BLACKFYRE GLOBAL (AUSTRALIA) PTY LTD ABN 70 640 206 622 | ACN 640 206 622 Effective Date: 9 October 2026
1. PURPOSE AND APPLICATION
1.1 Blackfyre Global (Australia) Pty Ltd (ACN 640 206 622) (“Blackfyre Global”, “Blackfyre”, “we”, “us” or “our”) is committed to protecting the privacy, confidentiality and security of personal information collected, held, used and disclosed in the course of its business operations.
1.2 Blackfyre Global manages personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (“APPs”) and any other applicable Commonwealth, State or Territory privacy legislation.
1.3 This Privacy Policy applies to personal information handled by Blackfyre Global in connection with:
(i) its websites, online platforms and digital services; (ii) recruitment, employment, labour hire and workforce management activities; (iii) healthcare, professional staffing and other business services; (iv) social media advertising, digital campaigns, registrations and expressions of interest; (v) employment, contractor, supplier and client relationships; and (vi) any other activities undertaken during Blackfyre Global’s business operations.
1.4 This Privacy Policy explains how personal information is collected, managed, used, disclosed, secured and retained, together with the rights available to individuals in relation to their personal information.
2. COLLECTION OF PERSONAL INFORMATION
2.1 Blackfyre Global collects personal information reasonably necessary for its business functions, the provision of its services and compliance with applicable legal and contractual obligations.
2.2 Depending on the nature of an individual’s engagement with Blackfyre Global, information collected may include:
(i) personal identification and contact details, including names, addresses, telephone numbers, email addresses and dates of birth; (ii) employment history, curriculum vitae, qualifications, professional registrations, licences, certifications, competencies and references; (iii) employment preferences, availability, preferred locations, job applications and placement requirements; (iv) professional compliance records, including registration checks, police checks, working with children clearances and relevant training documentation; (v) employment and contractual records, including agreements, rosters, shift allocations, timesheets, remuneration and placement history; (vi) financial and payroll information, including banking details, tax file numbers, superannuation details, allowances and reimbursement records; (vii) health information and other sensitive information where reasonably necessary and collected with consent or another lawful authority; and (viii) information relating to website interactions, online enquiries, communication preferences and digital engagement.
2.3 Blackfyre Global will endeavour to limit the collection of personal information to that which is reasonably necessary for the relevant purpose.
2.4 Where reasonable and practicable, individuals may communicate with Blackfyre Global anonymously or using a pseudonym. Identification may, however, be required to facilitate recruitment, employment, placement, payroll or other services.
3. METHODS OF COLLECTION
3.1 Blackfyre Global may collect personal information directly from individuals through:
(i) website enquiries, online forms and registrations;
(ii) recruitment advertisements, job applications and expressions of interest;
(iii) social media platforms, advertising campaigns and lead-generation activities;
(iv) electronic recruitment, onboarding and workforce management systems;
(v) email, telephone, SMS, online messaging and other direct communications;
(vi) employment, contractor and commercial agreements; and
(vii) compliance, credentialing, payroll and administrative documentation.
3.2 Where permitted by law, Blackfyre Global may also obtain relevant personal information from third parties, including referees, previous employers, professional registration bodies, clients, recruitment partners and other authorised sources.
3.3 Where required by applicable privacy legislation, Blackfyre Global will provide individuals with appropriate information about the collection of their personal information at or before the time of collection, or as soon as practicable thereafter.
4. USE OF PERSONAL INFORMATION
4.1 Blackfyre Global may use personal information for purposes reasonably connected with its business operations, including:
(i) responding to enquiries, registrations and expressions of interest;
(ii) assessing suitability for employment, contracting or placement opportunities;
(iii) identifying and communicating relevant employment or professional opportunities;
(iv) managing candidate profiles, recruitment processes and workforce requirements;
(v) verifying qualifications, professional registration, competencies, references and compliance requirements;
(vi) facilitating introductions, applications and placements with prospective employers, healthcare facilities and other clients;
(vii) managing employment contracts, onboarding, rostering, timesheets, payroll, superannuation and other employment entitlements;
(viii) coordinating travel, accommodation and related placement arrangements;
(ix) conducting recruitment communications, marketing activities and promotional campaigns in accordance with applicable laws;
(x) managing client relationships, business administration and service delivery;
(xi) maintaining accurate and secure business records; and
(xii) complying with legal, regulatory, contractual and reporting obligations.
4.2 Personal information may also be used for a related secondary purpose where the individual would reasonably expect such use, where consent has been obtained or where otherwise permitted by law.
4.3 Blackfyre Global will not use personal information for purposes inconsistent with applicable privacy legislation.
5. RECRUITMENT, REGISTRATIONS AND EMPLOYMENT PLACEMENTS
5.1 Where an individual applies for employment, registers as a candidate, responds to a recruitment advertisement or otherwise expresses interest in professional opportunities, Blackfyre Global may collect, use and retain relevant personal information to facilitate recruitment and placement activities.
5.2 Such information may be used to:
(i) assess qualifications, experience, availability and suitability;
(ii) match individuals with current or future employment and placement opportunities;
(iii) communicate regarding applications, interviews, employment conditions and placement requirements;
(iv) establish and maintain candidate records within authorised business systems;
(v) verify credentials and satisfy relevant employment or professional requirements; and
(vi) facilitate engagement with prospective employers, clients and healthcare facilities.
5.3 By voluntarily submitting a recruitment enquiry, application, registration or expression of interest, an individual acknowledges that Blackfyre Global may collect and use the information provided for the recruitment purposes disclosed at the time of collection and described in this Privacy Policy.
5.4 Where appropriate, and subject to any necessary authorisation, relevant professional information may be disclosed to prospective employers, clients, healthcare facilities or other parties directly involved in assessing or facilitating a potential placement.
5.5 Candidate information may be retained for consideration for future opportunities where reasonably necessary and permitted by law, subject to applicable retention requirements and communication preferences.
5.6 Additional information, declarations or consents may be required before an individual commences employment, completes onboarding or undertakes a placement.
6. SOCIAL MEDIA, ONLINE REGISTRATIONS AND DIGITAL CAMPAIGNS
6.1 Blackfyre Global may collect personal information submitted voluntarily through social media advertisements, online campaigns, website forms, digital registrations and expressions of interest.
6.2 Information collected through these channels may be transferred to, stored within or processed through authorised third-party business systems for the purposes of:
(i) managing enquiries and expressions of interest;
(ii) assessing suitability for employment or professional opportunities;
(iii) contacting individuals about the opportunities or services in which they have expressed interest;
(iv) maintaining recruitment and candidate records;
(v) facilitating registration, onboarding and placement activities; and
(vi) communicating other relevant opportunities where permitted by law.
6.3 Submission of personal information through a campaign or online registration constitutes an acknowledgement of the relevant collection notice and this Privacy Policy where these have been made available to the individual.
6.4 Where separate consent is required for promotional or direct marketing communications, Blackfyre Global will obtain or otherwise establish an appropriate basis for those communications in accordance with applicable laws.
7. THIRD-PARTY SERVICE PROVIDERS
7.1 Blackfyre Global engages third-party service providers to support its operational, administrative, professional and technological requirements.
7.2 Such service providers may perform functions relating to:
(i) recruitment, candidate registration and employment management;
(ii) job applications, workforce scheduling and placement administration;
(iii) payroll, superannuation, taxation and financial processing;
(iv) professional credentialing, compliance and verification;
(v) electronic communications, advertising and marketing administration;
(vi) website hosting, information technology, data storage and security;
(vii) travel, accommodation and logistics; and
(viii) other services reasonably necessary for business operations.
7.3 Personal information may be disclosed to or processed by these service providers where reasonably necessary for the performance of their services or otherwise permitted by law.
7.4 Blackfyre Global takes reasonable steps to ensure that third-party arrangements incorporate appropriate confidentiality, security, access and information-handling safeguards.
7.5 Blackfyre Global does not sell personal information to third parties.
8. DISCLOSURE OF PERSONAL INFORMATION
8.1 Blackfyre Global may disclose personal information where reasonably necessary to provide its services, fulfil its contractual obligations or comply with applicable laws.
8.2 Recipients may include:
(i) prospective employers, clients and host organisations;
(ii) hospitals, healthcare facilities, government health services and other placement providers;
(iii) authorised recruitment, employment and workforce management service providers;
(iv) payroll, banking, taxation and superannuation providers;
(v) professional registration, credentialing and compliance bodies;
(vi) travel, accommodation and associated service providers;
(vii) professional advisers, including legal, accounting and auditing advisers; and
(viii) regulatory authorities, government agencies and other persons where disclosure is required or authorised by law.
8.3 Blackfyre Global will take reasonable steps to ensure that disclosures are limited to information relevant to the applicable purpose.
8.4 Where required by law, Blackfyre Global will obtain the individual’s consent before disclosing sensitive information or information for purposes outside those otherwise authorised.
9. SENSITIVE INFORMATION
9.1 Certain business activities, particularly recruitment and employment in regulated industries, may require Blackfyre Global to collect sensitive information.
9.2 This may include:
(i) health or medical information relevant to specific employment or workplace requirements;
(ii) criminal history information required for relevant employment checks; and
(iii) other information classified as sensitive information under applicable privacy legislation.
9.3 Sensitive information will only be collected where reasonably necessary and with the individual’s consent or where collection is otherwise permitted by law.
9.4 Blackfyre Global will take reasonable steps to restrict access to sensitive information and ensure its use and disclosure are limited to authorised purposes.
10. MARKETING AND COMMUNICATIONS
10.1 Blackfyre Global may communicate with individuals regarding employment opportunities, professional services, recruitment activities, industry updates and business-related information.
10.2 Communications may be delivered through email, telephone, SMS, digital platforms or other appropriate channels.
10.3 Direct marketing communications will be conducted in accordance with applicable privacy and electronic marketing laws, including the Spam Act 2003 (Cth).
10.4 Where consent is required, Blackfyre Global will obtain or rely upon a legally recognised form of consent and will maintain appropriate communication preferences and unsubscribe mechanisms.
10.5 Individuals may request to cease receiving promotional communications at any time.
10.6 An individual’s decision to unsubscribe from marketing communications does not prevent Blackfyre Global from communicating with that individual where reasonably necessary in connection with an active application, contractual relationship, employment arrangement, placement, payroll obligation or other lawful operational requirement.
11. OVERSEAS ACCESS AND DISCLOSURE
11.1 Blackfyre Global may engage authorised personnel, contractors and third-party service providers located outside Australia to support its business operations.
11.2 Accordingly, personal information may be accessed, stored, processed or disclosed outside Australia, depending on the nature of the applicable services and arrangements.
11.3 Where personal information is disclosed to an overseas recipient, Blackfyre Global will take reasonable steps to comply with applicable Australian privacy requirements, including appropriate contractual, technical and organisational safeguards.
11.4 The countries in which overseas recipients are likely to be located will be identified where practicable and required by law.
11.5 Overseas access and disclosure arrangements will be reviewed periodically to ensure this Privacy Policy accurately reflects Blackfyre Global’s information-handling practices.
12. SECURITY OF PERSONAL INFORMATION
12.1 Blackfyre Global takes reasonable steps to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.
12.2 Depending on the nature of the information, safeguards may include:
(i) secure information management and electronic storage systems;
(ii) restricted access based on authorised roles and business requirements;
(iii) authentication, account management and access controls;
(iv) confidentiality obligations for employees, contractors and service providers;
(v) appropriate contractual and technical safeguards for third-party systems; and
(vi) internal procedures for managing information security and potential data breaches.
12.3 Blackfyre Global will assess and respond to actual or suspected data breaches in accordance with applicable legal obligations, including the Notifiable Data Breaches scheme where relevant.
12.4 Although reasonable precautions are taken, no electronic transmission or information storage system can be guaranteed to be entirely free from security risks.
13. RETENTION AND DISPOSAL OF INFORMATION
13.1 Blackfyre Global retains personal information for as long as reasonably necessary for the purposes for which it was collected, or as required or authorised by law.
13.2 Retention requirements may vary according to:
(i) the nature of the information collected;
(ii) employment, recruitment and contractual obligations;
(iii) payroll, taxation, financial and regulatory requirements;
(iv) professional compliance and accreditation obligations; and
(v) legitimate business requirements permitted by law.
13.3 Where personal information is no longer required for any lawful purpose, Blackfyre Global will take reasonable steps to securely destroy or de-identify it in accordance with applicable privacy requirements.
14. WEBSITE COOKIES AND ANALYTICS
14.1 Blackfyre Global’s websites and digital platforms may use cookies, analytics technologies and similar tools to support website functionality, monitor performance and improve user experience.
14.2 These technologies may be used to:
(i) analyse website traffic and visitor engagement;
(ii) improve website content and functionality;
(iii) assess the effectiveness of recruitment and advertising campaigns; and
(iv) support relevant digital advertising and promotional activities where permitted by law.
14.3 Information collected through these technologies may be processed by authorised third-party providers in accordance with applicable privacy requirements.
14.4 Individuals may manage available cookie and tracking preferences through their browser, device or other applicable privacy settings.
15. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
15.1 Individuals may request access to personal information held about them by Blackfyre Global in accordance with applicable privacy legislation.
15.2 Individuals may also request correction of personal information that is inaccurate, incomplete, out of date, irrelevant or misleading.
15.3 Requests may be made using the contact details provided in clause 18 of this Privacy Policy.
15.4 Blackfyre Global may take reasonable steps to verify the identity or authority of an individual making a request before providing access to personal information.
15.5 Blackfyre Global will respond to requests within a reasonable period and in accordance with applicable legal requirements.
15.6 Where access or correction is refused in circumstances permitted by law, Blackfyre Global will provide the reasons and any relevant complaint information as required.
16. WITHDRAWAL OF CONSENT AND COMMUNICATION PREFERENCES
16.1 Where Blackfyre Global relies upon an individual’s consent for a particular collection, use or disclosure of personal information, the individual may withdraw that consent, subject to applicable laws and any continuing legal or contractual obligations.
16.2 Individuals may request amendments to their communication preferences or withdraw consent to optional marketing communications at any time.
16.3 Withdrawal of consent may affect Blackfyre Global’s ability to provide certain services where the relevant information is necessary for recruitment, employment, compliance or placement purposes.
16.4 Requests concerning withdrawal of consent will be managed in accordance with applicable legal and contractual requirements.
17. AUTOMATED SYSTEMS AND DECISION-MAKING
17.1 Blackfyre Global may use electronic systems and technology to assist with business administration, information management, recruitment workflows and other operational processes.
17.2 Where computer programs are used to make, or perform functions substantially and directly related to making, decisions that could reasonably be expected to significantly affect an
individual’s rights or interests, Blackfyre Global will provide any disclosures required under applicable privacy legislation.
17.3 Where required by law, such disclosures will identify the relevant categories of decisions and personal information involved.
17.4 Blackfyre Global will review its automated processing and decision-making arrangements to ensure compliance with applicable privacy transparency requirements.
18. PRIVACY ENQUIRIES, ACCESS REQUESTS AND COMPLAINTS
18.1 Individuals may contact Blackfyre Global to:
(i) request access to personal information;
(ii) request correction of personal information;
(iii) update communication preferences;
(iv) enquire about the collection, use, disclosure or security of personal information; or
(v) make a complaint concerning an alleged interference with privacy.
18.2 Privacy enquiries and complaints may be directed to:
18.3 Blackfyre Global will acknowledge, assess and investigate privacy complaints as appropriate and respond within a reasonable period.
18.4 Where an individual is dissatisfied with the outcome of a privacy complaint, they may be entitled to lodge a complaint with the Office of the Australian Information Commissioner (“OAIC”).
18.5 Further information regarding privacy rights and complaint procedures is available at https://www.oaic.gov.au.
19. AMENDMENTS TO THIS PRIVACY POLICY
19.1 Blackfyre Global may amend this Privacy Policy from time to time to reflect changes in its business operations, services, information-handling practices, legal obligations or regulatory requirements.
19.2 Any amendments will be published on Blackfyre Global’s website together with the date of the most recent revision.
19.3 Individuals are encouraged to review the Privacy Policy periodically to remain informed about how their personal information is managed.
