Global Privacy Policy
Personal information is any information or opinion about you that identifies you or could reasonably identify you. This Privacy Policy explains what personal information the PWS Group collects, why we collect it, how we use and protect it, and what rights you have in relation to it. It addresses our clients, website visitors, suppliers, employees and job applicants.
UK clients should also refer to the PWS UK Client Privacy Addendum, which supplements this policy and sets out specific obligations and rights under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. UK staff (PWS employees, workers and contractors) should also refer to the PWS UK Staff Privacy Notice.
The PWS Group consists of:
- People Work Smart Pty Ltd (ABN 92 668 618 826) (“PWS Australia”) — an Australian company that provides offshore staffing and BPO services to clients in Australia, New Zealand, and the United States;
- People Work Smart (UK) Ltd (“PWS UK”) — a UK company that provides offshore staffing and BPO services to clients in the United Kingdom; and
- People Work Smart Services Philippines, Inc. (“PWS Philippines”) — a Philippine company that employs the Employees who carry out the work delivered to clients.
This policy applies to (1) our clients and their contacts, (2) our employees, (3) website visitors, (4) suppliers and (5) job applicants.
Collection of Personal Information
Depending on how you interact with us, we may collect identity and contact details, professional information, application materials, billing records, and technical data such as device and usage information. For website visitors we may collect information you submit when contacting us, booking a Discovery Call, or applying via Refari, plus analytics via cookies and similar technologies (see our Cookie Policy).
Why We Collect and Use Personal Information
We use personal information to manage client and supplier relationships, recruit and deploy teams, process employment and payroll, respond to enquiries, operate our websites, and meet legal obligations in Australia, New Zealand, the US, the UK, and the Philippines.
Who We Share Personal Information With
We may share information within the PWS Group and with service providers (for example hosting, CRM, payroll/HR platforms, Refari, and Wistia) under appropriate agreements, and where required by law. We do not sell, rent, or trade personal information.
Data We Process on Behalf of Clients (‘Client Data’)
While delivering services, our employees may access data you own or control. That data belongs to you. PWS acts on your instructions and does not use it for our own purposes except as you direct or as required by law.
Confidentiality
We require staff and contractors to protect confidential and personal information and to access it only as needed to perform their roles.
How Long We Keep Personal Information
We retain personal information only as long as needed for the purposes described in this policy, or as required by applicable law and contractual obligations.
How We Protect Personal Information
We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including access controls and secure systems for employment and service delivery.
Data Breach Response
If we become aware of a data breach that is likely to result in serious harm, we will assess the incident and notify affected individuals and regulators as required by applicable law.
Cookies
We use cookies and similar technologies as described in our Cookie Policy.
Your Rights
Depending on your location, you may have rights to access, correct, or delete personal information, or to object to certain processing. Contact us using the details below to exercise these rights.
Contacting Us and Making a Complaint
Privacy enquiries: privacy@peopleworksmart.com
Philippines DPO: dpo.ph@peopleworksmart.com
Privacy Regulators
You may also contact your local privacy regulator if you are not satisfied with our response. Relevant regulators include the Office of the Australian Information Commissioner (OAIC), the UK Information Commissioner’s Office (ICO), and the Philippine National Privacy Commission.
Changes to This Policy
We may update this policy from time to time. The version published on this website is the current policy.
UK Client Policy Addendum
About This Addendum
This addendum supplements the Global Privacy Policy for UK clients and explains how PWS UK acts as a controller or processor under UK GDPR.
Controller and Processor – What This Means
Where PWS UK determines the purposes and means of processing, it acts as a controller. Where it processes personal data solely on documented client instructions to deliver contracted services, it acts as a processor.
When PWS UK acts as Data Processor
As a processor, PWS UK processes Client Data only on the client’s instructions, implements appropriate security measures, and assists with data subject requests and breach notifications as required by contract and UK law.
Security Measures
PWS UK maintains technical and organisational measures appropriate to the risk, including access control, staff training, and secure environments for offshore delivery.