Plain-English Summary
We collect your personal information to provide the BowerNest service, match apprentices with employers, and improve the platform. We only collect what we need, and we protect it with strong security measures. You can ask to see or correct your information at any time. We will not share your information without your consent, except where required by law. If something goes wrong with your data, we will let you know. You can complain to us or to the Australian Information Commissioner if you are unhappy with how we handle your information.
1. Purpose
This Privacy Policy explains how BowerNest Australia Pty Ltd ("BowerNest", "we", "us", or "our") collects, holds, uses, and discloses personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"). This policy applies to all personal information collected through the BowerNest website, platform, and pilot program.
2. Definitions
| Term | Definition |
|---|---|
| Personal Information | Information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined in the Privacy Act 1988 (Cth) |
| Sensitive Information | A subset of personal information that includes information about an individual's racial or ethnic origin, health information, criminal record, and other categories specified in the Privacy Act 1988 (Cth) |
| APP | Australian Privacy Principles as set out in Schedule 1 of the Privacy Act 1988 (Cth) |
3. Information We Collect
BowerNest collects personal information that is reasonably necessary for, or directly related to, one or more of our functions or activities. The types of personal information we may collect include:
- Identity information: first name, last name, date of birth, and photographic identification (where required for verification purposes);
- Contact information: email address, phone number, postal address;
- Professional information: employer details, trade or occupation, apprenticeship status, training provider details, qualifications, and work history;
- Registration information: role type (apprentice, employer, educator, parent/guardian, RTO/TAFE, other), trade interests, and pilot program preferences;
- Technical information: IP address, browser type and version, device information, operating system, time zone setting, and general location data;
- Usage information: pages visited, features used, time spent on the Service, and interaction data; and
- Communication information: records of correspondence with BowerNest, feedback, and survey responses.
4. How We Collect Information
We collect personal information through the following means:
- directly from you, when you register for the pilot program, create an account, complete a form, or communicate with us;
- automatically, through cookies and similar technologies when you use our website (see our Cookie Policy for details); and
- from third parties, where you have consented to the disclosure of your information to us, or where we are otherwise authorised or required by law to collect information from third parties.
5. Purpose of Collection
We collect and use personal information for the following purposes:
- to provide, operate, and improve the Service;
- to facilitate participation in the BowerNest pilot program;
- to match apprentices with suitable employers and training opportunities;
- to track apprenticeship progress and training milestones;
- to communicate with you about the Service, including updates, notifications, and support;
- to comply with our legal obligations, including under the Privacy Act 1988 (Cth), Australian Consumer Law, and other applicable legislation;
- to protect the safety and wellbeing of users, including through safety and mental health support features;
- to conduct research and analysis to improve our services (using de-identified or aggregated data where possible); and
- to respond to enquiries, complaints, and feedback.
6. Disclosure of Personal Information
We may disclose your personal information to:
- our employees, contractors, and service providers who assist in operating the Service, subject to confidentiality obligations;
- participating employers, where you are an apprentice who has consented to share your profile for matching purposes;
- registered training organisations (RTOs) and TAFEs, where necessary to verify or track training progress, with your consent;
- cloud hosting and infrastructure providers who store data on our behalf;
- professional advisors, including legal, accounting, and auditing professionals;
- government agencies or regulators, where required or authorised by law; and
- any other party with your express consent.
7. Cross-Border Disclosure
BowerNest uses cloud infrastructure that may involve the storage or processing of data in locations outside Australia. Before disclosing personal information to an overseas recipient, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to the information, in accordance with APP 8. BowerNest is committed to data sovereignty principles and will prioritise the use of Australian-based data storage where feasible.
8. Data Quality and Security
In accordance with APP 10 and APP 11, BowerNest will take reasonable steps to:
- ensure that the personal information we collect, use, and disclose is accurate, up-to-date, complete, and relevant;
- protect personal information from misuse, interference, loss, and from unauthorised access, modification, or disclosure; and
- destroy or de-identify personal information that is no longer needed for any purpose for which it may be used or disclosed under the APPs, unless we are required by law to retain it.
Our security measures include encryption of data in transit and at rest, access controls, regular security assessments, and staff training. BowerNest is actively working towards alignment with SOC 2 and ISO 27001 frameworks. Our policies, procedures, platform architecture, and values are structured to meet these security and government-grade compliance standards, with formal certification planned as the platform matures.
9. Access and Correction
Under APP 12 and APP 13, you have the right to:
- request access to the personal information we hold about you; and
- request correction of any personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
To make an access or correction request, please contact us at [email protected]. We will respond to your request within a reasonable period (and in any event within 30 days). We will not charge you for making a request, but we may charge a reasonable fee for providing access if the request requires substantial effort.
10. Complaints
If you believe that BowerNest has breached the APPs or handled your personal information inappropriately, you may lodge a complaint with us at [email protected]. We will acknowledge your complaint within five business days and will investigate and respond 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.
11. Notifiable Data Breaches
BowerNest complies with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). In the event of an eligible data breach, we will notify affected individuals and the OAIC as required by law.
12. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and, where appropriate, by direct communication.
This policy is part of the BowerNest Legal Policy Framework (Version 1.0). If you have questions about this policy, please contact us at [email protected]. This document should be reviewed by qualified legal counsel before reliance.
