Privacy Policy

1. Our commitment to your privacy

SCA Connect is committed to protecting the privacy, confidentiality and security of the personal information entrusted to us.

As an Australian immigration services provider, we routinely handle personal and sensitive information concerning our clients, their family members, employees, employers, sponsors and other individuals involved in migration matters.

This Privacy Policy explains how Janaye Pty Ltd trading as SCA Connect (“SCA Connect”, “we”, “us” or “our”) collects, holds, uses, discloses and protects personal information.

We manage personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) and comply with other applicable legal and professional obligations, including confidentiality obligations applying to Registered Migration Agents.

This Policy applies to personal information handled by SCA Connect through all aspects of our business and services, including our website, client services, consultations, communications, forms, client portals, information technology systems and interactions with third-party service providers.

2. What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

The personal information we collect and hold will depend upon your relationship with SCA Connect and the services we provide.

It may include:

• your name, date of birth and contact details;
• residential and postal addresses;
• passport and travel document information;
• visa and immigration information;
• citizenship and nationality information;
• government-issued identifiers;
• photographs and identity documents;
• family and relationship information;
• employment and work history;
• qualifications, education and professional information;
• salary and remuneration information;
• financial information;
• taxation information;
• information about employers, sponsors and associated organisations;
• travel history;
• correspondence with you and third parties;
• documents and information supplied in connection with migration matters;
• information contained in visa applications and other government applications;
• information provided by government agencies, assessing authorities and other organisations;
• records of consultations and communications;
• information concerning the services we provide to you; and
• technical information generated when you interact with our website, portals or electronic services.

We may also collect information about individuals other than our direct client where that information is relevant to a matter, including family members, dependants, partners, employees, employers, sponsors and other associated persons.

3. Sensitive information

Migration matters can require SCA Connect to collect and process sensitive information.

Sensitive information may include information about an individual’s:

• racial or ethnic origin;
• health or medical history;
• disability;
• criminal record;
• religious or philosophical beliefs;
• political opinions or associations;
• professional or trade associations;
• sexual orientation or practices;
• biometric information; and
• other information classified as sensitive information under the Privacy Act.

We only collect and use sensitive information where it is reasonably necessary for our functions or activities and where we have the required consent or are otherwise permitted or required by law.

Because immigration matters can involve particularly sensitive circumstances, we apply additional care to the handling of this information.

4. How we collect personal information

Where reasonable and practicable, we collect personal information directly from you.

We may collect information through:

• consultations and meetings;
• telephone and video calls;
• email and other electronic communications;
• our website;
• online enquiry and assessment forms;
• client questionnaires;
• client portals;
• documents uploaded or provided to us;
• correspondence;
• electronic signatures;
• employers and sponsoring organisations;
• family members and authorised representatives;
• government agencies;
• the Department of Home Affairs;
• skills assessing authorities;
• educational institutions;
• professional advisers;
• publicly available sources;
• third parties authorised by you;
• technology platforms used in delivering our services; and
• other sources where collection is authorised or required by law.

Where we receive personal information about you from another person, we will take reasonable steps where required to ensure you are aware of the circumstances of collection.

5. Why we collect, hold and use personal information

We collect, hold and use personal information where reasonably necessary to conduct our business and provide our services.

This may include:

• assessing immigration options and eligibility;
• providing immigration assistance and professional advice;
• preparing and managing visa, sponsorship, nomination and other applications;
• preparing submissions and correspondence;
• communicating with clients, employers, government agencies and other relevant organisations;
• verifying identity and information;
• obtaining and reviewing supporting evidence;
• conducting legal, policy and factual research;
• managing client matters and records;
• managing employer-sponsored migration programs;
• communicating with prospective clients;
• responding to enquiries;
• providing quotations and entering into client agreements;
• processing payments and managing accounts;
• complying with legal, regulatory and professional obligations;
• maintaining the security and integrity of our systems;
• managing complaints and disputes;
• improving our services, systems and business processes;
• training and quality assurance;
• business administration; and
• marketing and communicating information about our services where permitted by law.

Where appropriate, we will explain why information is being collected and how it is intended to be used.

6. Artificial intelligence, automation and technology-assisted processing

SCA Connect uses technology, including approved artificial intelligence (“AI”), machine-learning and automation systems, to assist our Registered Migration Agents and staff in providing efficient and high-quality services.

Depending upon the circumstances, approved AI and automated technologies may assist with activities including:

• document processing, classification and information extraction;
• summarising information and documents;
• research;
• drafting and reviewing correspondence;
• assisting with preparation and review of documents and submissions;
• administrative processing;
• workflow management and automation;
• organising and retrieving information;
• translation and language assistance;
• data analysis;
• quality assurance; and
• other activities supporting the provision and administration of our services.

Where personal information is processed using AI, SCA Connect applies privacy, confidentiality and security requirements appropriate to the information and the purpose for which the technology is being used.

SCA Connect maintains controls governing which AI systems may be used for business purposes and the types of information those systems are permitted to process.

We do not authorise staff to enter identifiable client information or sensitive client information into unauthorised public or consumer AI services.

Where reasonably practicable, we minimise the personal information provided to AI systems and use de-identified information where identifying information is unnecessary.

Human oversight

Artificial intelligence assists our people. It does not replace the professional responsibility of our Registered Migration Agents.

AI-generated information can be incomplete, inaccurate or inappropriate. Where AI contributes to substantive immigration assistance, professional advice, assessments, submissions or other material work, appropriate human review is required before that information is relied upon.

Our Registered Migration Agents remain responsible for immigration assistance provided by them.

SCA Connect does not rely upon AI as an unsupervised substitute for the professional judgement of a Registered Migration Agent.

Client consent

Where required, SCA Connect obtains written consent before entering a client’s personal details into an AI platform or system in connection with providing immigration assistance.

Our Client Agreement and associated consent processes provide further information concerning the use of AI in delivering our services.

Consent to SCA Connect’s use of approved AI does not authorise individual staff members to use client information with any AI service. Client information may only be processed using systems and methods authorised by SCA Connect.

You may contact us if you have questions or concerns about the use of your personal information in connection with AI.

7. Automated decision-making

SCA Connect may use computer systems, automation and AI to assist our staff and Registered Migration Agents with analysis, administration, workflow management and decision support.

We do not regard AI as a substitute for the professional judgement and responsibility of a Registered Migration Agent.

Where a computer program uses personal information to make, or do something substantially and directly related to making, a decision that could reasonably be expected to significantly affect an individual’s rights or interests, SCA Connect will provide the information required by applicable privacy law about the use of such systems.

Where applicable, this may include information about:

• the kinds of personal information used by the computer program;
• the kinds of decisions made solely by computer programs; and
• the kinds of decisions for which a computer program performs functions substantially and directly related to making the decision.

SCA Connect will review its use of automated systems as technology and applicable privacy requirements develop.

8. Disclosure of personal information

In providing our services, we may disclose personal information to third parties where reasonably necessary, with appropriate authority or consent, or where otherwise permitted or required by law.

Depending upon the matter, recipients may include:

• the Department of Home Affairs and other Australian Government agencies;
• Australian state and territory government agencies;
• review bodies, tribunals and courts;
• overseas government authorities where relevant to your matter;
• skills assessing authorities;
• educational institutions;
• health and medical service providers;
• police and character assessment authorities;
• employers and sponsoring organisations;
• professional advisers;
• translators and interpreters;
• financial institutions and payment service providers;
• accounting and business administration providers;
• information technology and cybersecurity providers;
• cloud hosting and data storage providers;
• document management and electronic signature providers;
• approved artificial intelligence and technology service providers; and
• other organisations or persons involved in providing services relevant to your matter.

We do not sell client personal information.

Where third-party technology providers process personal information on our behalf, we take reasonable steps appropriate to the circumstances to assess privacy, confidentiality and security considerations.

9. Overseas disclosure and processing

Some of the organisations and technology providers with which SCA Connect interacts may operate or process information outside Australia.

This may include overseas government authorities relevant to a migration matter, international organisations and technology or cloud service providers with infrastructure, personnel or subprocessors located overseas.

Where personal information may be disclosed to an overseas recipient, SCA Connect will consider its obligations under the Privacy Act, including the Australian Privacy Principles.

Where practicable, we consider the location in which information is stored or processed and the privacy and security arrangements applying to relevant service providers.

Because the location of cloud infrastructure and service-provider subprocessors may change, it may not always be practicable to identify every country in which information may be processed. Where required and practicable, information about likely overseas locations will be provided.

10. Security of personal information

SCA Connect takes reasonable steps to protect personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Our security measures may include, as appropriate:

• access controls;
• identity and authentication controls;
• multi-factor authentication;
• encryption;
• secure cloud services;
• information access restrictions;
• cybersecurity controls;
• logging and monitoring;
• secure client communication and document systems;
• staff confidentiality requirements;
• privacy and security training;
• information classification;
• controls governing the use of AI and external technology services; and
• incident and data breach response procedures.

Access to client information is restricted according to legitimate business and professional requirements.

No method of electronic transmission or storage is completely risk-free. We continually review our practices and controls having regard to the nature and sensitivity of the information we hold and developments in technology and cybersecurity.

11. Data breaches

SCA Connect maintains processes for identifying, assessing, containing and responding to suspected privacy and security incidents.

Where a data breach is likely to result in serious harm and meets the requirements of the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Privacy Act.

Suspected inappropriate disclosure of personal information through an AI or other technology service is treated as a potential privacy or security incident and assessed accordingly.

12. Retention and disposal

SCA Connect retains personal information for as long as reasonably necessary for the purposes for which it was collected and to comply with our legal, professional and regulatory obligations.

Client files are generally retained for at least seven years or for any longer period required by applicable law or professional obligations.

When personal information is no longer required to be retained, we take reasonable steps to destroy it securely or permanently de-identify it, subject to applicable legal and technical requirements.

13. Accuracy and quality of information

SCA Connect takes reasonable steps to ensure that personal information we collect, use and disclose is accurate, up-to-date, complete and relevant having regard to the purpose for which it is used or disclosed.

We encourage you to notify us if your personal information changes or if you believe information we hold about you is inaccurate.

This obligation also applies where technology or AI assists in generating, analysing or processing personal information. AI-generated information is not assumed to be accurate merely because it has been generated by an automated system.

14. Accessing and correcting your personal information

You may request access to personal information SCA Connect holds about you and request correction of information you believe is inaccurate, out-of-date, incomplete, irrelevant or misleading.

Requests should be made using the contact details below.

We may need to verify your identity before providing access to personal information.

There may be circumstances in which we are permitted or required by law to refuse access or correction. Where applicable, we will explain our decision and available complaint mechanisms.

We do not charge a fee for making an access request, although in some circumstances we may charge reasonable costs associated with providing access where permitted by law.

15. Direct marketing

SCA Connect may use personal information to communicate with you about our services, migration developments or other information we reasonably believe may be relevant to you where permitted by law.

You may opt out of receiving direct marketing communications at any time by using an unsubscribe facility provided in the communication or by contacting us.

We will not use sensitive information for direct marketing without appropriate consent.

16. Website, cookies and analytics

Our website may use cookies and similar technologies to operate the website, remember preferences, understand how visitors use our services and improve website performance.

Information collected may include:

• IP address;
• browser and device information;
• operating system;
• approximate geographic location;
• pages visited;
• referring pages or websites;
• interactions with our website; and
• date and time of access.

We may use third-party analytics and technology providers in connection with our website.

You can manage or restrict cookies using your browser settings. Restricting some cookies may affect website functionality.

17. Links and third-party websites

Our website may contain links to websites operated by third parties.

SCA Connect is not responsible for the privacy or security practices of external websites. We encourage you to review the privacy policies of external services before providing personal information to them.

18. Social media

SCA Connect may use social media platforms to communicate with clients, prospective clients and members of the public.

Information you provide through a social media platform is also subject to that platform’s privacy practices and may be processed outside Australia.

We recommend that you do not provide sensitive immigration, identity or other confidential information through public social media channels.

19. European Union and other international privacy rights

Where SCA Connect is subject to privacy or data protection laws in another jurisdiction in relation to an individual, we will comply with applicable requirements.

Individuals whose information is subject to the European Union General Data Protection Regulation (“GDPR”) may have additional rights depending upon the circumstances, including rights relating to access, correction, erasure, restriction of processing, data portability, objection and certain automated decision-making.

The application of these rights depends upon the circumstances and applicable law and may be subject to legal and professional record-retention requirements.

20. Privacy complaints

If you have a concern or complaint about the way SCA Connect has handled your personal information, please contact us using the details below.

Please provide sufficient information for us to understand and investigate your concern.

We will acknowledge and investigate privacy complaints and respond within a reasonable period.

If you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Information about privacy rights and complaints is available from the OAIC.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• our services and business practices;
• technology and information systems;
• our use of artificial intelligence and automation;
• service providers;
• legislation and regulation; and
• regulatory guidance.

The current version will be published on our website and will identify the date it was last updated.

We will review this Policy periodically and following material changes to our handling of personal information.

22. Contact us

For privacy enquiries, requests for access or correction, or privacy complaints, please contact: