Privacy Policy

  1. Sharp & Carter Privacy Policy

Effective date: 22 April 2026

1. INTRODUCTION

Sharp & Carter Pty Ltd and its related bodies corporate listed in the Appendix (collectively, “Sharp & Carter”, “we”, “us” or “our”) are committed to protecting the privacy of the individuals whose personal information we collect and handle. This Privacy Policy explains how we collect, hold, use,discloseand otherwise handle personal information in connection with our business as a recruitment, executive search, labour hire, contracting and related workforce solutions provider in Australia.

We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs), and other applicable Australian laws and regulatory obligations. Where applicable, this includes obligations relating to direct marketing, employment, workplace, tax, superannuation, record-keeping, cyber security, and notifiable data breaches.

This Privacy Policy is intended to provide an explanation of our personal information handling practices, including:

  • what personal information we collect;

  • how we collect it;

  • why we collect, use and disclose it;

  • how we store and protect it;

  • when we may disclose it in Australia or overseas;

  • how long we keep it; and

  • how you can access, correct or complain about our handling of it.

This Privacy Policy applies to personal information relating to:

  • candidates and prospective candidates;

  • labour hire employees, temporary workers, contractors and contingent workers;

  • referees and emergency contacts;

  • clients and prospective clients;

  • suppliers, service providers and business partners;

  • visitors to our websites, portals and digital platforms;

  • individuals who subscribe to our communications or attend our events; and

  • individuals who otherwise interact with us.

This Privacy Policy does not form part of any employment contract, labour hire assignment, contractor agreement, or services agreement, but it applies to the handling of personal information in connection with those arrangements.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?

The Sharp & Carter entity that collects or holds your personal information will usually be the entity that:

  • engages withyou;

  • provides services to you or yourorganisation;

  • employs or engagesyou;

  • places you with a client; or

  • operates the platform,eventor campaign through which your information is collected.

A list of Sharp & Carter entities is set out in the Appendix.

Because we operate as a group, your personal information may be shared between Sharp & Carter entities where reasonably necessary for recruitment, labour hire, administrative, operational, risk, legal, compliance, technology, finance, payroll, reporting or related business purposes.

3. WHAT IS PERSONAL INFORMATION?

In this Privacy Policy, “Personal Information” means information or an opinion about an identified individual, or an individual who isreasonably identifiable,whether or notthe information is true andwhether or notit is recorded in a material form.

Examples include a person’s name, contact details, resume, work history, interview notes, identification documents, online identifiers, payroll details, and information about workplace performance or incidents where that information identifies, or could reasonably identify, the individual.

We may also handle “Sensitive Information” where permitted by law. Sensitive Information may include information such as criminal record information, union membership, or other categories recognised as sensitive information under the Privacy Act 1988 (Cth).

4. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT?

The kinds of personal information we collect depend on who you are, how you interact with us, the services being provided, and the legal and operational requirements that apply.

4.1 Candidates & Prospective Candidates

If you are a candidate or prospective candidate, we may collect and hold personal information including:

  • your name, preferred name, and title;

  • contact details such as email address, telephone number, and residential address;

  • date of birth where relevant or required;

  • resume, CV, cover letters, work history and career background;

  • education, qualifications, training, licences, tickets, accreditations, and memberships;

  • skills, experience, competencies, salary expectations, benefits expectations, work preferences, mobility, and availability;

  • citizenship, visa status, working rights and related supporting documentation;

  • interview notes, candidate registrations, consultant notes, call notes, and correspondence;

  • role preferences, job search criteria, and placement history;

  • referee details and referee feedback;

  • psychometric, aptitude, skills, personality or behavioural assessment results where used;

  • results of background checks, screening checks and verification processes where required or authorised, including identity checks, right to work checks, reference checks, qualification checks, and criminal record checks where lawful and relevant;

  • information about conduct, complaints, investigations, incidents or workplace concerns relevant to a role, placement or employment relationship;

  • information about absences, fitness for work, restrictions or adjustments where relevant and lawful;

  • compensation, remuneration and payroll-related information where relevant;

  • photographs, video interview content or recorded interviews where used and notified;

  • information you provide through forms, websites, portals, surveys, competitions, webinars or events; and

  • any other information you choose to provide to us.

4.2 Labour Hire Employees, Temporary Workers, & Contractors

If you work for or through Sharp & Carter in a labour hire, temporary, contractor, or contingent worker capacity, we may also collect and hold:

  • employee or contractor identifiers;

  • tax file number information where permitted and required bylaw;

  • bank account details;

  • superannuation fund details;

  • payroll, pay rate and timesheet information;

  • attendance, roster, assignment and shift information;

  • leave, absence and availability information;

  • emergency contact details;

  • workplace health and safety information, including incident reports, injury information and return to work information where lawful and necessary;

  • site access, induction and compliance records;

  • client feedback, performance records and assignment history;

  • disciplinary, grievance or conduct information where relevant;

  • records needed to meet obligations under workplace, industrial, tax, superannuation, workers compensation and related laws; and

  • any other information reasonably required to employ, engage, assign, manage, pay or support you.

4.3 Clients & Prospective Clients

If you are a client, prospective client or representative of a client, we may collect and hold:

  • your name, job title and business contact details;

  • organisation details and business profile information;

  • job briefs, hiring requirements, organisational charts and workforce planning information;

  • information about vacancies, remuneration, structures, projects, systems or teams;

  • interview and recruitment process feedback;

  • information required to provide labour hire, contracting, recruitment, executive search or related services;

  • marketing preferences, event attendance and engagement history; and

  • correspondence and records of communications with us.

4.4 Referees & Other Third Parties

If you are a referee, emergency contact, former employer representative, educator, verifier or other third party, we may collect and hold:

  • your name, title and contact details;

  • your relationship to a candidate;

  • your organisation and position;

  • information you provide about a candidate’s employment history, conduct, performance, skills, suitability or other relevant matters; and

  • records of communications, checks and assessments involving you.

4.5 Website Users, Portal Users, & Marketing Contacts

If you use our websites, portals or digital platforms, or subscribe to our communications, we may collect and hold:

  • your name and contact details;

  • account, login or profile details;

  • information you submit in forms, chat tools, registrations or downloads;

  • preferences and subscription information;

  • IP address, browser type, operating system, device type and device identifiers;

  • cookie information and similar tracking technology data;

  • website usage information, including pages viewed, session duration, navigation paths, referring URLs and interactions with content;

  • email engagement data such as opens, clicks and unsubscribes;

  • information collected through analytics tools, advertising tools and tracking pixels; and

  • any other information you provide or that is generated by your interaction with our digital properties.

4.6 Sensitive Information

We only collect sensitive information where:

  • you consent;

  • the collection is reasonably necessary for our functions or activities and permitted by law; or

  • we are otherwise required or authorised by law to do so.

Depending on the circumstances, this may include:

  • health information relevant to fitness for work, workplace adjustments, injury management, workers compensation or assignment suitability;

  • criminal record information where relevant to a particular role, client requirement or legal obligation;

  • biometric or identity verification information where used lawfully by a third-party verifier;

  • union or professional association membership where relevant and lawfully handled; and

  • other sensitive information you choose to provide.

​​We ask that you do not provide sensitive information unless it is reasonably necessary for the relevant purpose or we have requested it.

5. HOW DO WE COLLECT PERSONAL INFORMATION?

We may collect personal information directly from you, from third parties, from publicly available sources, and through automated means associated with our systems and digital platforms.

5.1 Direct collection

We commonly collect information directly from you when you:

  • submit a resume or job application;

  • register through our website, candidate portal, or other platform;

  • attend an interview or screening call;

  • communicate with our consultants by phone, email, video call, text message, or in person;

  • provide information for payroll, onboarding, or compliance purposes;

  • complete a form, survey, assessment or questionnaire;

  • attend one of our events, webinars, or promotions;

  • subscribe to salary guides, newsletters, market updates, or alerts; or

  • otherwise interact with us.

5.2 Collection from third parties

We may collect personal information about you from third parties where lawful and reasonable, including from:

  • referees and nominated contacts;

  • current and former employers, managers, or colleagues;

  • clients and prospective clients;

  • job boards and professional networking platforms such as SEEK and LinkedIn;

  • recruitment platforms;

  • skills assessment, psychometric testing, and background screening providers;

  • education, licensing, qualification, and right to work verification providers;

  • payroll, timesheet, onboarding, and compliance providers;

  • publicly available sources and media;

  • corporate websites and professional directories; and

  • other service providers, suppliers, and publicly accessible sources relevant to recruitment, labour hire, or business development.

Where appropriate, we will obtain your consent before collecting certain information from third parties, especially where sensitive information is involved or where consent is otherwise required.

5.3 Collection from publicly available and professional sources

As part of recruitment, executive search, labour hire, and business development activities, our consultants may collect professional profile information from publicly available or professional sources, such as LinkedIn profiles, public resumes, business websites, industry directories, networking events, media articles and similar sources.

We do this to identify, assess and contact prospective candidates, verify information, understand labour markets, support client assignments and build relevant professional networks.

Where required by law, we will take reasonable steps to provide notice of collection.

5.4 Automated collection through digital channels

When you visit our website, use our portal, click on our emails, interact with our digital advertising or otherwise engage with our online services, we and our technology partners may collect information automatically using technologies such as:

  • cookies;

  • web beacons;

  • pixels and tracking pixels;

  • tags;

  • scripts;

  • server logs; and

  • analytics and advertising technologies.

These technologies help us understand website behaviour, improve user experience, administer our platforms, measure campaign performance, personalise content, maintain security, and support marketing and remarketing activities.

6. WHY DO WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?

We collect, hold, use and disclose personal information where reasonably necessary for our functions and activities as a recruitment, executive search, labour hire and workforce solutions business, and for related business, legal, compliance and operational purposes.

Depending on the circumstances, we may use and disclose personal information for the following purposes:

6.1 Recruitment

  • sourcing, identifying and contacting potential candidates;

  • assessing candidate suitability for permanent, temporary, contract, labour hire or executive opportunities;

  • shortlisting, interviewing and evaluating candidates;

  • presenting and representing candidates to clients for current and future opportunities;

  • arranging interviews and managing recruitment processes;

  • obtaining and considering references, checks and verifications;

  • maintaining candidate profiles and talent pools;

  • communicating about relevant vacancies and opportunities; and

  • supporting clients with workforce planning and recruitment decisions.

6.2 Labour Hire, Employment, & Assignment Management

  • employing or engaging labour hire employees, contractors, and temporary workers;

  • onboarding workers and managing placements, and assignments;

  • payroll processing, superannuation administration, and taxation compliance;

  • timesheet processing, attendance monitoring, and assignment administration;

  • work health and safety management, site compliance and incident response;

  • managing fitness for work, leave, availability and workplace adjustments;

  • responding to performance issues, complaints, misconduct or grievances;

  • administering workers compensation, return to work and insurance-related processes;

  • fulfilling obligations to clients in relation to labour hire services; and

  • maintaining records required under employment, workplace, industrial, tax and related laws.

6.3 Client Service Delivery 

  • taking job briefs and understanding hiring needs;

  • introducing candidates and facilitating recruitment processes;

  • providing labour hire, contract and recruitment services;

  • managing client relationships and service quality;

  • preparing proposals, service documentation, market insights and related materials;

  • administering invoicing, credit, collections and related commercial functions; and

  • maintaining operational records relevant to services provided.

6.4 Business Development, Marketing, & Communications

  • sending newsletters, alerts, market updates, event invitations, salary guides and other communications;

  • promoting our services, brand and events;

  • conducting surveys, market analysis and business intelligence activities;

  • maintaining and improving our websites, portals, campaigns and communications;

  • tailoring content and advertising;

  • measuring campaign performance and audience engagement; and

  • managing opt-ins, unsubscribes and communication preferences.

6.5 Risk, Compliance, & Legal Purposes

  • meeting legal, regulatory, and contractual obligations;

  • establishing, exercising or defending legal claims;

  • complying with lawful requests, court orders, warrants or regulatory requirements;

  • conducting audits, investigations and risk assessments;

  • protecting the rights, property, systems, people, reputation and operations of Sharp & Carter, our clients and others;

  • maintaining business continuity, cyber security, and fraud prevention measures; and

  • responding to suspected misconduct, unlawful activity, or security incidents.

6.6 Training & Quality Assurance

  • training our consultants and support teams;

  • maintaining quality assurance and recruitment process integrity;

  • reviewing consultant performance and service outcomes;

  • analysing market trends and workforce patterns; and

  • improving our systems, workflows, methodologies, and digital tools.

7. CANDIDATE REPRESENTATION 

As part of our recruitment and executive search services, candidates may provide information to Sharp & Carter so that our consultants can consider them for opportunities and, where appropriate, represent them to clients.

By applying for a role through us, providing a resume or profile to us, requesting our assistance in relation to a job search, engaging in a recruitment process with us, or otherwise indicating interest in being considered for roles, you acknowledge and agree that Sharp & Carter may:

  • assess your suitability for current and future opportunities;

  • contact you about relevant opportunities;

  • present your profile, resume, candidate summary, interview impressions, consultant observations and other relevant recruitment information to clients;

  • discuss your candidacy with clients, including our assessment of your alignment to a role;

  • retain your details in our candidate database and talent pools;

  • contact you about future roles that we reasonably consider may be relevant to you; and

  • create consultant summaries, market maps and internal candidate records for recruitment and client servicing purposes.

Where required by law or where appropriate in the circumstances, we will seek your consent before disclosing sensitive information or before presenting you for a role where additional consent is appropriate. Nothing in this Privacy Policy obliges Sharp & Carter to present, continue to represent, or promote any candidate to any client, or to disclose confidential information received from clients, referees or other third parties.

8. REFERENCE CHECKS & EVALUATIVE MATERIAL

Reference checking is an important part of recruitment and labour hire processes.

Where you nominate a referee, or where a referee otherwise provides information about a candidate, we may collect, hold, use and disclose referee information and reference content for recruitment, suitability assessment, employment, assignment, compliance and related purposes.

To protect the integrity of recruitment processes and encourage candid participation by referees:

  • evaluative material provided in confidence may be treated as confidential;

  • we may decline to provide access to confidential evaluative material where permitted by law;

  • we may use reference information to assess suitability, conduct, performance, capability and risk;

  • we may disclose reference information or our conclusions drawn from it to relevant clients, internal decision-makers or service providers where reasonably necessary and lawful; and

  • we may retain records of references and related consultant notes for audit, compliance, legal and operational purposes.

Candidates should ensure they have authority to provide referee details before nominating a referee.

9. WHEN CAN WE USE OR DISCLOSE YOUR PERSONAL INFORMATION?

We may use or disclose personal information for the primary purpose for which it was collected, for related purposes that would reasonably be expected, with your consent, or as otherwise permitted or required by law.

Depending on the circumstances, we may disclose personal information to:

  • our related entities;

  • our employees, consultants and authorised representatives;

  • clients and prospective clients;

  • referees and verification contacts;

  • background screening and verification providers;

  • psychometric, aptitude and skills assessment providers;

  • payroll, superannuation, timesheet, onboarding and workforce management providers;

  • IT, cloud hosting, analytics, CRM, ATS, and software providers;

  • legal, accounting, insurance, finance and professional advisers;

  • regulators, courts, tribunals, law enforcement bodies and government agencies;

  • workers compensation insurers, brokers and rehabilitation providers;

  • outsourcing and administrative support providers;

  • marketing, event and communications providers; and

  • any other party where you have consented or where disclosure is otherwise lawful.

We may also disclose personal information in connection with a business restructure, merger, acquisition, divestment, financing transaction, due diligence processor sale of assets, subject to appropriate confidentiality and legal safeguards.

10. APPLICANT TRACKING SYSTEMS, JOBADDER,&CLIENT SYSTEMS

Sharp & Carter uses applicant tracking systems, databases, customer relationship management tools, workflow tools and related recruitment technologies to manage candidate, client and assignment information.

This may include JobAdder and other applicant tracking system (ATS) or recruitment software providers used by Sharp & Carter or our clients.

Accordingly, personal information may be:

  • collected through online application forms, portals or integrations powered by JobAdder or other ATS providers;

  • stored in our ATS and related databases;

  • searched, categorised, matched and processed within those systems;

  • shared with client ATS platforms or hiring systems where reasonably necessary for a recruitment process;

  • incorporated into candidate profiles, client submissions, workflows and recruitment records; and

  • hosted on infrastructure controlled by those providers, including infrastructure located outside Australia.

Where we use JobAdder or another ATS, we expect that provider to handle personal information in accordance with applicable contractual commitments, privacy obligations and security requirements. However, the provider’s own privacy practices may also apply to the handling of information within its platform environment.

Where a client requires candidate information to be uploaded to or processed in a client-owned ATS or recruitment system, we may disclose relevant candidate information to that system for the purposes of progressing the recruitment process, facilitating hiring decisions, maintaining hiring records or meeting client compliance requirements.

11. ARTIFICIAL INTELLIGENCE, AUTOMATION AND TECHNOLOGY-ASSISTED PROCESSING

Sharp & Carter may use artificial intelligence, machine learning, automation and other technology-assisted tools to support aspects of our operations.

These tools may be used for purposes such as:

  • resume parsing and information extraction;

  • classification, tagging and organisation of candidate data;

  • search, matching and ranking support;

  • generation of draft summaries, notes, shortlists, advertisements, communications or interview guides;

  • transcription and summarisation of calls, interviews or meetings;

  • quality assurance and workflow automation;

  • fraud detection, cyber security monitoring and anomaly detection;

  • website personalisation, advertising optimisation and campaign analytics; and

  • data enrichment, trend analysis and operational reporting.

Where we use these tools, they are intended to support, not replace, human judgment.

Sharp & Carter’s position is that:

  • final decisions about candidate suitability, presentation, shortlisting, hiring recommendations, assignment management and employment-related action are made by appropriately authorised human decision-makers;

  • AI-generated or automated outputs may be reviewed, tested, verified or supplemented by consultants, managers, pay roll or compliance teams before action is taken;

  • sensitive information is not intentionally used in AI-enabled processes except where lawful, necessary and appropriately governed;

  • AI tools must be used in a manner consistent with our confidentiality, privacy, legal, cyber security and operational governance requirements; and

  • we may impose internal controls on prompts, inputs, outputs, review requirements, access permissions, retention settings and approved use cases.

Because AI and automated tools may assist with internal processing, candidate information and related content may be processed by approved technology providers subject to contractual and governance controls.

12. DIRECT MARKETING

We may use personal information to send direct marketing communications about our services, opportunities, events, reports, salary guides, market updates, promotions and related content where permitted by law.

Depending on the circumstances, this may include communication by:

  • email;

  • SMS;

  • phone;

  • social media or digital platforms;

  • online advertising;

  • post; or

  • other electronic channels.

We may market to candidates, clients, prospective clients, contractors and other contacts where:

  • they have consented;

  • they would reasonably expect us to do so; or

  • we are otherwise permitted by law.

We do not use sensitive information for direct marketing unless permitted by law and, where required, with consent.

You can opt out of direct marketing communications at any time by:

  • using the unsubscribe facility in the communication;

  • adjusting your preferences where available; or

  • contacting us using the details in this Privacy Policy.

We will action opt-out requests within a reasonable time and at no cost, except for any usual costs of transmitting the request.

13. WEBSITE ANALYTICS, COOKIES, TRACKING PIXELS AND WEBSITE BEHAVIOUR TRACKING

13.1 Google Analytics & Analytics Tools

We may use Google Analytics and other analytics services to understand how users interact with our websites, portals, landing pages, emails and digital content.

These tools may collect information such as:

  • IP address;

  • browser and device information;

  • operating system;

  • approximate location data;

  • pages viewed;

  • navigation paths;

  • time spent on pages;

  • referring pages or campaigns;

  • interactions with forms, content and site features; and

  • conversion and engagement metrics.

This helps us analyse website behaviour, maintain and improve our digital properties, understand user preferences, improve recruitment and marketing performance, and optimise the user experience.

13.2 Cookies

Our websites may use cookies and similar technologies to recognise your browser or device and remember information about your visit.

Cookies may be used to:

  • support site functionality;

  • keep you logged in where relevant;

  • remember preferences;

  • understand traffic and usage patterns;

  • personalise content;

  • measure campaign performance; and

  • support advertising and remarketing.

You can usually manage cookies through your browser settings. If you disable cookies, some features or functionality of our website may be limited.

13.3 Tracking Pixels & Advertising Technologies

We may use tracking pixels, tags and related advertising technologies in our websites, emails and digital campaigns. These technologies may allow us and our advertising or platform partners to:

  • understand whether emails are opened or links are clicked;

  • measure the effectiveness of digital campaigns;

  • deliver personalised or targeted advertising;

  • show relevant content on third-party websites or platforms;

  • understand audience engagement; and

  • limit or manage repeated ad exposure.

13.4 Website Behaviour Tracking & Personalisation

We may analyse website behaviour and interaction data to understand how individuals use our digital channels, which content is most relevant, and how users move through recruitment or enquiry journeys.

This may include the use of session data, page interaction data, form completion behaviour, campaign attribution, segmentation and audience analytics to improve our website, user experience, candidate attraction, client engagementand digital communications.

14. OVERSEAS DISCLOSURE AND CROSS-BORDER DATA HANDLING

Some of our service providers, technology platforms, software vendors, data hosting providers and analytics or marketing providers may be located outside Australia or may store or process information overseas.

This may include providers located in countries such as the United States, the United Kingdom, countries in the European Economic Area and other jurisdictions in which our providers operate.

As a result, your personal information may be disclosed to, stored in or accessed from overseas locations in connection with:

  • cloud hosting;

  • applicant tracking systems;

  • customer relationship management systems;

  • payroll or workforce platforms;

  • analytics or advertising platforms;

  • communication and collaboration tools;

  • background screening or verification tools; and

  • other business systems used to support our operations.

Where we disclose personal information overseas, we take reasonable steps to ensure that the overseas recipient handles the information in a manner consistent with applicable privacy obligations, including through contractual protections, due diligence, governance requirements, security controls and vendor management measures.

However, privacy laws in other countries may differ from Australian laws, and in some cases overseas recipients may be subject to lawful foreign access requests.

15. DATA QUALITY

We take reasonable steps to ensure the personal information we collect, use and disclose is accurate, up to date, complete and relevant having regard to the purpose of use or disclosure.

Because recruitment and labour hire information can change frequently, we encourage you to tell us promptly if your details change, including your contact details, availability, role preferences, qualifications, licences, working rights or any other relevant information.

We may also update records based on later interactions, referee feedback, compliance checks, assignment history, client feedback or other information lawfully obtained.

16. HOW WE STORE AND PROTECT PERSONAL INFORMATION

We hold personal information in electronic and, in some cases, hard copy form.

Information may be stored in:

  • applicant tracking systems and recruitment databases;

  • payroll, onboarding and workforce systems;

  • CRM platforms;

  • cloud storage environments;

  • email systems and collaboration tools;

  • document management systems;

  • secure network drives;

  • laptops, mobile devices and portable equipment; and

  • physical files and secure storage facilities.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure.

These steps may include:

  • access controls and role-based permissions;

  • password requirements and authentication controls;

  • multi-factor authentication;

  • single sign-on controls where implemented;

  • encryption in transit and, where appropriate, at rest;

  • endpoint protection and security monitoring;

  • logging, audit trails and activity monitoring;

  • vendor due diligence and contractual security obligations;

  • confidentiality obligations for staff, contractors and suppliers;

  • physical access controls for offices and records;

  • secure disposal, deletion and destruction procedures; and

  • cyber security, incident response and business continuity measures.

No method of transmission over the internet, and no method of electronic storage, is completely secure. While we take reasonable steps to protect information, we cannot guarantee absolute security.

17. DATA BREACHES AND CYBER SECURITY INCIDENTS

If we become aware of a suspected or actual data breach or cyber security incident involving personal information, we may investigate, contain, assess and remediate the incident in accordance with our internal incident response processes and legal obligations.

Where required under the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of an eligible data breach.

Depending on the circumstances, we may also notify clients, insurers, law enforcement bodies, regulators, technology providers or other affected parties where reasonably necessary or legally required.

Where applicable to us, and if triggered by the relevant legislation, cyber extortion or ransomware payment reporting obligations may also apply.

18. HOW LONG DO WE KEEP PERSONAL INFORMATION?

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, for related operational purposes, and to meet legal, regulatory, contractual, insurance, dispute resolution, audit and record-keeping obligations.

Retention periods may vary depending on the type of information and the relationship involved. For example, we may retain information for periods necessary to:

  • maintain candidate databases and talent pools;

  • manage repeat placement and future opportunity processes;

  • comply with employment, payroll, taxation, superannuation and workplacelaws;

  • respond to legal claims, complaints or audits;

  • maintain recruitment process integrity and records; and

  • meet client or contractual requirements.

When personal information is no longerrequired, we will take reasonable steps to destroy it or de-identifyit, unless we arerequiredorpermittedby law toretainit.

19. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

You may request access to the personal information we hold about you, and you may request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

We will respond to requests within a reasonable period and generally within30 days.

We may need to verify your identity before processing a request.

We may refuse access or correction in some circumstances permitted by law, including where giving access would:

  • unreasonably affect the privacy of another person;

  • reveal confidential evaluative material generated in connection with a commercially sensitive decision-making process, including confidential reference material;

  • prejudice legal proceedings or negotiations;

  • be unlawful; or

  • otherwise fall within a permitted exception.

If we refuse a request, we will provide written reasons to the extent required by law.

If we have previously disclosed personal information that has been corrected, and you ask us to notify third parties of the correction, we will take reasonable steps to do so where practicable and lawful.

20. ANONYMITY & PSEUDONYMITY

Where lawful and practicable, individuals may interact with us anonymously or using a pseudonym.

However, in many cases this will not be practical because recruitment, labour hire, payroll, compliance, right to work, identity verification, employment and client servicing processes require us to know who you are.

21. THIRD-PARTY WEBSITES & EXTERNAL PLATFORMS

Our websites, communications and social media channels may contain links to third-party websites or platforms.

We are not responsible for the privacy practices, content or security of those third-party websites or platforms. You should review their privacy policies separately before providing personal information to them.

22. CHILDREN & MINORS

Sharp & Carter does not knowingly collect personal information from children for recruitment or labour hire purposes unless lawful and reasonably necessary in the circumstances.

If we become aware that we have collected personal information from a child in circumstances where we should not have done so, we will take reasonable steps to delete or de-identify the information, subject to legal obligations.

23. COMPLAINTS

If you believe we have mishandled your personal information or breached the Privacy Act 1988 (Cth), you may make a complaint to us.

Complaints should be sent to:

Privacy Officer
Sharp & Carter
Email:privacy@sharpandcarter.com.au

Please provide sufficient detail so that we can understand and investigate your complaint.

We may ask you to verify your identity and provide further information.

We will investigate your complaint and respond within a reasonable period,generally within30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

24. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in law, regulation, technology, business practices, services, risksettingsor privacy requirements.

The latest version will be made available on our website.

Whereappropriate, we may also provideadditionalnotice of material changes.

25. HOW TO CONTACT US

If you have any questions about this Privacy Policy, want to access or correct your personal information, want to opt out of marketing, or wish to make a privacy complaint, please contact:

Privacy Officer
Sharp & Carter
Email:privacy@sharpandcarter.com.au

APPENDIX 1 – SHARP & CARTER ENTITIES

Sharp & Carter Pty Ltd ATF The Sharp & Carter Unit Trust ABN 60 939 579 224

Sharp & Carter Finance and Accounting Pty Ltd ATF The S & C Finance and Accounting Unit Trust ABN 34 144 764 231

Sharp & Carter Accounting Clerical Pty Ltd ATF The S & C Accounting Clerical Unit Trust ABN 39 570 183 662

Sharp & Carter VIC Sales Pty Ltd ATF The S & C VIC Sales Unit Trust ABN 94 204 898 743

Sharp & Carter VIC Marketing Pty Ltd ATF The S & C VIC Marketing Unit Trust ABN 57 172 622 437

Sharp & Carter Management Consulting Pty Ltd ATF The S&C Management Consulting Unit Trust ABN 77 924 364 546

Sharp & Carter Legal Pty Ltd ATF The S & C Legal Unit Trust ABN 17 447 406 933

Sharp & CarterSouth EastMelbourne Pty Ltd ATF The S & CSouth EastMelbourne Unit Trust ABN 78 732 660 986

Sharp & Carter South East Melbourne Accounting Clerical Pty Ltd ATF The S&C South East Melbourne Accounting Clerical Unit Trust ABN 86 494 095 832

Sharp & Carter Business Support Pty Ltd ATF The S & C Business Support Unit Trust ABN 44 253 812 103

Sharp & Carter Digital and Technology Pty Ltd ATF The S & C Digital and Technology Unit Trust ABN 65 318 212 186

Sharp & Carter Sydney Pty Ltd ATF The Sharp & Carter Sydney Unit Trust ABN 24 636 141 079

Sharp & Carter Sydney Accounting Clerical Pty Ltd ATF The Sharp & Carter Sydney Accounting Clerical Unit Trust ABN 30 296 062 310

Sharp & Carter North West Sydney Pty Ltd ATF The S&C North West Sydney Unit Trust ABN 58 523 411 809

Sharp & Carter North West Sydney Accounting Clerical Pty Ltd ATF The S&C North West Sydney Accounting Clerical Unit Trust ABN 35 929 301 286

Sharp & Carter NSW Sales & Marketing Pty Ltd ATF The S & C NSW Sales & Marketing Unit Trust ABN 30 992 830 482

Sharp & Carter NSW Technology, Projects and Digital Pty Ltd ATF The S&C NSW Technology, Projects and Digital Unit Trust ABN 96 526 803 817

Sharp & Carter Brisbane Executive Pty Ltd ATF The S&C Brisbane Executive Unit Trust ABN 51 401 738 394

Sharp & Carter Brisbane Professional HR Pty Ltd ATF The S&C Brisbane Professional HR Unit Trust ABN 99 532 031 641

Sharp & Carter Brisbane Sales & Marketing Pty Ltd ATF The S&C Brisbane Sales & Marketing Unit Trust ABN 54 906 818 806

Sharp & Carter Brisbane Finance & Accounting Pty Ltd ATF The S&C Brisbane Finance & Accounting Unit Trust ABN 56 640 893 568

Sharp & Carter Brisbane Accounting Clerical Pty Ltd ATF The S&C Brisbane Accounting Clerical Unit Trust ABN 89 672 135 967

Sharp & Carter Brisbane Technology, Projects and Digital Pty Ltd ATF The S&C Brisbane Technology,Projectsand Digital Unit Trust ABN 96 330 543 922

Sharp & Carter Sydney North Shore Pty Ltd ATF The Sharp & Carter Sydney North Shore Unit Trust ABN 56 324 190 194

Sharp & Carter Sydney North Shore Accounting Clerical Pty Ltd ATF The Sharp & Carter Sydney North Shore Accounting Clerical Unit Trust ABN 51 881 549 002

Sharp & Carter South West Sydney Pty Ltd ATF The S&C South West Sydney Unit Trust ABN 23 402 579 961

Sharp & Carter South West Sydney Accounting Clerical Pty Ltd ATF The S&C South West Sydney Accounting Clerical Unit Trust ABN 53 808 487 917

Sharp & Carter Supply Chain Pty Ltd ATF The S&C Supply Chain Unit Trust ABN 68 938 537 864

Sharp & Carter Perth Accounting Clerical Pty Ltd ATF The S&C Perth Accounting Clerical Unit Trust ABN 40 287 559 886

Sharp & Carter Perth Digital & Technology Pty Ltd ATF The S&C Perth Digital & Technology Unit Trust ABN 78 873 689 115

Sharp & Carter Perth Finance & Accounting Pty Ltd ATF The S&C Perth Finance & Accounting Unit Trust ABN 82 239 179 682

Sharp & Carter HR Victoria Pty Ltd ATF The S&C HR Victoria Unit Trust ABN 51 570 399 511

Sharp & Carter HR NSW Pty Ltd ATF The S&C HR NSW Unit Trust ABN 23 171 436 423

Sharp & Carter Procurement Pty Ltd ATF The S&C Procurement Unit Trust ABN 50 291 781 678

Sharp & Carter Operations & Manufacturing Pty Ltd ATF The S&C Operations & Manufacturing Unit Trust ABN 66 385 508 875

Sharp & Carter Engineering Pty Ltd ATF The S&C Engineering Unit Trust ABN 44 781 327 006

Sharp & Carter Technical & Quality Pty Ltd ATF The S&C Technical & Quality Unit Trust ABN 87 328 190 605

Sharp & Carter Western Sydney Business Support Pty Ltd ATF The S&C Western Sydney Business Support Unit Trust ABN 47 892 887 207

Sharp & Carter VIC Healthcare Pty Ltd ATF The S&C VIC Healthcare Unit Trust ABN 28 193 897 588

S&C NSW Supply Chain Pty Ltd ATF The S&C NSW Supply Chain Unit Trust ABN 27 930 076 198

S&C Sydney Business Support Pty Ltd ATF The S&C Sydney Business Support Unit Trust ABN 26 742 621 804

S&C Professional Services Pty Ltd ATF The S&C Professional Services Unit Trust ABN 80 104 312 529

S&C Western Sydney Sales Pty Ltd ATF The S&C Western Sydney Sales Unit Trust ABN 99 298 795 381

S&C Sydney Sales Pty Ltd ATF The S&C Sydney Sales Unit Trust ABN 12 406 462 140

Sharp & Carter NSW Technical & Quality Pty Ltd ATF The S&C NSW Technical & Quality Unit Trust ABN 45 289 173 041

Sharp & Carter NSW Operations & Manufacturing Pty Ltd ATF The S&C NSW Operations & Manufacturing Unit Trust ABN 15 699 459 155

Sharp & Carter NSW Engineering Pty Ltd ATF The S&C NSW Engineering Unit Trust ABN 13 565 431 335

Sharp & Carter NSW Legal Pty Ltd ATF The S&C NSW Legal Unit Trust ABN 64 962 037 836

Sharp & Carter Perth HR Pty Ltd ATF The S&C Perth HR Unit Trust ABN 52 440 905 549

Sharp & Carter QLD Healthcare Pty Ltd ATF The S&C QLD Healthcare Unit Trust ABN 62 484 873 318

Sharp & Carter Brisbane Business Support Pty Ltd ATF The S&C Brisbane Business Support Unit Trust ABN 92 848 707 665