information unless you are authorised to do so and have provided any notices or obtained any consents required by law.

6. Purposes of use

PROPHR may use personal information to:

• respond to enquiries and manage relationships;
• assess service suitability, conflicts, risk, eligibility and compliance requirements;
• provide migration, recruitment support, white-label, technology, consulting, client support and related services;
• prepare, administer and manage service agreements, authorities,  forms, invoices, payments, refunds and client records;
• communicate with clients, candidates, business partners, referrers, suppliers, contractors and professional advisers;
• perform identity verification, sanctions, politically exposed person, fraud, security and risk checks where applicable;
• submit or support applications, lodgements, assessments, enquiries,      documents or correspondence to government bodies, assessing authorities or      other third parties where authorised;
• meet legal, accounting, tax, professional, insurance, regulatory, record-keeping and dispute obligations;
• operate, secure, test, improve and analyse the website, CRM, workflows, automations and business systems;
• use AI-assisted tools for drafting, classification, workflow, summarisation, quality control or administrative support, subject to human review where required;
• send marketing, updates and event information where permitted, with opt-out options; and
• investigate complaints, suspected misconduct, fraud, data incidents, modern slavery concerns or whistleblower reports.

7. Disclosure of personal information

We may disclose personal information to the extent reasonably necessary to:

• directors, officers, employees, registered migration agents, licensed immigration advisers, lawyers, paralegals, case workers, contractors and authorised support personnel;
• clients, employers, prospective employers, recruitment partners, migration partners, referrers or authorised representatives involved in the relevant matter;
• Australian or overseas government departments, regulators, tribunals, courts, skills assessing authorities, professional bodies, education providers, health providers or police clearance bodies where required or authorised;
• technology providers, hosting providers, CRM providers, secure document storage providers, e-signature providers, identity verification providers, payment processors, analytics providers, communications platforms and AI tool providers;
• professional advisers, auditors, insurers, banks, debt recovery providers, dispute advisers and legal representatives;
• law enforcement, regulators or other third parties where required or permitted by law; and
• a buyer, investor, financier or adviser if PROPHR is involved in a merger, acquisition, restructure, asset sale, due diligence process or financing transaction, subject to confidentiality protections where appropriate.

8. Overseas disclosure

PROPHR interacts globally and may disclose or store information in Australia and other countries relevant to the services.

This may include countries where clients, candidates, employers, partners, cloud providers, contractors, advisers, government bodies or assessing authorities are located.

Where required, we use reasonable safeguards for cross-border handling, including contractual obligations, confidentiality terms, access controls, vendor due diligence and other measures required by applicable privacy law.

9. AI-assisted processing

PROPHR may use AI-assisted tools to support drafting, summarisation, classification, triage, document review, workflow automation, quality checking and business administration.

We do not intend to use AI as the sole decision-maker for decisions that have a legal or similarly significant effect on a person, such as visa eligibility, case acceptance, employment selection, fee entitlement or complaint outcome.

Where AI-assisted tools are used, PROPHR remains responsible for appropriate human review, confidentiality, data minimisation, security and accuracy checks.

Do not submit personal information into public AI tools unless PROPHR has expressly authorised that use and appropriate controls are in place.

10. Automated decision-making transparency

PROPHR may use computer programs, workflow systems, AI-assisted tools or automation to support business processes.

Where a computer program is used to make, or substantially and directly support, a decision that could reasonably be expected to significantly affect a person’s rights or interests, PROPHR may use the following kinds of personal information:

• identity and contact details;
• candidate, employment, recruitment and role information;
• migration, visa, qualification, skills assessment and eligibility information;
• client, partner, employer or referrer information;
• risk, compliance, security, fraud, complaint or incident information;
• documents, correspondence, metadata and system activity records.

The kinds of decisions that may be made, or substantially and directly supported, by such systems may include:

• enquiry triage and workflow allocation;
• document classification and completeness checks;
• candidate or client intake review;
• compliance, risk or eligibility flagging;
• administrative prioritisation;
• quality control and internal review support;
• complaint, incident or escalation routing.

PROPHR will apply human review where a decision has a legal, migration, employment, financial, privacy or similarly significant effect on a person.

11. Cookies, analytics and reCAPTCHA

Our website may use cookies, analytics, advertising technologies, reCAPTCHA and similar tools.

These may collect device, browser, interaction and IP information. More detail is set out in our Cookie Policy.

12. Security

PROPHR uses administrative, technical and physical safeguards designed to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

No transmission or storage method is completely secure.

Access to personal information is limited to personnel and providers with a business need, subject to role-based access, confidentiality, multi-factor authentication where appropriate and audit controls.

13. Data breaches

If PROPHR becomes aware of an eligible data breach or another notifiable privacy incident, we will assess the incident and make notifications required by law, including to affected individuals and regulators where required.

14. Retention

PROPHR retains personal information for as long as needed for the purposes for which it was collected, including service delivery, legal, accounting, tax, migration, insurance, professional indemnity, audit, dispute, security and regulatory requirements.

We may delete, de-identify or archive information when it is no longer required.

15. Access, correction and privacy rights

You may request access to or correction of personal information we hold about you by contacting privacy@prop-hr.com.

We may need to verify your identity before responding. We may refuse or limit access where permitted by law.

Where another privacy law applies to your interaction with PROPHR, you may have additional rights under that law. Those rights may be limited by legal, professional, migration, regulatory, record-keeping or defence-of-claims requirements.

16. Marketing

You may opt out of marketing communications by using the unsubscribe function or contacting us.

We may still send non-marketing service, legal, billing, security or administrative communications.

17. Complaints

Privacy complaints should be sent to privacy@prop-hr.com.

Please provide enough detail for us to assess the issue. We will take privacy complaints seriously and respond within a reasonable period.

If you are not satisfied with our response, you may be able to complain to the Office of the Australian Information Commissioner or another applicable regulator.

18. Contact

Privacy contact: privacy@prop-hr.com

Postal contact:

PROPHR Proprietary Limited

Level 1, 63-73 Ann Street, Surry Hills, NSW 2010, Australia