Australia Residents – Applicants for employment with ghSMART


March 1, 2023

This ghSMART Privacy Policy (“privacy notice”, “privacy statement”, or “notice”) describes how G. H. Smart & Company, LLC and its subsidiaries (collectively “ghSMART”) collect, hold, use and disclose personal information about internal and external employment applicants and candidates who are residents of Australia (“Australia Applicants”), and comply with applicable privacy laws including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.


We have designated a privacy officer who is responsible for our compliance with this Notice.  You may contact our privacy ‎‎officer as described below.‎

Personal Information that we collect
The categories of personal information that we collect depends on the position(s) or location, as well as the associated qualifications and responsibilities. In general, the information we collect from you may include your identity and contact details, banking information, and employment and educational history information, and audiovisual data such as transcripts or recordings of interviews with you.

In limited instances we may collect government identifiers such as drivers’ licences, passport numbers, and information about your entitlement to social security or similar schemes.

We may collect these types of personal information directly from you, or in some instances from third parties including, recruiters and recruiting platforms, employee referrals, former employers, and publicly available records.

Purposes of Collection, Use and Disclosure

We collect, hold and use your personal information so that we can:

  • conduct recruiting, hiring, evaluation activities and onboard successful applicants;
  • verify information about you, including conducting criminal and background checks in accordance with applicable laws;
  • monitor and secure our resources, network and assets;
  • fulfill health and safety obligations;
  • conduct our business functions, including auditing and corporate governance activities; and
  • comply with our legal obligations under applicable laws and assist government and law enforcement agencies or regulators.

You do not have to provide us with your personal information but not providing certain requested information may prevent us from completing our recruiting process.

Disclosure of Personal Information

We may transfer or disclose your personal information to our related companies.

We may disclose your personal information to a third party, for our external service providers, for the performance of services for us or on our behalf.

Cross-border transfers of personal information

We may transfer the personal information we collect about you outside of Australia including to the United States, European Economic Area, United Kingdom and Canada where ghSMART has administrative services, subcontractors, service providers, client consultants and client leadership. You acknowledge that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be ‎able ‎to obtain disclosure of that personal information through the laws of the foreign jurisdiction‎.

We may also transfer your personal information as otherwise permitted or required by law.


We protect the personal information in our custody or control using reasonable physical, ‎‎organizational and electronic security arrangements. We ‎regularly review our practices to ensure they align with reasonable industry practices appropriate to ‎‎the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, ‎‎alteration or disclosure.‎

However, no method of transmission over the Internet, or method of electronic storage, is completely ‎secure. As ‎such, despite our safeguards and protocols, we cannot fully guarantee the security of your ‎personal ‎information and you should always exercise caution when disclosing personal information ‎over the ‎Internet (including by email).‎

Access to and Correction of Personal Information

We will make a reasonable effort to ensure that personal information we are using or disclosing is ‎‎accurate and complete. You may request corrections to your personal information as described below.

How to Exercise Available Rights

You can request access or correction of the personal information we hold about you by contacting us using the details below. In some instances, we are not required to provide you with access to your personal information.

We will not charge you for requesting access to personal information, but you may need to cover our reasonable costs in facilitating access, for example significant time spent on collating information.

Requests for access or correction will be responded to within a reasonable time.


If you have a complaint about how we have handled a privacy issue, you can contact us using the details below. If you remain unsatisfied, you can contact the Office of the Australian Information Commissioner (

Contact details 

If you have any questions about this privacy notice or how we handle your personal information, please contact: or +61 3 7064 1951.

Mail address:

G. H. Smart & Company, LLC
203 North LaSalle Street
Suite 2100
Chicago, IL 60601
The United States of America

G. H. Smart & Company Pty Ltd
Level 29 Chifley Tower
2 Chifley Square
Sydney NSW 2000

Changes to this privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.