Brushed Clean Candidate And Employee Privacy Policy

Effective Date: 28 September 2025

1. Our Commitment to Privacy

Brushed Clean is committed to protecting the privacy and security of the personal information we collect and hold about our job applicants (including those undertaking a trial) and our employees.

While Brushed Clean may be a small business, we voluntarily choose to handle your personal information in accordance with the Australian Privacy Principles (APPs) as a matter of best practice.

2. What Personal Information We Collect

We collect personal information that is reasonably necessary for the recruitment process (including the trial) and the management of our employees.

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3. Collection of Sensitive Personal Information

• We will only collect Sensitive Information (such as criminal record information, or health/disability information) with your explicit consent or where required or authorised by law.
• Health Information: We will collect information relevant to ensuring workplace safety or for the purpose of processing an insurance claim related to the trial.

4. How We Collect Personal Information

We generally collect information directly from you, but we also collect information from third parties, particularly for employment checks:

• From Third Parties:
• Nominated Referees: We collect information, opinions, and comments about your character and work suitability from your nominated referees (which may be a former employer, friend, or relative).
• Identity Verification for Non-Professional Referees: If you nominate a friend or relative as a referee, we will ask them to provide us with two documents: Photo Identification (ID) and Proof of Current Address (e.g., a utility bill or bank statement). This is solely to verify their identity and authenticity as a referee, protecting the integrity of our hiring process and ensuring they are a local reference as nominated.

5. Consent for Collecting Referee Data

By nominating a referee (whether professional, friend, or relative), you warrant that you have obtained the following explicit consent from them:

1. Consent to be Contacted: They consent to Brushed Clean contacting them for a reference check.
2. Consent to Provide Data: They consent to providing their personal information (including their identity, contact details, Photo ID, and Proof of Address) to Brushed Clean for the sole purpose of verifying their identity as a referee.

We will not process your application without this consent.

6. Purpose of Collection and Use (Why We Use the Data)

We collect, hold, use, and disclose your personal information for the following purposes:

7. Security and Storage of Personal Information

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure.

• Electronic Records: Stored on secure, password-protected systems.
• Hard Copy Records: Stored in lockable cabinets with restricted access.
• Retention of Candidate Data and Referee Documents:
• Successful Candidates and Employees: The personal information collected during recruitment, including the referee's Photo Identification (ID) and Proof of Current Address, will be transferred to your secure employee file and retained for the duration of your employment with Brushed Clean and for a period of seven (7) years after your employment ceases. This retention period is necessary to comply with legal record-keeping requirements and to maintain evidence for potential legal proceedings related to your employment or any alleged criminal activity.
• Unsuccessful Candidates: The personal information and referee documents will be retained for a maximum period of [Insert Time Period, e.g., six months to two years] to allow us to consider you for future suitable vacancies. After this period, all documents will be securely destroyed or permanently de-identified unless legal proceedings require longer retention.

8. Disclosure of Personal Information

We will only disclose your personal information to third parties where it is necessary for the purposes outlined above. This includes:

• Our third-party service providers (e.g., IT support, cloud storage providers).
• Our professional advisers (e.g., accountants, lawyers).
• Government bodies (e.g., the Australian Tax Office, superannuation funds, as required by law).
• Our insurers (in relation to the unpaid trial or any workplace incident).

We do not sell your personal information to any third party for marketing purposes.

9. Access to and Correction of Personal Information

You have the right to request:

• Access to the personal information we hold about you.
• Correction of any information we hold that you believe is inaccurate, incomplete, or out-of-date.

We will respond to your request within a reasonable time (usually 30 days) and will not charge you for making a request.

10. How to Make a Complaint

If you believe we have breached the Australian Privacy Principles or this Policy, please contact our Privacy Officer (details below) in writing. We will investigate your complaint promptly and respond in writing. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC).

Privacy Officer Contact Details

Name: Sandra McRitchie

Title: Privacy Officer, Brushed Clean

Email: sandra@brushedclean.com.au

Phone: 0415 687 000