Platform Privacy Policy

Version 1.1 | Effective Date: 4 September 2026

Jurisdiction: Australia (applies globally where JobSeal operates)
Governing Law: Laws of New South Wales, Australia

This document should be read in conjunction with the JobSeal Acceptable Use Policy.

1. Overview

JobSeal Pty Ltd ('JobSeal', 'we', 'us') is committed to protecting the privacy of all individuals who interact with our Platform. This Privacy Policy explains how we handle personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy applies to personal information collected from candidates, employers, employer users, referees, and visitors to our website.

2. Information We Collect

2.1 Candidates

We collect the following information from candidates:

Identity: Full name, email address, and phone number (all encrypted at rest);
Employment history: Company names, job titles, employment dates, employment type;
Referee and HR contacts: Names and professional email addresses of your nominated referee and HR contact for each role (encrypted at rest);
Behavioural scores: Aggregated dimension scores computed from your referee's survey responses. Individual question-level answers are never retained;
Usage data: When and how you access the Platform, REFID link views, device and browser information (hashed); and
Account data: Authentication details managed via AWS Cognito; we do not store passwords.

2.2 Employers and Employer Users

We collect:

Organisation details: Company name, ABN/ACN, billing address;
User details: Names and email addresses of account users; and
Usage and commercial data: Subscription history, verification orders, candidate search logs, billing records.

2.3 Referees

We collect:

Name and professional email address;
Employment confirmation data (whether you worked with the candidate during the stated period);
Participation metadata: whether you completed a survey, when, and using what device (hashed); and
Survey dimension averages: Computed averages across behavioural dimensions derived from your survey answers. Raw question-level responses are not retained.

Your name and email address are also recorded in our audit log for fraud-detection purposes. Unlike the rest of the verification record, this entry is retained for seven years and is not deleted when the candidate who nominated you deletes their account. See section 6 and the Referee Terms and Consent (section 7.1).

2.4 Website Visitors

Standard web analytics data including IP addresses (anonymised), browser type, pages visited, and session duration.

3. How We Use Personal Information

3.1 Candidates

To create and manage your REFID profile and account;
To facilitate employment verification requests to your nominated referee and HR contact;
To compute and display your JobSeal;
To make your name, career score, and verified employment history discoverable to employers searching the candidate pool, and visible on a verification report an employer generates for your profile — your email and phone number are never included in either without your separate approval of that employer's contact request;
To compute anonymous, aggregate market-benchmark statistics — for example, typical verified role scores by industry, function, seniority, location, and employment type — that we make available to employers with an active subscription. Every published statistic is calculated across a group of at least 20 candidates, so no individual's data can be identified or singled out from it. This applies even if you have enabled Stealth mode or an employer exclusion: those controls govern your visibility in employer search and reports (see Section 8), not whether your verified scores contribute to these anonymous, aggregate statistics, since the statistics never identify or expose any individual candidate;
To notify you of profile activity (referee and HR responses, disputes); and
To provide customer support and respond to disputes.

We do not currently notify you when an individual employer views your profile — an employer's own view history is visible only to them, not to you.

3.2 Employers

To provision and manage your account;
To process verification orders and deliver reports;
To enable candidate search functionality;
To process billing and manage subscriptions; and
To provide customer support.

3.3 Referees

To send and manage verification and survey requests;
To authenticate your participation via magic-link token;
To detect and investigate suspected fraudulent responses; and
To comply with audit and legal obligations.

4. Legal Basis for Processing

We process personal information on the following bases:

Contractual necessity: Processing necessary to provide the services described in our Candidate and Employer Terms of Service;
Legitimate interests: Fraud detection, security monitoring, platform integrity, and aggregate analytics that do not override individual rights;
Consent: Referee participation in a survey is voluntary and constitutes consent to the specific processing described in the Referee Terms and Consent. Note that not all processing of referee information rests on consent — retention of a referee's contact details in the audit log for fraud detection rests on the legitimate-interests and legal-obligation bases above, and so continues to apply whether or not a referee responds to a nomination; and
Legal obligation: Retention of records required by law, including the audit log.

5. Data Storage and Security

5.1 Storage Location

Your personal data is stored and processed in the AWS region associated with your account — for every user today, that is Australia (AWS ap-southeast-2, Sydney). If JobSeal introduces additional regional data centres in future (for example, to serve the European Union or North America), you will select your region at registration, and your data will be stored and processed there. Your data does not move to a different region without your explicit consent, except for the two narrow, anonymised or transient processes below — neither moves or stores your identifiable data outside your region on an ongoing basis:

Aggregate market-benchmark statistics (Section 3.1) may be computed from data held in every region JobSeal operates in, not only yours. The output is always an anonymous statistic covering at least 20 candidates or roles and never identifies or singles out any individual.
Employer search, once JobSeal operates in more than one region, may retrieve results from a region other than the searching employer's own, so employers can search the full candidate pool regardless of region. When this happens, the profile information already visible to employers under Section 7 may be processed momentarily by JobSeal's infrastructure in another region in order to return that result — it is not stored or retained there afterwards. You can control whether your profile is included in this cross-region search at all — see Section 8.

5.2 Encryption

All data is encrypted in transit using TLS 1.2 or higher;
Sensitive personal data fields (name, email address) are encrypted at the column level using AES-256 with AWS KMS-managed keys;
All storage media (database, object storage) is encrypted at rest; and
Payment card data is never stored by JobSeal; all payment processing is handled by Stripe under PCI DSS compliance.

5.3 Access Controls

Access to personal data is restricted to authorised JobSeal personnel on a need-to-know basis. All access is logged. Multi-factor authentication is required for all administrative access.

6. Data Retention

We retain personal information for the following periods:

Active candidate accounts: Retained for the duration of the account and for 7 years after deletion;
Referee participation records: Retained for 7 years from the date of participation;
Employer account and billing records: Retained for 7 years from account closure;
Survey dimension averages: Retained as part of the candidate's score history for the duration of the account;
Audit log entries: Retained for 7 years from creation, regardless of account status. Audit entries identify the person an action concerned and the person who performed it, by name or email address. This includes referees and HR contacts, who are not JobSeal account holders — their contact details persist in the audit log for the full seven years even after the related candidate account is deleted. We retain this because reference fraud is detectable only as a pattern across records over time. This retention rests on our legitimate interests and legal record-keeping obligations, not on consent, and is therefore not ended by a referee declining or withdrawing from a survey;
Website analytics: Anonymised after 90 days; and
Deleted account data: Personal profile data purged within 30 days of deletion request, subject to the audit log and legal retention exceptions above.

7. Disclosure of Information

We do not sell personal information. We may share personal information with:

Employers — search results and verification reports: Your name, career score, verified employment history, and LinkedIn URL (if provided) are visible directly to any employer with an active subscription who searches the candidate pool or generates a verification report for your profile, once you have at least one verified role. This does not require your approval for each employer, and, where JobSeal operates in more than one region, may include a search originating from an employer in a different region than yours, processed as described in Section 5.1;
Employers — contact requests: Your email address and phone number are disclosed only when you approve a specific employer's contact request — this applies whether or not that employer has already generated a verification report for you. You may approve or decline each request individually;
Employers — anonymous market-benchmark statistics: We publish aggregate statistics (see Section 3.1) to employers with an active subscription and the relevant plan entitlement. These statistics are calculated across groups of at least 20 candidates and never identify or expose any individual candidate's data, so we do not consider this a disclosure of personal information — we note it here regardless, for transparency;
Service providers: AWS (infrastructure), Stripe (payments), and other sub-processors who process data on our behalf under appropriate data processing agreements;
Law enforcement: Where required by a valid legal order or to comply with a legal obligation;
Professional advisers: Lawyers, accountants, and auditors under confidentiality obligations; and
Business transfers: In the event of a merger, acquisition, or sale of assets, candidate data may be transferred to the acquiring entity, which will be required to honour this Policy.

8. Your Rights

In addition to your rights under the Australian Privacy Act, you can directly control your visibility to employers:

Stealth mode: Remove your profile from employer search results entirely, at any time, from your account settings;
Employer exclusions: Block specific employer domains (for example, a current employer) from seeing your profile in search, without affecting your visibility to anyone else; and
Cross-region search visibility: Once JobSeal operates in more than one region, control whether your profile can be returned to an employer searching from outside your own region, at any time, from your account settings. This is included (switched on) by default, so employers can search the full candidate pool from day one — turning it off removes you from every other region's search results without affecting your visibility to employers in your own region.

These controls govern your visibility in employer search and reports specifically. They do not exclude your verified scores from the anonymous, aggregate market-benchmark statistics described in Section 3.1 — those statistics never identify or single out any individual, including candidates using any of the above controls, so removing yourself from search does not require also removing yourself from an anonymous group statistic.

Under the Australian Privacy Act, you also have the right to:

Access: Request a copy of the personal information we hold about you;
Correction: Request correction of inaccurate, outdated, or incomplete information;
Deletion: Request deletion of your account and personal information, subject to retention obligations;
Portability (candidates): Request an export of your profile data in a machine-readable format;
Objection: Object to processing carried out under legitimate interests where your interests override ours; and
Complaint: Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

To exercise any of these rights, contact us at privacy@jobseal.co. We will respond within 30 days.

9. Cookies and Tracking

Our website uses strictly necessary cookies for authentication and session management. We use analytics cookies only with your consent. We do not use advertising or tracking cookies.

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified to registered users via email at least 30 days before taking effect.

11. Contact

Privacy Officer, JobSeal Pty Ltd
Email: privacy@jobseal.co
Office of the Australian Information Commissioner: www.oaic.gov.au | 1300 363 992