Impact People Solutions – Privacy Policy
Last updated: 29 May 2025
DJCO Pty Ltd as trustee for the CPO Connect Trust (CPO Connect, we, us or our) is committed to providing quality services to you and understands the importance of your privacy.
This policy outlines how we collect, hold, use and share your personal information and your rights in relation to that information. While we are not captured by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), we do our best to comply with Australian privacy legislation in handling personal information.
This policy does not constitute a contractual representation, promise, guarantee or warranty by us to you as to the manner in which we will or may collect, store, use, disclose, protect or otherwise handle your personal information.
What is personal information?
Personal information is information or an opinion about an individual that is or could reasonably be identified, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Why do we collect personal information?
We collect your personal information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your personal information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
Generally, our services are mostly intended for use by employer organisations. The organisation that engages us or enters into our subscription terms will control its instance of the services and be responsible for the personal information it discloses to Impact People Solutions.
If we do not collect personal information, we may not be able to provide you or your employer with our products or services.
What personal information do we collect?
The type of personal information we collect depends on the nature of your interactions with us. We may collect personal information about our clients, their employees, our contractors and employment applicants.
Generally, the types of personal information we collect includes:
- names;
- contact details (including email address, postal address and phone number);
- profession, occupation and job title;
- social media account details;
- gender and date of birth;
- information about the products and services you have enquired about;
- billing information such as bank details;
- information about your use of our goods and services;
- information about other types of services you may be interested in;
- information or data which we automatically collect from you through the use of cookies or similar technologies, such as location data and online identifiers;and
- any other information you provide to us.
When we collect personal information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive information
The personal information we collect may contain sensitive information. Sensitive information is defined in the Privacy Act as information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- for the primary purpose for which it was obtained;
- for a secondary purpose that is directly related to the primary purpose;
- with your consent; or
- where required or authorised by law.
When and how do we collect personal information?
We may collect personal information about you when:
- you provide it to us directly – eg, if you submit a form, contact us via phone or email or enter your personal details when using our services;
- we receive it from another party or source – eg, from your social media account if you provide it to us, from your employer, our related companies or public information; or
- we collect it automatically – eg, via cookies and log data relating to your use of the website.
Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Collecting the personal information about someone else
If you provide us with the personal information of someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.
You must take reasonable steps to ensure the individual concerned is aware of and consents to the various matters detailed in this privacy policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, our identity, and how to contact us.
Where requested to do so by us, you must also assist us with any requests by the individual to access or update the personal information you have collected from them and provided to us.
Unsolicited information
If we receive personal information that we have not requested and determine that the personal information received is not reasonably necessary to provide our services, we will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
Anonymity/pseudonymity
Where practicable, you may be able to interact with us anonymously or by using a pseudonym. Circumstances where it is not practicable, however, include where personal information is required to complete a credit card transaction or to contact you about our services or services you might be interested in.
Cookies and information about visits to our websites
We may collect information about how you use and visit our websites, apps and other digital services. For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information only in anonymous, aggregated form for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose such information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
We may also collect information based on how you use any of our websites, including through ‘cookies’, web beacons and other similar technologies.
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable our systems to recognise your browser and record information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).
We use cookies to provide you with a more consistent experience across our services. No attempt is made by us to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of our websites may not function fully for users that disable cookies.
Use and disclosure of personal information
Personal information is collected, stored and used for a range of purposes so that we can provide products and services that you request, give you access to our products or services, identify and promote products or services that may be of interest to you, respond to your enquires and to share your information with our contracted partners for marketing and analytics purposes.
We may also use and disclose your personal information to:
- consider any concern or complaint that you raise against us or to manage any legal action between you and us;
- prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
- enforce legal rights; or
- comply with any relevant laws, regulations, codes of practice and court orders.
Your personal information may also be disclosed to various third parties to enable us to provide our products and services or to support our business functions.
We do not disclose any personal information to entities located overseas. However, we may transfer your personal information to an entity which is in a foreign country to assist us in providing our products and services. For example, your personal information may be stored on servers located overseas by our third-party cloud storage providers, or it may be provided to current or potential contracted overseas services providers or partners where the provision of our products or services requires the transfer of the information.
Third party links
Our website and services may contain links to other websites. We do not share your personal information with those websites and we are not responsible for the privacy practices applying in respect of those websites.
Security of personal information
Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information.
Direct marketing
We may send you direct marketing communications regarding our products and services. We may send these communications to you by email, phone and by other means, unless you opt-out or we are subject to legal restrictions from doing so. You may opt-out of receiving marketing communications from us at any time by contacting us via the contact details at the end of this privacy policy or by using the opt-out mechanism included in our marketing communications.
Access to your personal information
You may contact us to request access to your personal information and you may also ask us to correct information that we hold that you believe is inaccurate, incomplete or out of date. We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your personal information.
In order to protect your personal information we may require identification from you before releasing the requested information.
In certain circumstances, we may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, we will write to you to explain the reasons why this is the case.
Maintaining the quality of your personal information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Making complaints and enquiries
If you have any queries or complaints about our privacy policy please contact us on:
CPO Connect
We may ask you to place your concerns in writing so that our compliance staff can fully understand and investigate your complaint.
We will provide you with an estimated response timeframe in relation to your complaint. In any event, we will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
Policy updates
This policy may change from time to time and is available on our website.