CV Screen Pty Ltd Privacy Policy

Effective Date: 29 May 2024

1. Introduction

CV Screen Pty Ltd (ABN 55 643 347 296) (“we”, “our”, “us”) is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy explains how we collect, use, disclose, store, and manage personal information, and how you can access or correct your information.

2. Nationally Coordinated Criminal History Check

CV Screen Pty Ltd (“CV Screen”) is authorised to access nationally coordinated criminal history checks through the Australian Criminal Intelligence Commission (ACIC), which administers the process under the Australian Crime Commission Act 2002 (Cth) (ACC Act). The National Police Checking Service (the Service), delivered in partnership with Australian police agencies, enables access to Police Information in accordance with applicable Australian laws.

As permitted under the ACC Act, the Service provides CV Screen with Police Information to assist in assessing the suitability of individuals for roles of trust, specific professions, or to meet legislative obligations.

To access this Service, CV Screen is accredited under section 46A(5) of the ACC Act and has entered into a formal Agreement with the ACIC. By signing the Agreement Schedule, CV Screen affirms its commitment to comply with all applicable requirements, including those outlined in the Privacy Act 1988 (Cth).

With direct access to the Service, CV Screen plays an important role in supporting the safety and security of the Australian community.

3. Collection of Personal Information

The personal information we collect depends on your interaction with us and is limited to what is essential to facilitate nationally coordinated criminal history checks. This information may include:

  • Full name, gender, date and place of birth

  • Residential address history

  • Driver’s licence, firearm licence, or passport details

  • Contact information

  • Information related to the purpose of the check or employment

  • Details or opinions associated with current or previous check applications

This may also include “sensitive information” or personal opinions, whether factually correct or not, about an applicant.

We collect personal information directly from you when you interact with us—such as by visiting our website, creating a user account, placing an order for checks, entering into agreements, corresponding with us, or providing feedback. We may record and retain details of these transactions.

Additionally, we may monitor and record communications (including email and phone conversations) for security, training, and dispute resolution purposes. We may also collect personal information from third parties, such as identity verification data obtained through the Document Verification System (DVS) during the check process.

We store personal information both electronically (via password-protected systems, email, and web forms) and in hard copy, maintained in a secure, access-controlled environment. Our primary database is Australian-owned and located within Australia.

Where appropriate and possible, we will explain why the information is being collected and how it will be used at the time of collection.

Why and How We Collect, Hold, Use, and Disclose Your Personal Information

We collect, hold, use, and disclose personal information to deliver our services effectively, lawfully, and in line with your expectations and applicable legal obligations. We do so for the following purposes:

  • To lodge identity verification applications and receive results through the Department of Home Affairs Document Verification Service (DVS)

  • To confirm proof of identity

  • To process payments for our services

  • To share identity check results with persons you or your applicants authorise

  • To provide results to designated parties, as outlined in our terms and conditions

  • To enable authorised third parties to verify identity check results

  • To deliver and improve the quality of our services

  • To fulfil our obligations under agreements with the Department of Home Affairs relating to the DVS

We only collect personal information when it is reasonably necessary for one or more of these functions. The processing of personal information will only occur under one or more of the following lawful bases:

  • To perform a contract with you

  • Where we have a legitimate interest that is not overridden by your rights

  • To meet legal or regulatory obligations

  • With your consent

We may disclose personal information to the following entities as required to fulfil the above purposes:

  • Our contractors, consultants, advisors, associates, or related entities

  • Government bodies, industry regulators, tribunals, or courts in relation to a complaint, legal matter, or regulatory requirement

  • Other entities or third parties with your express consent (e.g. parties you authorise to verify your identity) or as required by law

In some cases, we may also use your personal information for a secondary purpose that you consent to, including:

  • De-identifying your personal information (removing personal identifiers to create anonymised data), and

  • Using or disclosing this de-identified data for analytical, research, or service improvement purposes

All personal information is collected fairly, lawfully, and in a non-intrusive manner. If you choose not to provide certain personal information, we may be unable to offer some or all of our services, and certain features on our website may not function as intended.

Direct Marketing

We may use your personal information, including your contact details, to send you information about our products and services that we believe may be of interest to you.

You have the right to opt out of receiving marketing communications from us at any time. You can choose to stop receiving marketing messages entirely or specify your preferred communication channels (e.g. email, SMS, phone, or mail).

  • To opt out of email marketing, simply use the “unsubscribe” link provided in our emails.

  • To opt out of other forms of marketing communication, please contact our Data Protection Officer using the contact details provided below.

We will respect your preferences and ensure your request is actioned promptly.

How We Hold and Protect Your Personal Information

We are committed to safeguarding your personal information and take appropriate technical and organisational measures to protect it. While no system can ever be completely secure, we continuously assess and enhance our security practices to mitigate risks.

We implement a range of security controls, including:

  • Encryption and pseudonymisation of data;

  • Access controls and authentication protocols;

  • Data retention policies to ensure information is not kept longer than necessary.

Personal information is stored in both electronic and physical formats. Electronic data is hosted on secure, password-protected servers maintained by third-party providers. As of the date of this policy, all personal information is stored exclusively within Australia.

To prevent misuse, loss, or unauthorised access, modification, or disclosure, we maintain:

  • Physical security measures to restrict access to our premises;

  • Network security, including strong password and firewall protections;

  • Secure communication protocols; and

  • Restricted access to personal information, limited to authorised staff and contractors only.

When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it (refer to the “Retention” section for more detail).

To further secure the identity verification process, we implement additional measures such as:

  • Logging IP addresses;

  • Capturing and securing payment information;

  • Verifying identity by comparing your official ID with a self-captured photo (e.g., a “selfie” taken via a smartphone, tablet, or webcam); and

  • Capturing digital signatures.

These steps help ensure the integrity and security of our services and protect your personal data throughout the verification process.

Why We Disclose Information to Other Organisations

We disclose personal information strictly in accordance with the services we provide and as outlined in this Privacy Policy.

To deliver the highest quality products and services, we may collaborate with trusted third-party service providers. Some of these providers operate partly or entirely from overseas. In such cases, personal information may be transferred internationally to facilitate efficient and secure service delivery.

For example:

  • We may partner with a third party to verify the authenticity of identity documents, ensuring compliance with proof-of-identity requirements.

  • We may engage providers to monitor email delivery (e.g., bounce tracking) to improve communication reliability.

These disclosures may involve personal information such as your (or your applicant’s) name, address, date of birth, contact details, driver’s licence, or passport details. The countries where these third parties are located may vary over time and will be updated as necessary.

We may also disclose personal information to a third party where:

  • You have authorised them to access your identity verification results; or

  • They require access via a secure verification feature to validate the authenticity of your identity check.

By sharing a verification report (electronically or in hard copy) with a third party, you acknowledge and consent to our provision of associated personal information through secure verification channels. This process helps maintain the accuracy, integrity, and security of the verification.

In addition, we may disclose aggregated, de-identified data to third parties to improve our services. This type of information does not identify any individual and is used solely for analysis and enhancement purposes.

We also use tools such as Google Analytics User-ID tracking to collect aggregate data about service use. This tracking does not collect or store sensitive personal information. If you prefer not to be included in this tracking, please contact our Data Protection Officer or reach out using the contact details provided in this policy to opt out.

4. Sensitive Information

Under the Privacy Act 1988 (Cth), sensitive information refers to information or an opinion about an individual’s:

  • racial or ethnic origin,

  • political opinions or membership of a political association,

  • religious or philosophical beliefs,

  • membership of a trade union or other professional or trade association,

  • criminal record, or

  • health information.

We collect and use sensitive information strictly for the primary purpose of delivering nationally coordinated criminal history checks through the National Police Checking Service. This information will only be used or disclosed where it is:

  • directly related to the purpose for which it was collected, and

  • required or authorised by law.

We treat all sensitive information with the highest level of confidentiality and take appropriate security measures to protect it in accordance with applicable legislation and industry standards.

5. Third Parties

We may engage third parties to support the delivery of our services, including the facilitation of nationally coordinated criminal history checks through the National Police Checking Service. These third parties may include technology providers, identity verification services, data storage providers, and other trusted service partners.

We disclose personal and sensitive information to third parties only:

  • for the primary purpose for which it was collected (e.g., processing criminal history checks);

  • where required or authorised by law;

  • with your explicit consent; or

  • where disclosure is otherwise permitted under the Privacy Act 1988 (Cth).

Sensitive information—as defined under the Privacy Act—includes details or opinions about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union or professional association membership, criminal record, or health information.

We take all reasonable steps to ensure that third parties handle your information in a secure and compliant manner, consistent with applicable privacy legislation and our own privacy and security standards.

6. Purpose of Collection

We collect personal information lawfully, fairly, and in a non-intrusive manner. The primary purpose of collecting personal information is to facilitate nationally coordinated criminal history checks through the National Police Checking Service.

For Individual Users:

We collect personal information to:

  • verify the accuracy of information you have provided, including information sourced from third parties;

  • administer and deliver our services to you;

  • communicate with you effectively;

  • understand customer needs and continually enhance our services;

  • detect and prevent fraud, misuse, or data loss;

  • protect your security while using our website.

For Corporate Users:

We collect personal information to:

  • verify the accuracy of information you and your organisation have provided, including information sourced from third parties;

  • meet legal obligations by identifying users who access personal information through our system;

  • administer and deliver our services to your organisation;

  • support effective communication with corporate clients;

  • understand organisational needs and improve our service offerings;

  • prevent fraud, misuse, or loss of data;

  • ensure secure access to our digital platforms.

Compliance and Quality Assurance
CV Screen maintains rigorous internal policies and procedures to ensure the integrity and accuracy of information submitted through the Service. We validate all information prior to formally lodging a police check. Our operations comply with standards set by the Australian Criminal Intelligence Commission (ACIC) and are subject to regular audits and compliance reviews by ACIC and its authorised personnel.

We maintain up-to-date security systems, including firewalls, antivirus protection, and regularly updated operating systems, to safeguard all personal information.

Policy Updates
This Privacy Policy is subject to change. The most current version will always be available on our website.

7. Manner of Collection – Cookies

Cookies are small data files that are stored on your device when you access our website. They typically contain a string of letters and numbers that uniquely identify your device and may store information such as your username and password used for registration.

We use session cookies that are active only while you are logged into our site. These cookies help enhance security by verifying your identity and allowing seamless access to secure areas of the website without requiring you to re-enter your login details during your session.

You have control over your cookie preferences. Most web browsers allow you to:

  • configure settings to refuse cookies,

  • delete cookies stored on your device.

Please note that disabling or deleting cookies may affect your ability to access certain features or secure areas of our website.

8. Storage and Security – Security of Personal Information

We store your Personal Information in a manner that reasonably protects it from misuse, loss, and unauthorized access, modification, or disclosure. Our security measures include:

  • Physical security to prevent unauthorized access to our premises;

  • Regular staff training on best practices for information security;

  • Computer network security, including strong password controls to prevent unauthorized access;

  • Secure communication protocols;

  • Restricting access to authorized personnel only.

When your Personal Information is no longer required for the purpose it was collected, we take appropriate steps to securely destroy or de-identify the information. Data is retained for twelve months and disposed of within three months, in accordance with our agreement with the ACIC. Identification documents submitted via our website are deleted once the police release your check results. Payment details are handled securely by third-party payment gateway providers and are not accessible to us.

At CV Screen, we promote a culture of privacy and security awareness through ongoing staff training, adequate resourcing, and strong management oversight. Our commitment to continuous improvement means our Information Security Policy is regularly reviewed and updated to ensure ongoing compliance and effective management.

Key elements of our Information Security Policy include:

  • Clearly defined information security roles, responsibilities, and clearance levels;

  • Physical security for hard copy, media, and electronic records to prevent unauthorized access;

  • Access controls including password protection, restricted file access, and firewall implementation;

  • Technical safeguards such as anti-virus software and up-to-date operating systems;

  • Secure management of digital certificates;

  • Enforcement of strong password policies;

  • Regular staff training on information security awareness;

  • Procedures for incident management and prevention.

9. Information Disclosure – Disclosure of Personal Information

Personal Information may be collected by the Australian Criminal Intelligence Commission (ACIC), Australian police agencies, or other parties as authorised by law.

The following parties may have access to your Personal Information and police check results:

  • Authorised CV Screen staff who request and receive the police check results;

  • Authorised ACIC personnel supporting CV Screen and police agencies in processing the police check;

  • Authorised police staff involved in the assessment of the police check;

  • Third-party organisations, but only with your consent or as permitted by relevant legislation.

All authorised CV Screen staff undergo specialised training to ensure your Personal Information is handled securely and in accordance with our Information Security Policy. We do not transfer or disclose Personal Information to parties outside Australia.

Please note that the ACIC cannot be contacted directly by members of the public. For any enquiries, please email: contact@cvscreen.com.au.

For more information about the ACIC, please visit their website: https://www.acic.gov.au/our-services/national-police-checks

10. Information Access – Access to Your Personal Information

You have the right to access the Personal Information we hold about you and to request updates or corrections, subject to certain exceptions.

To access your Personal Information or to lodge a complaint, please email us at: contact@cvscreen.com.au.

CV Screen does not charge a fee to process access requests; however, an administrative fee may apply if you request a copy of your Personal Information.

To protect your privacy, we may require you to provide identification before releasing the requested information.

11. Complaints and Check Result Dispute

CV Screen welcomes feedback on all aspects of our business. If you submit a complaint, we will record it and respond within three business days with an outcome or the next steps required to resolve the issue.

If you dispute the result of a nationally coordinated criminal history check, you can submit a dispute using the official ACIC dispute form. We will lodge your completed dispute form directly with the ACIC for investigation.

The relevant police agencies will investigate the dispute and determine an appropriate outcome. CV Screen will contact you if further information is required to support the investigation.

Once the investigation is complete, you will be informed whether the dispute was:

  • Successful – resulting in a new or amended police check; or

  • Unsuccessful – the original result remains unchanged.

Unsuccessful disputes can be challenged further, and additional documentation may be requested to support your case.

If you have complaints about how we collect, use, disclose, store, secure, or dispose of your Personal Information—including any breaches or concerns about our policies—please email us at: contact@cvscreen.com.au.

If you are not satisfied with our response to your complaint, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC) at http://www.oaic.gov.au.

Unsubscribe

If you no longer wish to receive communications from us, you may unsubscribe at any time by using the unsubscribe option included in our emails or by updating your communication preferences. Alternatively, you can contact our Data Protection Officer (details above) to opt out of our communications.

12. Information Corrections

It is important to us that your Personal Information is accurate and up to date. We take reasonable steps to ensure the information we hold is complete and current. If you believe any of your Personal Information is incorrect or outdated, please notify us as soon as possible so we can update our records and continue to provide you with quality services.

13. Use of the Document Verification Service (DVS)

How We Use the DVS
We use the Department of Home Affairs Document Verification Service (DVS) to verify identity documents provided by you or your applicants. This allows us to confirm the authenticity of identification information efficiently and securely as part of providing nationally coordinated criminal history checks. The DVS helps us meet our verification obligations while protecting your personal information.

Legal Obligations Regarding Collection
We collect personal and identification information lawfully and fairly in accordance with the Privacy Act 1988 (Cth) and the Australian Crime Commission Act 2002 (Cth). Our use of the DVS complies with these legal frameworks, and we only collect information that is necessary for identity verification and related services. We are also bound by agreements with the Department of Home Affairs regarding the handling and security of your data.

Your Rights in Relation to Collection
You have the right to:

  • Access the personal information we hold about you;

  • Request corrections to any inaccurate or incomplete information;

  • Withdraw your consent to the collection and use of your information, noting this may affect our ability to provide certain services;

  • Lodge a complaint if you believe your information has been mishandled (see below).

Consequences of Declining Consent
If you choose not to provide consent for the collection and verification of your identification information through the DVS, we may be unable to verify your identity, or we may manually verify your documents. This may result in delays or prevent us from processing your nationally coordinated criminal history check or other related services.

Making Complaints
If you have any concerns or complaints about how your identification information is collected, used, or disclosed in relation to the DVS, please contact us at:
Email: contact@cvscreen.com.au

If you are not satisfied with our response, you can escalate your complaint to the Office of the Australian Information Commissioner (OAIC) via their website: http://www.oaic.gov.au.

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