This policy explains how Rostr Pty Ltd (ABN 00 000 000 000) ("Rostr", "we", "us") handles personal information. We are based in Perth, Western Australia. We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), whether or not the Act applies to us as a small business. If we ever treat the Act as not applying to us, we will say so here.
1. Two kinds of people, two roles
Rostr is used by construction contractors to run site access. That means we deal with two groups:
- Account holders. The builder or contractor who signs up, pays for Rostr and manages sites. For their details, we are the organisation collecting the information.
- Workers. People who clock on and off a site using Rostr. The site operator (our customer) decides which workers are added, which inductions they complete and which licences are checked. We hold that information on the site operator's behalf, and we also use it to run the service, keep it secure and meet our own legal obligations.
If you are a worker and you have a question about why your site collects something, your employer or the site operator is the right first call. If you cannot get an answer, contact us and we will help.
2. What we collect
Account holders and managers
- Name, work email, mobile number, job title
- Company name, ABN, trading address
- Billing details. Card numbers are held by our payment provider, not by us [TODO: name provider]
- Sign-in records, device and browser information, support messages
Workers
- Name, mobile number, employer, trade
- Clock-on and clock-off events: the time, the site, the gate whose QR code was scanned, and whether the event was sent live or queued on the phone while offline
- Induction records: answers to questions, acknowledgements, signatures, which videos were watched
- Licence and ticket details: type (for example white card, working at heights, high risk work licence), licence number, expiry date, and a photo of the card or licence if the site operator asks for one. A licence photo can show your date of birth and your face
- Transfers between sites run by the same operator
- Device and browser information needed to make the phone web app work
Website visitors
- What you type into the waitlist, demo or contact forms
- Aggregated, anonymous page statistics from Plausible Analytics. Plausible does not use cookies and does not identify individuals. [TODO: remove if Plausible is not used]
We do not ask for health information, union membership or any other sensitive information as defined in the Act, other than what appears on a licence photo. We ask site operators not to add fields that collect it.
3. How we collect it
- Directly from you, when you sign up, clock on, complete an induction or upload a licence
- From the site operator or your employer, when they add you to a site
- From your phone, when you scan a QR code (the scan sends the gate code and the time, not your location)
When you first clock on at a site using Rostr, the phone screen tells you who is collecting your information and links to this policy. [TODO: confirm the in-app collection notice wording]
4. Why we collect it
- To record who is on a site, so the site operator can meet work health and safety duties
- To run inductions and keep a record that they were completed
- To check licences and tickets against their expiry dates and warn before they lapse
- To build timesheets from clock events
- To produce attendance insights for the site operator (see section 7)
- To run, secure, support and bill for the service
- To meet legal obligations, including record-keeping under work health and safety laws
We do not sell personal information. We do not use worker information for marketing.
5. Who we share it with
- The site operator you clocked on with, and your employer if they are a subcontractor on that site. They see your clock events, inductions and licence status for their sites only
- Service providers who host and run Rostr for us, under contracts that limit what they can do with the data: cloud hosting and storage in Sydney, Australia [TODO: provider name]; email delivery [TODO: provider]; payment processing [TODO: provider]; AI model provider for Ask Rostr (section 7)
- Regulators and courts where the law requires it. A work health and safety regulator will usually ask the site operator for records, not us. If we receive a request directly, we will tell the site operator unless the law stops us
- A buyer of our business, if Rostr is sold, under the same obligations as this policy
6. Where it is stored
Rostr data, including backups, is stored in Australia. Some service providers may process limited information outside Australia: [TODO: list each provider, the data involved and the country]. Before we use an overseas provider we take reasonable steps to make sure they handle your information in line with the APPs, as APP 8 requires.
7. AI features
Ask Rostr and the attendance insights send a question and the relevant attendance figures to an AI model provider and return a plain-English answer. The provider is [TODO: provider and region]. Under our agreement with them, they do not keep the data or use it to train models. Insights are summaries of your own clock events; they do not profile individual workers for any purpose other than attendance on your sites, and no automated decision in Rostr denies a worker access without a human-set rule (such as an expired licence).
8. Government identifiers
Licence numbers are government identifiers. We store them so the site operator can verify a licence and track its expiry. We do not use them as our own identifier for you, and we do not disclose them except as described in section 5, in line with APP 9.
9. Security
We encrypt data in transit and at rest. Each company's data is isolated at the database level so one customer cannot read another's. Access by Rostr staff is limited, logged and only for support or maintenance. Licence photos are stored separately from the main database with access controls of their own.
If a data breach happens that is likely to cause serious harm, we will notify the Office of the Australian Information Commissioner (OAIC) and the affected people as the Notifiable Data Breaches scheme requires, and we will notify the site operator so they can meet their own obligations.
10. How long we keep it, and deletion
| Information | Kept for |
|---|---|
| Clock events, inductions, timesheets | While the site operator's account is open, then as set by the site operator's retention setting. Default [TODO: 7] years after the site is closed, to match work health and safety record-keeping periods. |
| Licence and ticket photos | Deleted [TODO: 12] months after your last clock-on with that operator, or sooner on request. The licence type and expiry date are kept with your clock-on record. |
| Worker profile (name, mobile, employer) | While you are linked to an open site. Removed [TODO: 12] months after your last clock-on, or on request. |
| Account holder details and billing records | While the account is open, then [TODO: 7] years for tax and accounting law. |
| Closed accounts | Export available for 30 days after closure. Data deleted within 90 days. Backups purged within 35 days after that. |
| Website form submissions | Until we have replied and the enquiry is closed, then no more than [TODO: 24] months. |
Deletion on request. You can ask us to delete your personal information at any time by emailing privacy@rostr.au. We will confirm your identity, tell the site operator, and delete what we can within 30 days. Where a law requires a record to be kept (for example a site attendance record under work health and safety law), we keep the minimum needed, tell you what that is and why, and delete the rest.
11. Access and correction
You can ask for a copy of the personal information we hold about you, and ask us to correct it, under APP 12 and APP 13. Workers can see their own clock events, inductions and tickets in the Rostr phone app at any time. For anything else, email privacy@rostr.au. We will respond within 30 days. We do not charge for access requests.
12. Anonymity
You can read this website without telling us who you are. You cannot clock on to a site anonymously: the point of the record is to know who was there.
13. Cookies and local storage
This website sets no cookies. It stores your light-or-dark theme choice and billing toggle in your browser's local storage, which never leaves your device. The app at app.rostr.au uses a sign-in cookie that is necessary to keep you signed in. We do not use advertising cookies or trackers.
14. Complaints
If you think we have mishandled your information, email privacy@rostr.auwith "Privacy complaint" in the subject line. We will acknowledge it within 7 days and aim to resolve it within 30. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner atoaic.gov.au or on 1300 363 992.
15. Changes
We will post any changes here and update the date at the top. If a change affects how we handle worker information, we will tell site operators by email at least 14 days before it takes effect so they can tell their crews.
16. Contact
Privacy officer, Rostr Pty Ltd
[TODO: postal address], Perth, Western Australia
privacy@rostr.au