Table of Contents

1. Purpose & Legal Basis
2. What Information We Collect
3. How We Collect, Use, Store and Share Information
4. Overseas Disclosure of Information
5. Security, Accuracy & Retention
6. Access and Correction Rights
7. Notifiable Privacy Breaches
8. Privacy Officer / Contact Details
9. Complaints Procedure
10. Policy Review

We may collect the following types of personal information, as reasonably necessary for our operations:

Clients / Prospective Clients

• Name, address, contact phone number and email
• Building, site access, security or emergency contact details
• Cleaning requirements, schedules, preferences

Employees / Contractors / Prospective Staff

• Identity information (name, date of birth, address)
• Contact details (phone, email)
• Employment history, qualifications, references
• Criminal conviction history (only where legally required or relevant to the role)
• Emergency contact information
• Bank account and tax/PAYE information for payroll
• Other lawful data needed for legal compliance (e.g. health & safety, insurance)

Collection

We collect personal information directly from you where possible (e.g. job applications, onboarding, client contracts). We only collect information necessary for the purposes which are lawful and connected to our functions or activities. We will tell you what we are collecting, why, and with whom the information may be shared. This satisfies the IPP 1, 2, 3 of the Privacy Act.

Use

We use personal information for purposes including:

• Providing cleaning and related services to clients;
• Managing employment / contractor relationships;
• Payroll, tax and legal compliance;
• Health & safety and emergency management;
• Communicating with you, scheduling, or responding to your inquiries.

We will not use your information for purposes other than those for which it was collected, unless you consent, or as permitted by law. (IPP 8–10)

Storage & Security

We store information securely, both electronically and physically:

• Electronic data is protected by access controls, passwords, secure backups;
• Physical records are kept in locked filing systems where appropriate;
• Access is limited to those who need the information to perform their job;
• We take reasonable steps to ensure the information is accurate, up-to-date, and complete. (IPP 5, 8)

Sharing / Disclosure

We generally will not disclose your personal information to third parties except:

• with your consent;
• where required for delivering our services (for example to site security, to arrange access);
• where required by law (e.g. for audits, legal compliance);
• to protect someone's safety (if required by law).

We will always ensure that any third parties we share information with are bound by confidentiality obligations and suitable safeguards.

• We take reasonable steps to ensure that personal information is accurate, complete, and up-to-date before we use it. You can help by letting us know if your details change. (IPP 8)
• Retention: we keep personal information only as long as needed for the purposes for which it was collected or required by law. Once no longer needed, we securely destroy or de-identify it. (IPP 9)

We will appoint or identify a Privacy Officer who is responsible for ensuring compliance with this policy and with the Privacy Act 2020.

We will review this policy at least annually or more often if required (for example changes to the law, or if we become aware of a privacy risk). Employees, contractors, and clients may provide feedback at any time.