Privacy Policy

Cogent Business Solutions Pty Ltd (Cogent) is committed to maintaining the privacy and confidentiality of personal information. Cogent adheres to the Australian Privacy Principles (“APPs”) under the Privacy Act 1988 (Cth) (“Privacy Act”) when collecting, using, disclosing, securing and providing access to personal information.

This policy details the practices we have adopted to protect your privacy so that you can feel confident about how we manage the personal information you entrust to us.

We collect personal information (including contact name, telephone number, address, email address, occupation, education and qualifications etc) in a range of contexts:

• when entering into relationships with new clients
• when individuals apply directly for employment with us
• when individuals register online for employment with us
• when the information is required as part of a contract essential to the provision of a business service 

When and Why do we Collect Personal Information?

We collect your personal information when either:

• you provide it to us as part of recruitment or employment, 
• The Australian Government, through one of its departments provides it to us for security clearance purposes

Because:

• you or your company are one of our service providers,
• you make a complaint, comment or ask a question of us,
• you work for us or have applied to work for us,
• you have been in contact with us for another reason in relation to the above.

We will notify you about the collection of personal information at or before the time we collect it, or if that is not practicable, as soon as practicable after personal information about you has been collected. 

What is Personal Information and what do we collect?

The Privacy Act defines ‘personal information’ as:

‘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.’

General Personal Information encompasses general Personal details such as Name, Address, Email, Phone number.

Sensitive Personal Information includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, provided the information or opinion otherwise meets the definition of personal information

We only collect personal information that is required in order for us to carry out our services. This will always include general information. If you have been referred to us for a security clearance this will also include sensitive information and unique identifying information such as a passport number, tax file number or driver licence number.

This information can be collected through a variety of methods including:

• Paper forms completed and submitted by you
• Sent through via email by you
• Provided verbally over the phone or in person by you or one of your referees
• Provided to us by your employer organisation though one of the above means

What do we do with Personal Information?

We may use personal information:

• to enable us to provide capability and services to our clients including personnel security vetting.
• to deliver services in accordance with Australian government policies such as the Government Protective Security Policy Framework (PSPF)
• to communicate information about our services to you
• for our internal administrative, planning, product development and research requirements
• to consider the suitability of applicants for employment with us

Disclosure of Personal Information to Third Parties

We may disclose your personal information to third parties for a number of purposes including:

• Some of our systems are managed externally by Quo Group in accredited/approved environments. Your personal information may be held on these systems.
• Internally for the processing human resource related activities i.e. payroll,
• Other purposes as permitted or required by law.

Specific Disclosures:

• Our Technology Service Provider (Quo Group) – your personnel information may be held on Quo Group servers managed in accordance with the Information Security Manual.
• Use of contractors and outsourced service providers
  
  • Cogent uses contractors and outsourced service providers to undertake certain business functions. 
  • Contractors engaged for security clearance processing, where information about you is provided to the contractors, Cogent or the Commonwealth generally retain effective control of the information and require privacy requirements (such as training, information security, data breaches and auditing) are met in its terms of contract with the contractor.

Apart from this, your personal information is never shared, sold, rented or otherwise disclosed except if required by law or with your consent.

At any time, you may opt-out of receiving any communications from us (other than as required for the operation of our business e.g. regarding payment of accounts).

How we hold and what we do to Safeguard Personal Information?

We will take all reasonable steps to protect and maintain the security of any personal information we receive. We use a variety of secure techniques to protect your information, including:

• An Information Security Policy structure spanning the entire business
• Secure IT infrastructure
• Password protections and access privilege controls
• System audits to ensure policies and procedures are adhered to
• Dissemination markers applied to documents containing personal information
• locked file cabinets of sturdy construction,
• encryption of data and connection through digital certificates.

We have internal policies in place supporting the management of personal information and these are included into the standard training programs to ensure they are followed. Access to personal information is restricted to personnel who have a requirement as part of their duties to access such information. 

Cogent stores personal information about you as hardcopy documents or as electronic data within our or Commonwealth record management and information technology systems.

We will only keep your personal information when we consider it necessary for one of the purposes you have disclosed it. If we consider that it is no longer necessary to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information.

Access and Correction

On written request, Cogent will provide access to any personal and sensitive information we hold about you, subject to some exceptions which are set out in the Australian Privacy Principles (Principle 12 – Access to, and correction of, personal information).

Cogent will respond to any written request for access to personal and sensitive information within 30 calendar days after the request is made.

If your personal information changes or if you no longer require our services, we will take reasonable steps to correct, update or remove the personal data you have provided to us.

We will respond to any written request for correction, update or removal of your personal information within 30 calendar days after the request is made.

Suspected Privacy Breaches

Suspected breaches are handled in accordance with the Privacy Act. If you suspect your information has been breached, please contact us via the details below.

Alternatively, if you would like to make a complaint about a breach of the Australian Privacy Principles you can contact us via the details below. You can also make a complaint to the Office of the Australian Information Commissioner on 1300 363 922 or via their website.

Retention and Disposal of Personal Information

The following are retained for 180 days from the date they are returned to the Australian Government Security Vetting Agency (AGSVA) or Department of Foreign Affairs and Trade, then disposed of at end of month following that date.

• All personally identifiable documents relating to the clearance subject in relation to an Australian Government security clearance.

Links

Websites operated by us may contain links to other sites operated by third parties. We make no representations or warranties as to the privacy practices of any third-party site and are not responsible for the privacy policies of other sites.

Future Changes to Our Privacy Policy

We may change this policy from time to time and will notify you by posting an updated version of this policy on this website. This document represents our policy as at 11 November 2024.

Contacting Us

If you have any questions about our privacy policy, or any complaint regarding the treatment of your privacy by us, please email our Business Manager at [email protected], telephone us on 61 2 6152 9222 or write to us at:

Cogent Business Solutions PO Box 140

FYSHWICK ACT 2609

Where applicable, you have the option of dealing anonymously or by pseudonym with Cogent should you wish to do so.

Cogent’s Privacy Policy is available to be accessed via our website www.cogent.com.au.