Privacy Policy
Effective date: 5 October 2026
Winnchester Consulting Pty Ltd (Winnchester, we, us or our) is committed to protecting personal information and handling it responsibly, transparently and securely.
Winnchester is a small business and may qualify for the small business exemption under the Privacy Act 1988 (Cth). Nevertheless, as a matter of good business practice, we seek to manage personal information consistently with the Australian Privacy Principles (APPs). Where the Privacy Act or another applicable privacy law applies to a particular activity, we will comply with the applicable legal requirements.
Where relevant to our activities, we may also consider applicable overseas privacy laws, including the UK General Data Protection Regulation and EU General Data Protection Regulation.
If you do not agree with this Policy, you should not provide personal information to us. Where information is required for us to provide a service or conduct a recruitment process, choosing not to provide it may affect our ability to assist you.
1. Who this Policy applies to
This Policy applies to personal information we handle about:
visitors to our website and other online services;
prospective, current and former clients, including their personnel;
candidates, prospective candidates and referees involved in recruitment-related services;
individuals involved in workplace investigations, employee relations, HR advisory or other consulting engagements;
attendees of our events, webinars and consultations;
suppliers, contractors and business partners; and
other individuals who communicate or interact with Winnchester.
Personal information relating to Winnchester's own employees may also be subject to applicable employee records exemptions and internal policies.
2. What personal information we collect
The information we collect depends on your relationship with Winnchester and the nature of your interaction with us.
It may include:
Identification and contact information: your name, job title, employer, address, email address, telephone number and similar contact information.
Recruitment and employment information: CVs and résumés, employment history, qualifications, licences, professional registrations, work rights, remuneration expectations, availability, career preferences, interview responses and notes, reference information, assessments, background-check results and other information relevant to assessing suitability for employment.
Client and consulting information: information required to provide HR, workplace relations, investigation, advisory, recruitment, project or other professional services.
Booking and transaction information: appointment history, services purchased, invoices, receipts and information associated with payment transactions. Payment card information may be processed directly by our payment providers rather than retained by Winnchester.
Sensitive information: where relevant and appropriate, this may include information concerning health or disability, workplace adjustments, racial or ethnic origin, professional or trade association membership, union membership, criminal history or other information classified as sensitive information under applicable law. We seek to collect sensitive information only where reasonably necessary and with consent or other appropriate legal authority.
Communications and interview information: emails, correspondence, interview responses, call and meeting notes, chat messages, transcripts, summaries, feedback and testimonials.
Website and technical information: IP address, browser or device information, pages viewed, usage information, cookies, analytics information and similar technical data.
We generally do not require Tax File Numbers, full payment-card details or other information that is unnecessary for our services. Where such information is provided inadvertently, we take reasonable steps to appropriately secure, delete or de-identify it when it is no longer required.
3. How we collect personal information
We may collect personal information:
directly from you when you contact us, apply for or express interest in a position, participate in an interview or recruitment process, complete a form or assessment, provide documents, attend a meeting, make a booking or otherwise communicate with us;
from our clients where information is necessary for us to perform services on their behalf;
from referees, background-screening providers and other third parties with appropriate authority or as otherwise permitted by law;
from recruitment platforms, professional networking platforms and publicly available sources, including platforms such as SEEK and LinkedIn;
through our website, online services, cookies, analytics tools and similar technologies; and
through technology used to assist with communications, interviews, meetings and professional services.
Where you provide personal information about another person, you should be authorised to provide that information and, where appropriate, make them aware that their information may be provided to Winnchester.
4. Recruitment candidates
If you apply for a position advertised or managed by Winnchester, express interest in an employment opportunity, respond to sourcing activity from Winnchester, or otherwise agree to participate in a recruitment process, we may collect and use information reasonably relevant to assessing your candidacy.
This may include information supplied directly by you, information obtained through interviews or assessments, publicly available professional information, and information obtained from third parties with your authority.
By applying for a position or agreeing to be considered for an opportunity, you authorise Winnchester to use information relevant to your candidacy for the recruitment process concerned and, where appropriate, to disclose relevant candidate information to the prospective employer or client for whom Winnchester is conducting the recruitment process.
We will not ordinarily provide your information to an unrelated prospective employer for a different employment opportunity without first obtaining your agreement or otherwise having an appropriate basis to do so.
Information disclosed to clients will generally be limited to information reasonably relevant to the recruitment process.
5. Live dictation, transcription and AI-assisted note-taking
Winnchester may use approved technology to assist us in creating accurate contemporaneous records of interviews, meetings, telephone calls and other business communications.
This may include:
speech-to-text or live dictation functionality;
automated transcription;
AI-assisted meeting or interview notes;
automated summarisation; and
tools that assist in organising or analysing information provided during a conversation.
Depending on the technology used, spoken content may be temporarily captured, transmitted or processed by a third-party service provider for the purpose of converting speech into text or preparing notes or summaries.
Winnchester does not ordinarily retain an audio or video recording of a recruitment interview or telephone screen unless we specifically advise the participants that recording will occur. Some transcription or AI-assisted technologies may temporarily process audio as part of producing a transcript even where no audio recording is retained by Winnchester.
Where we intentionally retain an audio or video recording, we will advise participants and obtain consent where required.
Transcripts, summaries and notes generated using these technologies may form part of our business or recruitment records and will be handled in accordance with this Policy.
We do not intentionally use candidate voice recordings to create biometric voice profiles for recruitment purposes.
6. How we use personal information
We may collect, use and disclose personal information to:
provide, administer and improve our HR, recruitment, workplace relations, investigation and advisory services;
assess candidates for employment opportunities;
undertake candidate sourcing, screening, interviewing, assessment and reference checking;
provide appropriate candidate information, recommendations and recruitment outcomes to clients;
verify identity, qualifications, licences, work rights or other relevant credentials;
arrange background screening where authorised;
communicate with clients, candidates, referees, suppliers and other stakeholders;
schedule appointments, meetings and services;
prepare reports, correspondence, records, templates, recommendations and other professional deliverables;
administer accounts, invoicing and payments;
maintain appropriate business records;
manage complaints, disputes, legal claims, insurance matters and business risk;
maintain the security and integrity of our systems;
improve our services, processes and website;
provide service updates and, where appropriate, marketing communications; and
comply with applicable legal and regulatory requirements.
We seek not to use personal information for purposes materially unrelated to the reason it was collected without an appropriate basis to do so.
7. Sensitive information
We recognise that recruitment, HR and workplace matters can involve sensitive information.
We seek to collect sensitive information only where:
it is reasonably necessary for the relevant purpose;
you have provided consent;
collection is required or authorised by law; or
another applicable legal exception applies.
Candidates are not generally required to volunteer information concerning protected or sensitive personal characteristics unless that information is reasonably relevant to the recruitment process, such as information required to arrange a reasonable workplace adjustment.
8. Disclosure of personal information
We may disclose personal information where reasonably necessary to:
Clients and prospective employers, including where Winnchester is conducting recruitment, HR, investigation or advisory work for that organisation.
Service providers supporting our business, which may include providers of:
Microsoft 365, email and productivity services;
cloud hosting and data storage;
recruitment and applicant-management platforms;
AI-assisted transcription, note-taking and productivity services;
scheduling and forms;
payment processing;
background screening and identity verification;
CRM systems;
analytics and website services;
cybersecurity and IT support; and
other technology reasonably required to deliver our services.
We may also disclose information to:
professional advisers, including legal advisers, accountants, auditors and insurers;
government agencies, regulators, courts, tribunals or law enforcement agencies where required or authorised;
parties involved in managing or responding to legal claims or disputes; and
a successor or assignee in connection with a genuine business restructure, acquisition or transfer, subject to appropriate confidentiality and privacy safeguards.
We seek to use reputable service providers and take reasonable steps appropriate to the circumstances to protect information disclosed to them.
9. Overseas processing and disclosure
Some of the technology and service providers used by Winnchester may store or process information outside Australia.
Depending on the service concerned, information may be processed in countries or regions including the United States, United Kingdom, New Zealand and European Union.
This may include cloud productivity services and AI-assisted transcription, note-taking or other technology platforms.
Where practicable, we consider the privacy and security arrangements of service providers before using them and take reasonable steps appropriate to the circumstances to safeguard personal information.
By providing personal information to Winnchester and using our services, you acknowledge that information may be processed using service providers located outside Australia as described in this Policy.
Where applicable law requires a particular form of consent or other safeguard for an overseas disclosure, we will take appropriate steps to comply with that requirement.
10. Automated and AI-assisted tools
Winnchester may use artificial intelligence and other automated technology to assist with administrative and professional tasks, including transcription, summarisation, drafting, document organisation and analysis.
We do not regard AI-generated output as a substitute for professional judgement. Where AI-assisted tools are used in recruitment or HR work, material decisions remain subject to appropriate human consideration.
We seek to avoid providing more personal information to an AI or technology provider than is reasonably necessary for the relevant task and select tools having regard to their security, privacy and data-handling arrangements.
We do not knowingly authorise third-party AI providers to use confidential candidate or client information to train publicly available AI models unless this has been specifically agreed and is appropriate in the circumstances.
11. Cookies and analytics
We use cookies, pixels and similar technologies to operate and improve our website, understand website usage, remember preferences, measure performance and support marketing activities.
These may include services such as Google Analytics, Microsoft Clarity and Meta technologies.
You may configure your browser to reject or restrict cookies. Doing so may affect some website functionality.
Where required, we may provide additional cookie notices or preference controls.
12. Direct marketing
We may send information about Winnchester's services, events, resources or other matters that we reasonably believe may be relevant to you where permitted.
You may opt out of direct marketing communications at any time by using an unsubscribe facility provided in the communication or contacting us at admin@winnchester.com.au.
Opting out of marketing will not prevent us from sending administrative or service-related communications where required.
13. Security
We take reasonable steps appropriate to the nature of the information we hold to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.
Measures may include:
access controls;
multi-factor authentication;
encryption in transit;
secure cloud services;
appropriate device and account security;
confidentiality requirements; and
limiting access to information to people who reasonably require it.
No electronic system or method of transmission can be guaranteed to be completely secure.
If a data breach occurs, we will assess and respond to it having regard to the nature of the information and applicable legal obligations. Where the Privacy Act and Notifiable Data Breaches scheme apply to the relevant circumstances, we will comply with applicable notification requirements.
14. Retention and deletion
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, our legitimate business requirements and any applicable legal, contractual, insurance or regulatory obligations.
Retention periods vary depending on the type of information concerned.
Certain financial, corporate and client records may generally be retained for up to seven years or another period required by law.
Candidate and recruitment records may be retained for a period appropriate to the relevant recruitment engagement, potential disputes, client requirements and legitimate future recruitment purposes. Where we wish to retain candidate information for materially different future opportunities, we may seek further agreement where appropriate.
When information is no longer reasonably required, we take reasonable steps to securely destroy or de-identify it, subject to technical, legal and record-keeping requirements.
15. Access and correction
You may contact us if you wish to:
ask what personal information Winnchester holds about you;
request access to information we hold;
ask us to correct information you believe is inaccurate, incomplete or out of date; or
raise a concern about the way your information has been handled.
We may need to verify your identity before responding to a request.
There may be circumstances in which access cannot reasonably or lawfully be provided, including where access would unreasonably affect another person's privacy, reveal confidential information relating to another person, prejudice an investigation or legal proceeding, or where another legal restriction applies.
Where appropriate, we will explain why access has not been provided.
16. Information handled on behalf of clients
Some personal information is handled by Winnchester in the course of providing services to another organisation.
For example, a client may engage Winnchester to undertake recruitment, workplace investigations, HR advisory work or another people-related project.
In those circumstances:
information may have been collected by the client before being provided to Winnchester;
Winnchester may collect additional information to perform the engagement;
the client may have separate privacy obligations and policies; and
requests concerning information may sometimes need to be addressed jointly with, or referred to, the relevant client.
We expect clients to have appropriate authority to provide personal information to us and will assist appropriately with privacy-related enquiries.
17. Third-party websites and services
Our website and communications may contain links to third-party websites, platforms or services.
Those third parties operate independently from Winnchester and may have their own privacy practices and terms.
We are not responsible for the privacy practices of independent third parties and encourage you to review their policies where relevant.
18. Children
Winnchester's services are primarily intended for business, employment and professional purposes.
We do not intentionally collect personal information from children under 16 through our general website or services except where this is legitimately required in connection with a client engagement and appropriate safeguards are in place.
19. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices or applicable law.
The current version will be published on our website with its effective date.
Material changes to the way we handle personal information may also be communicated through other appropriate means.
20. Questions and complaints
Questions, requests or complaints concerning privacy may be directed to:
Privacy Officer
Winnchester Consulting Pty Ltd
Email: admin@winnchester.com.au
We aim to acknowledge privacy complaints within 10 business days and to resolve them within 30 days where reasonably practicable.
Where the Privacy Act 1988 (Cth) applies to the relevant matter and you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).
Further information is available from the OAIC.