Recruitment Privacy Policy

Please read the information below before proceeding with your application:

Privacy laws (including but not limited to the Privacy Act 1988 (Cth), Personal Data Protection Act 2012 and Data Protection Act 2018) affect how we administer the collection, use and disclosure of your personal information. This Privacy Policy explains the approach adopted by Pepper Global Midco Limited, its related corporations and affiliates (“Pepper”, “we”, “our” or “us”) to the collection and handling of your personal information for the purposes of our recruitment process. This Privacy Policy applies to all applicants for employment or a contract or internship position with Pepper.

The types of personal information that Pepper collects, processes, holds, discloses and transfers about you include:

  • identification information, including your name, date of birth, driver's licence, citizenship or visa information, national identification numbers, personal contact details including postal address, email and telephone numbers.
  • your resume, work and education history, and
  • other information that we think is necessary.

To the extent relevant to your application, we may also collect and/or process sensitive or special personal data where relevant to the recruitment process, including where necessary to accommodate any disability needs.

We may also collect information about you because we are required or authorised by law to collect it, including payroll/ taxation and superannuation law, which require us to collect personal information.

If you provide third party personal data to us (such as the personal data of your spouse, children, family members and/or referees), by doing so, you confirm that you have obtained their respective consents to our collection, use and disclosure of their personal data on these terms. You confirm that the information that you submit is true and accurate and does not violate any applicable laws or breach any contract or render Pepper liable to any claim or proceedings whatsoever.

Pepper collects personal information submitted by you via this platform.

The processing of your personal information for recruitment purposes is:

  • necessary to consider whether to enter into an employment relationship with you;
  • necessary to comply with any legal right or obligations to which we are subject in relation to your employment of engagement; or
  • carried out with your consent, to carry out criminal record checks and pre-employment searches with a credit reference agency, where countries laws permit;

and includes but is not limited to the following:

  • to process your application including to identify and contact you; 
  • to determine whether you have the professional skills, expertise and experience for the position applied for;
  • if you are offered a position with Pepper, to verify the personal data provided including your identity, address, right to work, employment history and academic background and other background screening purposes including, where allowed by law, criminal record checks, searches with a credit reference agency and sanctions screening checks; and
  • to assist in the administration of Pepper’s global recruitment program, recruitment campaign planning, and compliance with related internal policies. 

Pepper may exchange your personal information with your referees, and with third party organisations involved in the recruitment process. For example, we engage third parties to conduct pre-employment/background screening in accordance with local regulatory, legislative and geographic requirements. These organisations may conduct various searches, which may include verification of your identification information, employment references, civil, credit and criminal records, specific regulatory accreditation required for your role, directorships, property ownership, education, employment history and qualifications, social media searches and any other background information in relation to you. Where relevant to your application, we may also disclose your personal information to organisations providing personality assessment and/or psychometric testing or to arrange visa, or otherwise satisfy migration requirements applicable in the relevant jurisdiction. In addition, we may also disclose your personal information as required or allowed by any applicable law or regulation, including to any court, tribunal, regulatory authority or governmental entity.

If you accept an offer of employment or a contract internship position with Pepper, the information provided in your application and any other information collected in the course of the application and recruitment process will become part of your employment records. If you are employed or engaged as a contractor or intern by Pepper, and you apply to become a customer of a Pepper entity, your personal information will be treated in accordance with the privacy policy applicable to such Pepper entity. Your customer records will be annotated to identify you as a staff member whilst you are employed or engaged by Pepper.

We may need to share some of your personal information with other members of the Pepper group and/or our contracted services providers located in various jurisdictions, including but not limited to the United Kingdom, Ireland, Spain, South Korea, Hong Kong, Singapore and the Philippines. Overseas entities may be required to disclose information to relevant foreign authorities under a foreign law.  Whilst we attempt to select and secure reputable offshore service providers, to the greatest extent permitted by applicable laws, we are not liable for any breach or misuse of information sent to offshore service providers. Where permitted by applicable laws, Pepper may transfer your personal information to an overseas entity which may not be subject to privacy laws or principles similar to those which apply to the jurisdiction you are located in, and any information disclosed to an overseas service provider may not have the same protection as under the privacy laws applicable to the jurisdiction you are located in.  Unless required by applicable laws, you may not be able to seek redress for any breach of your privacy which occurs outside of the jurisdiction you are located in. To the greatest extent permitted by applicable laws, you consent to Pepper disclosing your personal information to entities located outside the location you are in for purposes related to your employment, on the basis that Pepper is not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient of your personal information complies with privacy laws applicable in the jurisdiction you are located in.

Where required by applicable laws, when using external service providers, we will require that they take reasonable technical and organisational steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

In addition, if you are applying for a position in the European Union (“EU”) or located in the EU and your personal information is processed in a country outside of the EU, we will put in place contractual clauses approved by the EU Commission as providing an adequate level of protection.

You should be aware that the Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. We do not accept responsibility or liability for the confidentiality, security or integrity of your personal information in connection with its transmission over the Internet.

We store information in different ways, including in electronic form, cloud storage and IT servers that may be located overseas to store the personal information we hold. Your information will be held securely and used only by authorised staff within Pepper for recruitment purposes. The security of your personal information is important to us and we take reasonable technical and organisational steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. However, in the case of electronic storage, it is not always practicable to find out where your information may be accessed or held, as electronic or networked storage can be accessed from various countries via an internet connection.

Personal information is retained as long as necessary for the purpose for which it is collected and to meet legal, regulatory and operational requirements. Retention periods may differ for each country. At the end of the retention period, non-identifiable data is kept for management information purposes.

Pepper uses a number of assessments across our hiring processes and which ones you encounter depend on the role for which you are applying. Some of these assessments may measure your performance or evaluate your suitability for a role on a solely automated basis and without human intervention (‘automated decision-making’). We use automated decision-making because it allows for greater consistency and fairness in the decision-making process, for example, by reducing the potential for human error and bias. It is faster, more comprehensive, and more precise than human decision-making, thereby increasing the efficiency of the process. This means that candidates receive feedback more quickly and can therefore also apply for jobs elsewhere in a timely manner. Furthermore, Pepper receives a significant number of applications and the quantity of applications received may mean that the use of automated decision-making is necessary since human involvement may not be practically possible. If we undertake any assessments or profiling that will result in an automated decision relating to you, we will do so on the basis we think it is necessary to your application or with your consent; we will let you know and you will have the right to discuss the decision.

Recruitment activities are generally not aimed at minors. If you are a minor in the relevant jurisdiction, you must obtain the consent of your parent or guardian before contacting Pepper in relation to recruitment.

Please contact us at if you wish to:

  • update;
  • access or correct;
  • seek the deletion or erasure of;
  • provide us with feedback on our handling of;
  • raise a query on our handling of;

your personal information.

If you don't agree to Pepper collecting, using and disclosing your personal information in accordance with this Privacy Policy, Pepper will not be able to process your application and we will not be able to consider or proceed with your application.

By using this website, you consent to Pepper's collection, use and disclosure of your personal information pursuant to this Privacy Policy.

This Privacy Policy may be updated from time to time and it is your responsibility to visit our websites regularly for the most recent version.