Data privacy for job applicants

1. Introduction

At LGT Wealth Management Limited (ABN 50 005 311 937) (LGT Wealth Management), we are committed to safeguarding the Personal Information that we collect and use in the course of our business operations.

This Privacy Statement (Statement) describes how we manage our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), which regulate the way which we manage your Personal Information for the purposes of employment, including recruitment.  

Capitalised terms in this Statement are defined in section 4. References to LGT Wealth Management, we, us and our are to LGT Wealth Management and its affiliates. References to you and your are to you as an individual from whom we collect Personal Information.

This Statement should be read in conjunction with:

  • any other privacy or collection statement that we provide to you when we collect your Personal Information; and
  • the privacy statement of the organisation that you may have used to apply for a position with us.

2. Personal Information

2.1 What Personal Information do we collect?

We collect Personal Information about you to evaluate your employment application and administration of employment with us.  

The information we collect may be Personal Information and Sensitive Information, that may include:

  • identification and emergency contact details;
  • qualification, training, employment history;
  • psychometric testing details;
  • residency/visa status;
  • taxation, banking and superannuation or retirement membership details; and
  • union, professional or trade association membership details. 

2.2 How do we collect Personal Information?  

Directly from you

We will collect Personal Information only by lawful and fair means. We will, in most cases, collect Personal Information from you directly, including Sensitive Information you choose to disclose. For example, if you provide us with health or membership information.

If we receive unsolicited Personal Information about you that we would not otherwise have collected in accordance with the Privacy Act, we will destroy or de-identify the information.

From third parties

In some circumstances, we may also collect Personal Information and Sensitive Information about you from other third parties. Third parties from whom we may acquire Personal Information include, but are not limited to, information service providers, your referees (or organisations that they represent), a recruitment provider, previous employers, other CV checking agencies, criminal records check supplier, our psychometric testing and training provider, and/or  others who may be able to provide information to assist us with our recruitment decision or to process your employment.

Should a third party provide us with your Personal Information, we take reasonable steps to ensure that the information was collect lawfully and fairly. If you have any problems or queries with us obtaining Personal Information about you from a third party, or if you would like to correct the Personal Information we hold about you, you should contact us and the relevant third party to address your problems or queries – see more contact information in section 3.

Collection through other means

We may also collect Personal Information about you through other means, for example from publicly available information sources, third party search engines, Artificial Intelligence (AI) generated insights derived from automated systems that assess interactions, profiles and preferences; AI chatbots developed by OpenAI; and from your representatives and associates.

If we use AI-powered systems for any decision-making, we will ensure:

  • transparency regarding how AI is used in data analysis and decision-making;
  • fairness and non-discrimination, ensuring AI-driven insights do not result in biased outcomes; and
  • opt-out mechanisms where required, allowing individuals to request a human review of AI-driven decisions affecting them.

If you wish to restrict the collection of their Personal Information through automated tools, we request that you adjust your browser settings, opt out of preferences, or contact us directly. 

2.3 Why do we collect your Personal Information and how will we use and disclose it?

We collect your Personal Information to evaluate your employment application and administer employment with us.

We may use the Personal Information we collect about you for the following purposes:

  • to assess your skills, qualifications, and suitability for the position;
  • to communicate with you about the recruitment process;
  • to make informed decisions about the recruitment process;
  • to keep records related to our hiring processes;
  • to comply with legal or regulatory requirements and obligations; and  
  • to process your application to make an offer of employment, including processing your employment.

We can use Personal Information for a purpose that is directly related to the purpose for which it was collected, or for another purpose which is reasonably related to which you would reasonably expect. For instance, we may disclose Personal Information on a job application to a service provider to complete a CV Check. We will seek your consent if we seek to use Personal Information for another purpose that is unrelated to the purpose of collection.

If AI tools are used to analyse your Personal Information, we will implement safeguards to prevent bias and ensure that data is used fairly, ethically, and in accordance with privacy laws. 

2.4 Who do we disclose your Personal Information to?

We may share your Personal Information, for the purposes described in this Statement, with:

  • our employees and related bodies corporate, including to their officers, employees and professional advisers;
  • other third-party service providers, including CV checking agencies, legal, business consulting, information service, training and checking providers, recruitment agencies, banking, data processing, data analysis, electronic signing/collation, information broking, mailing, marketing, research, investigation, insurance, and identity verification;
  • state and federal government agencies, regulatory bodies and law enforcement agencies;  
  • referees and previous employers;
  • any other person to whom you have authorised us or our related bodies corporate to release Personal Information;
  • any other third party where we have obtained your written consent; and
  • other persons as required or permitted by law.

We take will have measures to ensure that the parties we share your Personal Information with are bound by equivalent privacy obligations as set out this Statement or you have provided your consent. 

2.5 Disclosure of Personal Information overseas

We may disclose your Personal Information to our related bodies corporate and other third party service providers outside of Australia, who perform functions on our behalf or assist us to undertake our business operations and activities. These overseas entities may be located in, or have personnel that may access your information from, jurisdictions including: Austria, Bahrain, Belgium, Brazil, Canada, China, Denmark, Finland, France, Germany, Hong Kong, India, Indonesia, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Malaysia, Netherlands, New Zealand, Norway, Philippines, Portugal,  Singapore, South Africa, South Korea, Spain, Switzerland, Taiwan, Thailand, United Arab Emirates, United Kingdom and United States of America. Before Personal Information is disclosed to an overseas recipient located in a foreign jurisdiction with inadequate privacy protection, we will take reasonable steps to ensure compliance with the Privacy Act or obtain the individual’s explicit consent. If we engage third-party AI providers or cloud-based AI services, we will ensure that they comply with Australian privacy laws and do not use Personal Information. Alternatively, we may seek the owner’s consent to the transfer for purposes beyond those disclosed.

2.6 Using our website and cookies

Please visit our website at www.lgtwm.com.au to review to our Privacy Statement   or for information about how our website use cookies and our responsibility regarding links on our website. 

2.7 Storage and Security of Personal Information  

We generally hold Personal Information in our electronic databases but also store Personal Information in hard copy form and in various third party databases. All Personal Information will be held in a secure environment-either in writing, electronically or both. We have security measures in place which are intended to protect Personal Information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

If we disclose your Personal Information to a third party, it will be done on a need to know basis so they can perform their duties as outlined in this Statement and/or undertake obligations as permitted by law. The key methods of securing the Personal Information we hold will include but are not limited to:

  • secure access to electronic and physical records containing Personal Information, via password protected access permissions to systems and security pass-protected access to filing cabinets and storage;
  • access only to authorised LGT Wealth Management staff who need to access the Personal Information to perform their regular duties;
  • varying access levels depending on the level of authority and the type of Personal Information required to be accessed; and
  • controls relating to how Personal Information is extracted from the secure environment and how it is used and distributed.

We will retain recruitment data for no longer than is reasonable for the purpose that it was collected, after which your personal information will be destroyed.

Where AI tools are used to analyse Personal Information, we will implement safeguards to prevent bias and ensure that data is used fairly, ethically, and in accordance with privacy laws.

If AI is used in data analysis, we will implement measures to protect Personal Information from unauthorised access, bias or misuse, including encryption, anonymisation, and regular audits.  

Where Personal Information is no longer needed for the purpose for which it was obtained and we are not required to hold it under Australian law, we will take reasonable steps to destroy, permanently de-identify or place it as beyond use. We have established procedures to regularly review, de-identify, place as beyond use or delete data when it is no longer needed.

2.8 Requests to access Personal Information

Accessing Personal Information

You can request to access the Personal Information we hold about you, at any time, by contacting the Human Resources team [email protected] or our privacy officer. We have included the contact details for our privacy officer at section 3.

We will respond within a reasonable time period of receiving a request from you. In order to protect your Personal Information, we may reasonably require identification from you before releasing the requested information to them.  

Where possible we will provide you with a copy or details of their Personal Information in the manner you they requested. We may charge a reasonable fee for providing your Personal Information to you. Sometimes we may be unable to provide you with access to all of your Personal Information. Where this is the case, we will tell you the reason.

2.9 Requests to correct or delete Personal Information

We take reasonable steps to ensure that the Personal Information we collect, use and disclose is accurate, complete, up to date and relevant. If you believe that your Personal Information is outdated, incorrect or incomplete, you may request to have the Personal Information corrected. We will respond within a reasonable period of receiving your request and we will promptly update our records accordingly.

You may also request deletion of your Personal Information where:

  • the data is no longer necessary for the purpose for which it was collected
  • you withdraw consent (where processing is based on consent)
  • the data was collected unlawfully

We will assess such requests in line with legal requirements and will inform individuals if any legal or regulatory obligations prevent deletion. If we refuse to comply with your correction request, we will tell you why. 

2.10 Privacy Complaints

If you have any questions regarding our compliance with the Privacy Act or if you wish to make a complaint about our handling of your Personal Information, we encourage you to contact us. Relevant contact details can be found in section 3.

Complaints should first be made in writing to us, and should include your name, email address and/or telephone number and clearly describe your complaint. We will endeavour to respond to a complaint within a reasonable time period of receiving the complaint.  

If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For further information regarding how to make a complaint to the OAIC, you can visit oaic.gov.au/privacy/making-a-privacy-complaint.

3. Other Information

3.1 Exemptions

This Statement does not apply in respect of any of our acts and practices that are directly related to an employee record of a current or former employee. These are captured in the LGT Wealth Management human resources policies and procedures. If you are successful in your application for employment with us, this Statement will cease to apply to you. Employees of LGT Wealth Management are covered by our internal policies and procedures relating to Privacy, including the way we handle their Personal Information.  

This Statement does not apply in respect of any Voluntary Disclosure questions you may choose to respond to as part of your employment application and will not be subject to the collection purpose and use as outlined in section 2.3. Any information provided as a Voluntary Disclosure will be used solely for the purpose of improving our understanding of the profiles of candidates participating in our hiring process.

3.2 Changes to this Statement

We reserve the right at our discretion to modify or remove any part of this Statement at any time. You should review this Statement from time to time so that you are updated on any changes. 

3.3 Contact details for privacy officer

You can contact our privacy officer by post or email, using the following contact details:  

LGT Wealth Management Privacy Officer 
Level 32, Chifley Tower, 2 Chifley Square 
Sydney NSW 2000
Email [email protected]

Definitions

TermDefinition
APPsAustralian Privacy Principles
LGT Wealth ManagementLGT Wealth Management and its affiliates
LGT Wealth ManagementLGT Wealth Management Limited
GRIGovernment related identifier. Has the meaning given in the Privacy Act and includes an identifier of an individual that has been assigned by a government agency or authority, including their agents.
OAICOffice of the Australian Information Commissioner
Personal Information

Information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not.

Common examples of Personal Information are an individual’s name, signature, address, telephone number, date of birth, bank account details and commentary or opinion about a person.

Sensitive InformationHas the meaning given in the Privacy Act and includes information about an individual’s racial or ethnic origin, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, criminal record, or health information.
Voluntary DisclosureIs the provision of information provided by you in answer to questions in your employment application specifically identified as ‘voluntary’