INTRODUCTION
We manage personal information in accordance with the Iran’ ECL Privacy Act and Principles. This policy applies to information collected by “HR Startup”. Please note by clicking on links in this website you will be leaving “HR Startup”.
We only collect information that is reasonably necessary for the proper performance of our activities or functions.
We do not collect personal information just because we think it could be useful at some future stage if we have no present need for it.
We may decline to collect unsolicited personal information from or about you and take steps to purge it from our systems.
When viewing this document, you will be able to find out how we manage your personal information under the Iran’ ECL.
You will also be able to find out about the information flows associated with that information.
If you have any questions please contact us.

1. Information Flow
When we collect your personal information:
·         we check that it is reasonably necessary for our functions or activities  as an employment agency;
·         we check that it is current, complete and accurate. This will sometimes mean that we have to cross check the information that we collect from you with third parties;
·         we record and hold your information in our Information Record System  [See. How your personal information is held];
·         we retrieve your information when we need to use or disclose it for our functions and activities [See. Purposes]. At that time, we check that it is current, complete, accurate and relevant. This will sometimes mean that we have to cross check the information that we collect from you with third parties once again – especially if some time has passed since we last checked;
·         subject to some exceptions, we permit you to access [See. Access & Correction] your personal information in accordance with Iran’ ECL.
·         we correct or attach associated statements to [See. Access & Correction] your personal information in accordance with Iran’ ECL.
·         we destroy or de-identify your personal information when it is no longer needed for any purpose [See. Purposes] for which it may be used or disclosed provided that it is lawful for us to do so. We do not destroy or de-identify information that is contained in a Commonwealth Record.

2. KINDS OF INFORMATION WE COLLECT AND HOLD
Personal  information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as a Recruitment Agency and is likely to differ depending on whether you are:
·         a Jobseeker
·         a Client
·         a Referee

2.1. For Jobseekers
The type of information that we typically collect and hold about Jobseekers is information that is necessary to assess amenability to work offers and work availability; suitability for placements; or to manage the performance in work obtained through us and includes:
·         candidate information submitted and obtained from you directly when you fill out and submit one of our application forms; together with any other sources in connection with applications for work
·         work performance information including feedback from clients (whether positive of negative)
·        information about incidents in the workplace including workplace accidents
·         information submitted and obtained in relation to absences from work due to leave, illness or other causes
·         information obtained to assist in managing client and business relationships
·         information received from referees
·         results of competency or medical tests
·         any complaints from or about you in the workplace
·         information we may receive about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved
·         any additional information you provide either during an interview or through subsequent contact

2.2. For Clients
The type of information that we typically collect and hold about Clients is information that is necessary to help us manage the presentation and delivery of our services and includes:
Client information submitted and obtained from the client and other sources in connection with applications to fill positions.
·           staff information
·           organizational Charts including chains of command and authority to list jobs
·           information about why a position is available and feedback on previous occupants of that role
·           information obtained to assist in managing client, candidate and business relationships
·           information about incidents in the workplace
·           work, Health and Safety information
·           feedback about “HR Startup” temporary staff performance

2.3. For Referees
The type of information that we typically collect and hold about Referees is information that is necessary to help to make determinations about the suitability of one of our Jobseekers for particular jobs or particular types of work and includes:
·           information obtained to assist with assessing a candidate’s suitability for work
·           information we may obtain includes your name, position, contact details and the circumstances that lead to your being able to provide a reference and opinion about the candidates work performance

3. Purposes
The purposes for which we collect, hold, use and disclose your personal information are likely to differ depending on whether you are:
·         a Jobseeker
·         a Client
·         a Referee
The following sections are also relevant to our use and disclosure of your personal information:
·         Our Policy on Direct Marketing [See. Our Policy on Direct Marketing]

3.1. For Jobseekers
Information that we collect, hold, use and disclose about Jobseekers is typically used for:
·         work placement operations;
·         recruitment functions;
·         statistical purposes and statutory compliance requirements;
·         Work, Health Safety risk management.

3.2. For Clients
Personal information that we collect, hold, use and disclose about Clients is typically used for:
·         client and business relationship management;
·         recruitment functions;
·         marketing services to you;
·         statistical purposes and statutory compliance requirements;
·         risk management.

3.3. For Referees
Personal information that we collect, hold, use and disclose about Referees is typically used for:
·         to confirm identity and authority to provide references;
·         Jobseeker suitability assessment;
·         recruitment functions.

3.4. Our Policy on Direct Marketing
Personal information may be used by “HR Startup” for marketing purposes:
·         personal information might be used directly by “HR Startup” for telephone marketing purposes;
·         customer lists are not obtained from third parties or shared with third parties for marketing purposes;
·         We will give individuals the direct option as to whether they wish to stay on a telephone marketing contact plan;
·         reference to the organization’s compliance with the requirements of the anti-spam legislation.

4. How your personal information is collected
The means by which we will generally collect your personal information are likely to differ depending on whether you are:
·         a Jobseeker
·         a Client
·         a Referee
We sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.
Sometimes the technology that is used to support communications between us will provide personal information to us – see the section in this policy on Electronic Transactions.

4.1. For Jobseekers
Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application for work.
Personal information is also collected when:
·         we receive any reference about you;
·         we receive the results of any competency or medical test;
·         we receive performance feedback (whether positive or negative);
·         we receive a complaint from you or about you in the workplace;
·         we receive any information about a workplace accident in which you are involved;
·         we receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you are involved;
·          you provide us with additional information about you.
We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the Iran’ ECL and our Privacy Policy.

4.2. For Clients
Personal information about you may be collected:
·         when you provide it to us for business or business related social purposes;
We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the Iran’ ECL and our Privacy Policy.

4.3. For Referees
Personal information about you may be collected when you provide it to us:
·       in the course of our checking Jobseeker references with you and when we are checking information that we obtain from you about Jobseekers;
We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the Iran’ ECL and our Privacy Policy.

4.4. Photos & Images
We will not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances.

4.5. Electronic Transactions
Sometimes, we collect personal information that individuals choose to give us via online forms or by email, for example when individuals:
·         make a written online enquiry or email us through our website;
·         submit a resume by email or through our website.
It is important that you understand that there are risks associated with use of the Internet and you should take all appropriate steps to protect your personal information.
You can contact us by land line telephone or post if you have concerns about making contact via the Internet.

5. How your personal information is held
Personal information is held in our Information Record System until it is no longer needed for any purpose for which it may be used or disclosed at which time it will be de-identified or destroyed provided that it is lawful for us to do so.
We take a range of measures to protect your personal information from:
·         misuse, interference and loss; and
·         unauthorized access, modification or disclosure.

5.1. Our Information Record System
Personal information will be held in the following ways:
·          Recruitment Software which are used as our consulting database for client and candidate information and history;
·          hard copies of application forms containing interview notes, resumes, references, test results, relevant certificates and work visas are filed under position sought. Electronic copies of resumes are filed on our network;
·          payroll information for temporary staff is entered on MYOB at the commencement of assignment and hard copies of relevant paperwork are filed in the accounts department’s filing system;
·          client job descriptions are kept electronically;
·          hard copies of client information are filed alphabetically;
·          cloud storage.

 5.2. Information Security
“HR Startup” takes all reasonable steps to ensure personal information it holds is protected against misuse, interference and loss and form unauthorized access, modification or disclosure.
“HR Startup” holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorized staff.
“HR Startup” will destroy or de-identify personal information in circumstances where it is no longer required, unless “HR Startup” is otherwise required or authorized by law to retain the information.

6. Disclosures
We may disclose your personal information for any of the purposes for which it is primarily held or for a lawful related purpose.
We may disclose your personal information where we are under a legal duty to do so.
Disclosure will usually be:
·         internally and to our related entities;
·         to our Clients;
·         to Referees for suitability and screening purposes.

6.1. Related Purpose Disclosures
We outsource a number of services to contracted service suppliers (CSPs) from time to time.  Our CSPs may see some of your personal information.  Typically our CSPs would include:
·         software solutions providers;
·         I.T. contractors and database designers and Internet service suppliers;
·         legal and other professional advisors;
·         insurance brokers, loss assessors and underwriters;
·         superannuation fund managers;
·         background checking and screening agents.
We take reasonable steps to ensure that terms of service with our CSPs recognize that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations.

7. Access & Correction
Subject to some exceptions set out in privacy law, you can gain access to your personal information that we hold.
Important exceptions include:
·           evaluative opinion material obtained confidentially in the course of our performing reference checks; and access that would impact on the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that the person who gave us that information is entitled to expect will be observed. We do refuse access if it would breach confidentiality.
For more information about access to your information see our Access Policy.
For more information about applying to correct your information see our Correction Policy.

7.1. Access Policy
If you wish to obtain access to your personal information you should contact us at: Hi at HRStartup Dot ir
You will need to be in a position to verify your identity.
Important exceptions include evaluative opinion material obtained confidentially in the course of us performing reference checks and access that would impact on the privacy rights of other people. Access may be refused if it would breach any confidentiality that attaches to that information or if it would interfere with the privacy rights of other people. In many cases evaluative material contained in references that we obtain will be collected under obligations of confidentiality that we make and which the communicator of that information is entitled to expect will be observed.
You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information and review information in order to determine what information may be provided. We will generally respond to your request for access within a reasonable time.

 7.2. Correction Policy
If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us.
We will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose [see. Purposes] for which it is held, the information is accurate, up to date, complete, relevant and not misleading.
If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third parties to whom we made the disclosure and we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.
If we are unable to agree that personal information we hold about you is not misleading, relevant, accurate, complete and up-to-date, you may ask us to place with the information a statement by you that claims that particular information is misleading, irrelevant, not accurate, incomplete or out-of-date.
If you wish to have your personal information corrected, you should contact us and we will respond within a reasonable period. You will need to be in a position to verify your identity.

Complaints
You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy.
For more information see our Complaints Procedure.

7.3. Complaints procedure
If you are making a complaint about our handling of your personal information, it should first be made to us in writing.
You can make complaints about our handling of your personal information to us at:
Hi at HRStartup Dot ir
NOTE: The Association Code and Dispute Resolution Rules do NOT constitute a recognized external dispute resolution scheme for the purposes of the Iran’ ECL; but are primarily designed to regulate the good conduct of the Associations members.
When we receive your complaint:
·         we will take steps to confirm the authenticity of the complaint and the contact details provided to us to ensure that we are responding to you or to a person whom you have authorized to receive information about your complaint;
·         upon confirmation we will write to you to acknowledge receipt and to confirm that we are handling your complaint in accordance with our policy;
·         we may ask for clarification of certain aspects of the complaint and for further detail;
·         we will consider the complaint and may make inquiries of people who can assist us to establish what has happened and why;
·         we will require a reasonable time (usually 30 days) to respond;
·         if the complaint can be resolved by procedures for access and correction we will suggest these to you as possible solutions;
·         if we believe that your complaint may be capable of some other solution we will suggest that solution to you, on a confidential and without prejudice basis in our response.

Acceptance
By providing personal information to us, whether verbally or in writing by whatever means then you expressly acknowledge that you have read and understood the terms and conditions outlined under our Privacy statement and as a result of this you consent to the “HR Startup” collecting personal information about you and disclosing and using that information as set out in the above terms.
By applying on line you are accepting our Privacy Statement Terms, have supplied us with true and correct information and have registered with “HR Startup” of your own free will.