Privacy Policy



Trak Recruiting Pty Ltd, Trak HR Consulting Pty Ltd and Scarlett Recruitment Pty Limited (also referred to as “Trak Group”, “we”, “our” or “us” in this policy) together consists of four divisions:

  1. Trak Recruiting: Recruitment of store based or multi-site positions, and all head office positions such as Buying, Planning, Accounting, Property, Marketing, VM, Ecommerce, etc.
  2. Trak Executive Search: Recruitment of CEO, ‘Heads of Roles’ across Stores, Merchandise, Marketing, IT, Accounting, Ecommerce, etc.
  3. Scarlett Recruitment: Recruitment for fashion and textile industries with a manufacturing and wholesale focus for roles such as Design, QC, Production, Supply Chain, Product Development, Sales and Account Management, etc.
  4. Trak HR Consulting: Provides outsourced HR support and strategy solutions as well as recruitment of HR related roles at all levels.



Trak Group is committed to protecting the privacy of personal information provided and/or collected in connection with doing business with any of our divisions, or visits to our websites.

This policy ensures compliance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (as amended) which regulates the handling of personal information about individuals.

This policy covers the collection, use, disclosure and storage of personal information, including any modification or correction of that information, and outlines how the Trak Group handles your personal information in accordance with the APPs.



This policy applies to individuals/external parties with whom the Trak Group does business, including candidates, clients, persons and visitors to our websites.


Policy Statement:

Trak Group aims to manage personal and sensitive information in accordance with the Privacy Act 1988 and Australian Privacy Principles (APPs), ensuring that:

  • Personal and sensitive information is collected fairly and lawfully for the purpose of the Trak Group divisions’ work.
  • Individuals are told why the Trak Group is collecting personal information, and to whom such information may be disclosed to.
  • All reasonable steps are taken to ensure the personal information collected is;
    • Accurate, current, relevant and complete
    • Not collected in an unreasonably or intrusive manner
    • Stored securely to prevent its loss or misuse.
  • Individuals are provided with access to personal information about them and (if applicable) given the opportunity to amend or correct that information in accordance with the APPs.
  • Information is used for a relevant purpose and is only used for another purpose under special circumstances, such as with an individual’s consent or unless authorised or required by law.
  • Information is only disclosed to others only under special circumstances, such as to trusted third parties, with the individual’s consent or unless authorised or required by law.



What is Personal Information?

Information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable (OAIC Definition).

As such, personal information includes, but is not limited to; contact details, work experience, qualifications, aptitude test results, the opinions of others about an individual’s work performance (whether true or not), e.g. references, work experience and qualifications, aptitude test results, incidents at the workplace, bank details, medical records and other information obtained or received by us in connection with possible and/or actual work placements.


What is Sensitive Information?

Sensitive information is a type of personal information on which the APPs place more stringent obligations on how it is to be handled. Sensitive information includes information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or a trade union, sexual preferences or practices, criminal records and health information. In most cases, in line with the Privacy Act, sensitive information can only be disclosed with the individual’s consent.


Collection of Personal/Sensitive Information

In the course of providing recruitment services or HR Consulting services, Trak Group may collect information about individuals, such as but not limited to names, contact details, skills, education, qualifications, languages spoken, professional association memberships or accreditations, employment history, past responsibilities, feedback/opinions, etc.

Personal/sensitive information (and any additional information provided to us) will be collected directly from individuals when they:

  • apply for a job
  • complete one of our application forms or complete an online registration
  • sign up for the newsletter/job alerts via our website
  • participate in an Entrance, Stay or Exit interview.

Personal/sensitive information may also be received indirectly, as part of the Trak Group providing its services, such as, but not limited to:

  • any reference about an individual
  • results of inquires we make from former employees, work colleagues, professional associations or registration bodies
  • results of any competency, medical test or background check. including criminal record checks
  • performance feedback about an individual
  • any complaint or other information from or about an individual in their current or previous workplace
  • any information on a workplace accident in which an individual was involved
  • information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which an individual was involved
  • information collected while undertaking HR Consulting projects and services. E.g. HR Audits/Exit interviews.

Where practicable, the purpose for which we collect personal information and the consequences of not providing it will be made clear at the time of collection.



The Trak Group websites include Trak Recruiting and Scarlett Recruitment websites. When visitors access our websites, the Trak Group may collect information about individuals when they:

  • contact us to make any enquiry, query or comment.
  • apply online for a job or general consideration with the Trak Group. Once submitted, an individual’s application will be sent directly to the relevant recruitment consultant who will review and advise whether they have been accepted for registration on our central database. This database, which includes relevant personal information, can be accessed by any of our recruitment consultants working in the Sydney or Melbourne offices. An individual’s application will constitute their express consent for us to use this information and process their application, carrying out reference checks and other related activities as may be required.
  • register or subscribe to our newsletter/job alerts.
  • participate in forums/blogs.

Website users who do not register can generally visit the websites without revealing who they are and without providing any specific personal information.

Trak Group gathers general information about all our website users collectively, such as what areas users frequently visit and what services users access the most. We only use such data anonymously and in aggregate form (that is, the information does not identify any one individual). This information helps us determine what is most beneficial for our users, and how we can continually improve the overall website experience for all.


Use and Disclosure of Personal Data

What will we use personal and sensitive information for?

The Trak Group holds, uses and discloses your personal and sensitive information for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy. We will not use or disclose an individual’s personal information for any other purpose other than which it is primarily held for, or that would be reasonably expected as related to relevant secondary purposes. Trak Group will only disclose information with your consent, unless authorised or required by law.

Trak Group will only generally use and disclose personal information for the following purposes, to:

  • establish and maintain relationships with website users, clients or candidates of the Trak Group.
  • provide recruitment or HR Consulting services as requested from the Trak Group.
  • answer inquiries in relation to providing services from persons to whom we may disclose personal information to (see below).
  • inform candidates of actual and possible work opportunities.
  • send candidate personal information, reports and other information to clients in order to apply for or be considered for jobs.
  • support career guidance and management for candidates.
  • assess ongoing performance and prospects or identify training needs for candidates.
  • conduct any test or assessment (including medical tests and assessments) that might be required.
  • create direct-market products and services, advise of news/industry updates, events, promotions/competitions, reports and other information. Where we do so, there will be an option to unsubscribe from such communications.
  • enable third parties that assist us to provide the services requested, such as psychometric evaluations or other skills tests.
  • be consistent with third parties policies who provide services to us such as IT and cloud storage.
  • manage any complaint, investigation or inquiry in which an individual is involved.
  • manage any insurance claim or proposal that requires disclosure of an individual’s personal or sensitive information.
  • undertake criminal or other background reference checks or as otherwise permitted by law.
  • enable research, development, business systems/infrastructure testing, and other business purposes to assist us in providing our services.


If individuals do not give us the information we seek, the Trak Group may be limited in its ability to:

  • find suitable candidates for clients
  • place candidates in work
  • provide effective Trak Group/HR Consulting services.


Who do we disclose personal and sensitive information to?

We may disclose personal and sensitive information for the purposes for which it is primarily held or as reasonably expected/ a related secondary purpose and we may only disclose information with your consent. We will take reasonable steps to ensure any contracted service provider complies with similar undertakings of the privacy and confidentiality and the privacy principles as that used by the Trak Group. Information may be disclosed to, but not limited to;

  • Potential and actual employers and clients of the Trak Group and trusted third parties
  • Referees
  • Trak Group employees and consultants
  • Trak Group insurers
  • Potential employers in Australia or overseas, regarding possible work placements or to assist us in providing our services
  • A professional association or registration body that has a legitimate interest in the disclosure of your personal and sensitive information
  • External providers of training as legally required
  • Background checking agencies – e.g. Nation Crime Check
  • Our contractors and suppliers – e.g. IT contractors/ database engineers/Cloud providers
  • Any person, regulatory or law enforcement authorities with a lawful entitlement to obtain the information.

We may also seek an individual’s consent to collect, hold, use or disclose your personal information for any other purpose not listed above.


Access and Amendment

Subject to some exceptions that are set out in the APPs individuals can gain access to the personal information that we hold. To request access to your personal information, you need to make a written request to our Privacy Coordinator (, verifying your identity and specifying what information you require. We will provide you with access to your personal information, if it is reasonable and practicable to do so unless we are legally obliged to refuse your request. We may charge a reasonable amount for providing access.

You may request that we correct personal information that we hold about you if you deem it to be inaccurate, incomplete, out-of-date, irrelevant or misleading. To request this you need to contact our Privacy Coordinator (

After notice from you and depending on circumstances, the Trak Group will take reasonable steps to correct or modify the relevant information. We may refuse your request to access, amend or delete your personal information in certain circumstances. If we do refuse your request, we will provide you with a reason for our decision and, in the case of amendments, we will place a note against your personal information, recording that you have disputed its accuracy. Requests to correct information errors will not be charged.

You may also request that the Trak Group stops using your information or contacting you. For example if at any time you would prefer to stop receiving newsletters and updates from us, please use the “unsubscribe” option included in the email or other material. We will comply with all requests as soon as is reasonably practicable.


Overseas Use and Disclosure

Geographically we focus on all major Australian cities as well as a number of regional locations. However, we also undertake assignments in New Zealand, Asia, Middle East, Europe and the UK. Therefore, with your permission we may transfer some information about you to countries other than your home country or a country other than the one in which the information was originally collected.

Whilst privacy practises and legislation may vary across different countries, we will take all reasonable steps to ensure that any information collected or shared about you is handled and protected in accordance with this Privacy Policy.


Storage, Security and Accuracy

Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or by any other electronic medium. We take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse, interference and loss, unauthorised access, modification or disclosure; holding personal information in a combination of secure computer storage facilities, cloud storage services, paper-based files and other records, using password protected electronic files, locked cabinets and physical work environment practices which restrict unauthorised personnel. In the case of computer based storage we maintain virus protection and security login practices.

The Trak Group will also take reasonable steps to keep this information accurate and up to date, by such methods as auditing candidates’ status. We recognise that information changes over time with changes of address and other personal circumstances. Please advise your consultant/Trak Group contact if your personal details change.


Retention of Personal and Sensitive Information

Personal and sensitive information is held until we consider it is no longer needed for any purpose for which it may be used or disclosed in connection with our recruitment or HR Consulting services. At that time we will remove any details that will identify individuals or we will securely destroy the records provided that it is lawful for us to do so. Generally, the following approach will be taken. However, the Trak Group reserves its right to use its discretion subject to specific circumstances, agreements or business needs;


For Recruitment Services

Following registration or job application, candidate details are generally kept on file within our internal database to enable us to provide our services and support your career, unless you request in writing that your details are not to be retained. The Trak Group will also conduct regular reviews of candidates on the central database and subject to activity retain or delete appropriate records. At any time candidates can request their details be removed or updated by contacting their consultant or our Privacy Coordinator ( Clients details will also be held on our internal database and regularly audited. Where no further useful purpose is determined for client or candidate personal information, the identifying elements (i.e. details that identify an individual) will be removed or securely destroyed provided that it is lawful for us to do so.


For Trak HR Consulting Services

Through providing Trak HR Consulting services we may collect individual’s personal and sensitive data. Such information is always collected with consent and treated confidentially, supported by a signed confidentiality agreement as required.

The retention of personal data will be discussed and agreed with clients and be subject to the ongoing/future relationship/work with that client. For example, agreements as to whether there will be an ongoing or future purpose to retaining the information.

However, where projects cease, generally personal data will have any identifying elements removed or securely destroyed provided that it is lawful for us to do so after 1 year.



The Trak Group privacy policy will be reviewed and updated from time to time.


Contact Us

For any queries or requests in line with the Trak Group’s Privacy Policy please contact our Privacy Coordinator:

Kerrie Connell

Phone: +61 9232 1678