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Privacy policy - Pacific Labour Facility


We are the Pacific Labour Facility (PLF), a project team dedicated to the Pacific labour mobility programs (Pacific Labour Scheme or PLS and Seasonal Worker Programme or SWP), acting under the legal entity Palladium International Pty Ltd ACN 010 020 201(Palladium), and in this privacy policy, weus or our.

We have been appointed to manage the PLS, as a managing contractor for the Department of Foreign Affairs and Trade (DFAT). Via our website, we also facilitate the data collection and data storage aspect of the application process for the SWP, which is run by the Department of Education, Skills and Employment (DESE). The PLS and the SWP are each labour mobility initiatives which aim to fill labour gaps and provide workers from the Pacific new opportunities to work in Australia. For both the PLS and the SWP, we also manage the employer and worker SMS alert service.

This privacy policy applies exclusively to the PLF. If you would like to read Palladium’s full privacy policy, you can access it here. You can also read DFAT’s privacy policy here and DESE’s privacy policy here or by requesting a copy from DESE at (

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

We may collect personal information about you, directly from you or from a third party, for the purpose of administering the PLS on behalf of DFAT (including the SMS alert services) or providing our application data collection and storage services and SMS alert services for the SWP, on behalf of DESE. We may collect this information via any forms you complete, whether online or offline, and any contact you initiate with us, such as via email. As a worker, we may access and collect information about you from the managing government agency or entity of the relevant program in your home country.

The types of personal information which we may collect in such circumstances include:

From employer applicants and/or employees of employer applicants for the PLS and/or SWP:

  • 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
  • your communications and activity information, such as logged emails, text messages and in person discussions with or about you
  • any enquiries you have submitted to us, DFAT or DESE, and our or their response to you
  • any other personal information requested by us or a third party and provided to us by you or a third party.

From potential workers and workers involved in the PLS and SWP:

  • your name
  • your contact details, including email address, mailing address, street address, telephone number and/or instant messenger information
  • your identity data and proofs, such as passport or license numbers and copies of the same
  • your supporting documents, such as references and background police checks
  • your necessary medical information, such as medical screening results or summaries, drug screening results
  • your travel coordination data, such as schedules, tickets, visa applications and approval documents
  • your communications and activity information, such as logged emails, text messages and in person discussions with or about you
  • any other personal information collected where a specific criteria is requested by an employer
  • any other personal information requested by us or a third party and provided to us by you or a third party.

As part of our SMS alert services (whether as a PLS employer, PLS worker, or SWP employer or SWP worker):

  • your name
  • your telephone number
  • as a worker, your country of origin
  • as a worker, your approved employer
  • your industry or sector
  • your location (town and state)
  • the SMS alerts sent to you
  • if applicable, information about the source through which you accessed the SMS alert sign-up.

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, your ethnicity, your religious beliefs or your criminal records. 

How we handle sensitive information: Provided you consent, your sensitive information may only be used and disclosed for purposes directly relating to the primary purpose for which the sensitive information was collected, including handling this information on behalf of DFAT as part of the PLS, disclosing this information to DFAT for the purposes of the PLS, disclosing this information to DESE for the purposes of the SWP and storing this information for DESE as part of the SWP. 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 indirectly collect when delivering our website to you include: 

  • your browser session and geolocation 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
  • 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:

  • as an employer, to facilitate the submission of your application for the PLS and/or SWP
  • as an employer, to assess your application as part of the PLS
  • as an employer, to enable DESE to assess your application as part of the SWP
  • where you apply for one Pacific labour mobility program, at your election, to fast track your application for the other program
  • for program deed administration
  • to enable you to access, use and benefit from our services and any associated applications, including any mobilisation organised by us under the PLS
  • to send you SMS alerts if you are part of our SMS alert system and to target the alerts sent to you, based on details such as your language, industry/sector, employer and location
  • to facilitate the appropriate monitoring of the safety of premises associated with the PLS
  • for our internal record keeping and administrative purposes
  • for analytics, to operate, evaluate and improve our services, the programs and any associated applications
  • to send you information about the PLS and/or SWP
  • to comply with our legal obligations and resolve any disputes that we may have
  • 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 PLS
  • DESE for the purpose of enabling them to administer the SWP
  • third parties for program evaluation and research purposes related to the PLS or SWP, including (without limitation) universities and global bodies such as the World Bank. This may include the contact details you provide to us. You consent to such third parties contacting you, using the contact details you provide to us, for PLS or SWP research-related purposes
  • 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 (GovCMS), 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
  • you
  • your referees
  • our existing or potential agents or business partners, for the purpose of providing our services
  • to other Commonwealth agencies and their contracted providers, including, but not limited to
    • the Department of Home Affairs
    • the Fair Work Ombudsman
    • the Department of Health
    • the Australian Taxation Office
    • the Australian Federal Police
    • the Australian National Audit Office and/or
  • State or territory agencies and their respective contracted providers, including, but not limited to:
    • law enforcement agencies
    • health agencies
    • workplace health and safety agencies
    • workers compensation agencies
  • local governments and their authorities
  • Ministers and their offices, members of Australian parliaments, and parliamentary committees
  • diplomatic missions and consulates within Australia
  • universities, colleges, schools and other educational or training institutions
  • any other person, agency or organisation which may be able to contribute information relevant to suitability to participate in the relevant program:
    • if consent has been provided, or
    • where it is otherwise permitted, including where it is required or authorised by or under an Australian law or a court or tribunal order
  • 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,
  • 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: For the purposes outlined above, we may disclose the personal information collected about you or from you, including the name and contact details of the individuals nominated by you as relevant contacts, to third parties operating outside Australia, including Australian external territories, foreign governments, non-government agencies and/or to individuals who are able to contribute information relevant to your suitability to participate in the relevant program.

Overseas recipients may not have the same privacy obligations as us. For this reason, we wish to seek your consent to disclose this personal information overseas. By providing us with personal information, you confirm that you consent to the disclosure of your information outside of Australia and acknowledge that Australian Privacy Principle 8.1 will not apply meaning that we are not required to take reasonable steps to 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, where you provide your consent, we would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act. You also acknowledge that, 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, the processing of your application and your participation in the programs may be impacted.

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. 

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:

Email: (

Last update: 29 July 2021