Privacy Policy

Effective Date: February 2025

1. Introduction

This Privacy Policy describes how Cloak Investigations Pty Ltd (ACN: 153 946 484, ABN: 20153946484), trading as Employment Screening Group ("we", "us", "our"), collects, uses, discloses and protects personal information through our website at employmentscreeninggroup.com (the "Website").

We are an Australian Criminal Intelligence Commission (ACIC) Accredited Body authorised to conduct national police checks and other employment screening services. We are committed to protecting your privacy and complying with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

2. Information We Collect

2.1 Information You Provide

When you use our Website to apply for police checks or contact us, we may collect:

Personal identification: Full name, email address, phone number
Employment information: Position applied for, employer/organisation name
Location information: Address, state/territory
Application details: Type of check requested, purpose of check
Payment information: Processed securely through our payment provider Stripe

2.2 Information Collected Automatically

When you visit our Website, we automatically collect:

Technical information: IP address, browser type, device information
Usage information: Pages visited, time spent, referral sources through Google Analytics
Essential cookies: Session cookies and CSRF tokens for security purposes

3. How We Use Your Information

We use your personal information to:

Process and fulfil police check applications in accordance with ACIC requirements
Communicate with you about your application status and provide customer support
Process payments for our services
Comply with legal and regulatory obligations
Improve our Website and services through analytics
Protect against fraud and maintain Website security

Important: We do not use information collected from police check applications for marketing purposes.

4. Information Sharing and Disclosure

4.1 ACIC and Law Enforcement

As an ACIC Accredited Body, we are required to share certain personal information with ACIC and relevant law enforcement agencies to conduct police checks. This includes all information necessary for identity verification and criminal history checking as mandated by ACIC standards.

4.2 Client Organisations

When you apply for a police check through a client organisation portal (such as Allambi Care or Junior Adventures Group):

Your application details and check results are shared with the requesting organisation
If your check contains a Disclosable Court Outcome (DCO), you will have the opportunity to review it before it is shared with the client organisation

4.3 Service Providers

We share information with trusted service providers who assist us in operating our Website:

Stripe: Payment processing (they receive payment card information directly)
SendGrid: Email delivery services
Google Analytics: Website analytics and performance monitoring
Hosting providers: Railway and Microsoft Azure (servers located in Australia)

4.4 International Transfers

For international police checks, we may transfer information to relevant authorities in the country where the check is being conducted. Australian police check results obtained through ACIC are not sent offshore without express approval from ACIC.

4.5 Legal Requirements

We may disclose your information when required by law, court order, or other legal processes.

5. Data Retention

The Website itself does not retain personal information. However, our broader business practices include:

Police check applications: Retained for 12 months unless otherwise required by contract or compliance obligations
Financial records: Retained as required by Australian taxation and financial regulations
Website analytics data: Aggregated and anonymised data only

6. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

Encryption of data in transit using HTTPS
Secure payment processing through PCI-compliant providers
Access controls and authentication measures
Regular security reviews and updates
CSRF protection and rate limiting

While we strive to protect your information, no method of electronic transmission or storage is 100% secure.

7. Your Rights

Under Australian privacy law, you have the right to:

Access: Request a copy of personal information we hold about you (identity verification required)
Correction: Request correction of inaccurate information (most corrections must be made at the source, such as ACIC)
Deletion: Request deletion through the ordering entity, subject to legal retention requirements
Complaints: Lodge a privacy complaint with our Privacy Officer

To exercise these rights, please contact our Privacy Officer using the details in Section 11.

8. Cookies and Tracking

Our Website uses only essential cookies required for security and functionality:

Session cookies to maintain your session while using the Website
Security cookies (CSRF tokens) to protect against cross-site request forgery attacks

We also use Google Analytics to collect aggregated information about Website usage to improve our services. This data is anonymised and used for Website improvement, marketing insights, and performance monitoring.

9. Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. Continued use of our Website after changes constitutes acceptance of the updated policy.

11. Contact Information

For privacy-related enquiries or to exercise your rights, please contact our Privacy Officer:

Email: support@employmentscreeninggroup.com
Phone: 1300 681 541
Postal Address: Building 1, Suite A1 Level 3, 209 Robina Town Centre Drive, Robina QLD 4226
Hours: Monday to Friday, 9am-5pm AEST

12. Complaints

If you have a privacy complaint, please contact our Privacy Officer first. We will investigate and respond to your complaint within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

13. ACIC Compliance

As an ACIC Accredited Body, we comply with all ACIC standards and requirements for the handling of personal information in connection with national police checks. This includes strict protocols for information security, data handling, and disclosure practices.