Privacy policy

We are the Pacific Labour Facility, a project team dedicated to the Pacific Labour Scheme, acting under the legal entity Palladium International Pty Ltd ACN 010 020 201, and in this privacy policy, we, us or our. We have been appointed to manage the Pacific Labour Scheme as a managing contractor for the Department of Foreign Affairs and Trade (DFAT). The Pacific Labour Scheme aims to fill labour gaps across Australia’s towns, especially in regional and rural areas and provide workers in the Pacific new opportunities for work in Australia.

This privacy policy applies exclusively to the Pacific Labour Facility. If you would like to read Palladium’s full privacy policy, you can access it here.

We understand that protecting your personal information is important. This privacy policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our services, forms and website (Services).

Personal information

Administering the Pacific Labour Scheme

We may collect personal information about you, directly from you or from a third party, for the purpose of administering the Pacific Labour Scheme on behalf of DFAT. We may collect this via any forms you complete, whether online or offline, and any contact you initiate with us, such as via email. The types of personal information which we may collect in such circumstances include:

  • your name;
  • details of your role within your employer’s entity (for example, as a director or a key staff member);
  • details of your relationship to an entity submitting an application, where you are nominated as a referee;
  • your contact details, including email address, mailing address and/or telephone number;
  • details of whether you (for example, as the entity’s director or partner) have been in breach of or investigated by an Australian Government authority (for example, in relation to workplace laws, tax laws or criminal laws in connection with business dealings);
  • details of whether you (for example, as the entity’s director or partner) have been declared bankrupt or have been charged with a fraud/dishonesty offence;
  • details of the forms you have submitted; and
  • any enquiries you have submitted to us, and our response to you.

Sensitive information: Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Some of the above information is considered sensitive information as it may relate to your trade union membership, your membership of other professional associations or your criminal records.

How we handle sensitive information: Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including handling this information on behalf of DFAT as part of the Pacific Labour Scheme and disclosing this information to DFAT for the purposes of the Pacific Labour Scheme. Sensitive information may also be used or disclosed if required or authorised by law.

Our website

We also may collect personal information about you, directly from you or from a third party, for the purpose of delivering our website to you. The types of personal information which we may collect when delivering our website to you include:

  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; and
  • additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications from which you permit us to collect information.

Cookies: We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Web beacons: We may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Google Analytics: We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see or any other URL Google may use from time to time.

Other personal information

We may also collect any other personal information requested by us and/or provided by you or a third party.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access, use and benefit from our Services and any associated applications;
  • to contact and communicate with you about our Services and the Pacific Labour Scheme;
  • for our internal record keeping and administrative purposes;
  • for analytics, to operate and improve our Services and any associated applications;
  • to send you information about the Pacific Labour Scheme;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • if you have applied for employment with us; to consider your employment application.

Disclosure of personal information to third parties

We may disclose personal information to:

  • DFAT for the purpose of enabling them to administer the Pacific Labour Scheme;
  • third party service providers for the purpose of enabling them to assist us in providing our Services to you, including (without limitation) our website host (WordPress) IT service providers, data storage, web-hosting and server providers, maintenance or problem-solving providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities, for the purpose of providing our Services;
  • our existing or potential agents or business partners, for the purpose of providing our Services;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
  • third parties to collect and process data via our online Services, such as Google Analytics. This may include parties that store data outside of Australia.

Disclosure outside of Australia: By providing us with personal information, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to take reasonable steps or ensure that overseas recipients handle that personal information in compliance with the Australian Privacy Principles. You acknowledge that some overseas third parties may not be regulated by the Australian Privacy Principles and if an overseas third party engages in any act or practice that contravenes the Australian Privacy Principles, we would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act. The overseas entity may be compelled by law to disclose this information to a third party.

Your rights and controlling your personal information

Your choice: Please read this privacy policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable, such as where you make an initial enquiry with us via email, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. You may also unsubscribe from our e-mail database or opt-out of marketing communications by using the opt-out facilities provided in the communication.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the relevant regulatory authority.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this privacy policy.

Links to other websites

Our Services may contain links to other websites, including in any embedded content. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this privacy policy.


We may, at any time and at our discretion, vary this privacy policy by publishing the amended privacy policy on our website. We recommend you check our website regularly to ensure you are aware of our current privacy policy.

For any questions or notices, please contact us at:


Last update: 21 January 2020