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Our Policies

People Priorities is committed to operating ethically, transparently and in full compliance with applicable law. Our policies reflect these values.

Last reviewed: June 2026  ·  Version 1.0

Modern Slavery Policy  ·  People Priorities Pty Ltd & People Priorities India Pvt Ltd  ·  Version 1.0, June 2026

People Priorities is committed to acting ethically and with integrity in all our business dealings and relationships. We are opposed to modern slavery in all its forms and are committed to implementing and enforcing effective systems and controls to ensure it does not take place anywhere in our business or supply chain.

Legal Context: The Modern Slavery Act 2018 (Cth) requires entities with annual consolidated revenue of $100M+ to lodge annual statements. People Priorities is below this threshold. However, we adopt this policy voluntarily as a demonstration of our ethical commitment, and because our clients — particularly larger organisations — may require evidence of our modern slavery practices as part of their own compliance obligations.

1. Our Commitment

People Priorities has a zero-tolerance approach to modern slavery. We are committed to:

  • Acting ethically and with integrity in all business dealings and relationships
  • Implementing and enforcing effective systems and controls to prevent modern slavery in our operations and supply chain
  • Ensuring transparency in our approach to tackling modern slavery
  • Complying with all applicable laws in Australia, India and any other jurisdiction in which we operate
  • Supporting and empowering employees to raise concerns without fear of reprisal

2. What is Modern Slavery

Modern slavery is a serious crime and a gross violation of human rights. It encompasses a range of exploitative practices including:

PracticeDescription
Forced LabourWork or service extracted under threat of penalty, where the person has not offered themselves voluntarily
Human TraffickingRecruitment, transportation or harbouring of people by means of threat, force or deception for exploitation
Debt BondageA person forced to work to pay off a debt where the terms are unfair, unreasonable or not clearly defined
Deceptive RecruitmentRecruiting workers through false promises regarding the nature or conditions of work
Child LabourWork that deprives children of their childhood, potential and dignity — harmful to their physical and mental development
Slavery & ServitudeExercising powers of ownership over a person, including through debt or contract

3. Our Operations & Supply Chain

People Priorities operates across two entities:

  • People Priorities Pty Ltd — Australian operations, serving SMEs and global businesses with strategic HR consulting and workforce solutions
  • People Priorities India Pvt Ltd — Registered in Thane, Maharashtra; employs staff in India on behalf of client organisations as Employer of Record

Our supply chain is primarily service-based and includes professional service providers, technology vendors, payroll platforms, and HR software providers. We do not manufacture physical goods.

Given the nature of our work — particularly our Employer of Record services — we are acutely aware of the risks of labour exploitation in cross-border employment arrangements and take our responsibilities in this area seriously.

4. Risk Assessment

We recognise that certain aspects of our operations and supply chain carry higher inherent risk of modern slavery exposure:

  • Cross-border employment (India): Offshore recruitment and employment in India carries risk of deceptive recruitment, excessive recruitment fees, and exploitative working conditions. We mitigate this by directly employing all India-based staff through our registered Indian entity with full statutory compliance
  • Recruitment processes: We conduct or oversee recruitment activities and commit to ensuring no recruitment fees are charged to candidates at any stage
  • Third-party suppliers: We assess key suppliers for compliance with employment and labour standards before engagement

5. Due Diligence

To identify and address modern slavery risks, People Priorities commits to the following due diligence measures:

  • All employees are engaged under written employment contracts with clear terms, compliant with applicable Indian and Australian employment law
  • All wages are paid directly to employees — no deductions are made for recruitment or administrative fees
  • We conduct pre-engagement checks on new suppliers and service providers to assess their employment practices
  • We include modern slavery representations and warranties in supplier agreements where appropriate
  • We maintain a whistleblower channel through which employees and third parties can report concerns anonymously
  • We review our due diligence processes annually or following any material change in our operations or supply chain

6. Reporting Concerns

Any employee, contractor, supplier or client who has concerns about potential modern slavery in our operations or supply chain is encouraged to report this immediately to the HR Director at People Priorities.

Reports can be made by email to hello@peoplepriorities.com or directly to the HR Director. All reports will be treated confidentially and investigated promptly. Employees who raise concerns in good faith will not face any adverse consequences.

Modern slavery offences in Australia can also be reported to the Australian Federal Police or the Australian Border Force.

7. Training & Awareness

People Priorities will ensure that all employees receive awareness training on modern slavery as part of their induction, and refresher training annually. Employees involved in procurement, recruitment or supply chain management will receive additional targeted training.

8. Policy Review

This policy will be reviewed annually by the HR Director and updated as required to reflect changes in applicable law, our business operations, or best practice guidance.

Disclaimer: This policy has been prepared by People Priorities based on the Modern Slavery Act 2018 (Cth) and related guidance current as at June 2026. It does not constitute legal advice. People Priorities recommends seeking independent legal advice in relation to specific modern slavery compliance obligations.

Data Protection Policy  ·  People Priorities Pty Ltd & People Priorities India Pvt Ltd  ·  Version 1.0, June 2026

This policy governs how People Priorities collects, processes, stores, transfers and protects personal data in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Privacy Regulations 2025, and India's Digital Personal Data Protection Act 2023 (DPDP Act).

Scope: This policy applies to all personal data processed by People Priorities — including data relating to employees, clients, candidates, contractors and website visitors. It applies to all staff, contractors and third parties who handle personal data on our behalf. The Privacy Act 1988 (Cth) applies to organisations with annual turnover above AUD $3 million, and to those handling employee records regardless of turnover. People Priorities complies with the APPs as a matter of policy across all operations.

1. Overview & Governing Framework

People Priorities is committed to protecting the personal data of everyone we work with. We process personal data only for legitimate business purposes, and only to the extent necessary for those purposes.

JurisdictionGoverning Law
AustraliaPrivacy Act 1988 (Cth) & 13 Australian Privacy Principles (APPs); Privacy Regulations 2025; Notifiable Data Breaches (NDB) Scheme
IndiaDigital Personal Data Protection Act 2023 (DPDP Act); Information Technology Act 2000; IT (Reasonable Security Practices) Rules 2011

2. Categories of Personal Data We Hold

Employee & Candidate Data

  • Name, address, contact details, date of birth, nationality
  • Tax file number, bank account details, payroll information
  • Employment history, qualifications, references
  • Performance records, leave records, disciplinary records
  • Statutory identifiers (Aadhaar, PAN for Indian employees)
  • Emergency contact details

Client Data

  • Business contact details (name, email, phone, role)
  • Organisation details and engagement records
  • Financial and billing information
  • Data shared in the course of providing HR services

Website Visitor Data

  • Name, email, phone number and message content submitted via contact forms
  • IP address and browser data collected via standard server logs

3. Legal Basis for Processing

We process personal data on one or more of the following lawful bases:

BasisExamples
Contractual NecessityProcessing employee payroll; fulfilling client service agreements
Legal ObligationEPF/ESI contributions; tax reporting; Fair Work Act obligations
Legitimate InterestsBusiness development communications with existing contacts; fraud prevention
ConsentMarketing communications to new prospects; optional data collection on website

Sensitive personal data (health information, biometric data, financial data) is only processed with explicit consent or where strictly required by law.

4. How We Use Personal Data

We use personal data only for the purposes for which it was collected, which may include:

  • Employing and managing staff in India on behalf of client organisations (Employer of Record services)
  • Providing HR consulting, payroll processing and compliance services
  • Communicating with clients and candidates about our services
  • Meeting statutory obligations including tax, social security and employment law requirements
  • Conducting background checks (with candidate consent)
  • Improving our services and understanding our client needs

We do not sell, rent or trade personal data to third parties. We do not use personal data for automated decision-making that produces legal or similarly significant effects without human oversight.

5. Data Security

People Priorities implements technical and organisational measures proportionate to the risks posed by our processing activities, including:

  • Encrypted storage for all personal and sensitive data
  • Role-based access controls — data is accessible only to those with a legitimate business need
  • Secure communication channels (VPN, encrypted email) for transfer of sensitive data
  • Multi-factor authentication on all systems holding personal data
  • Regular security awareness training for all staff
  • Annual review of data security practices and systems

Employees must not store personal data on personal devices or personal cloud storage accounts. Any data breach or suspected breach must be reported to the HR Director immediately.

6. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law:

Data TypeRetention Period
Employee records (active)Duration of employment + 7 years
Payroll & tax records7 years (AU) / 8 years (India) from end of relevant financial year
Candidate records (unsuccessful)12 months from last contact
Client recordsDuration of engagement + 7 years
Website contact form data2 years from date of submission
CCTV (if applicable)30 days unless required for investigation

On expiry of the retention period, personal data is securely deleted or anonymised.

7. Cross-Border Data Transfers

Given the nature of our business, personal data is routinely transferred between Australia and India. We ensure such transfers are compliant with the APPs (APP 8 — cross-border disclosure) and the DPDP Act 2023.

Before transferring personal data internationally, we ensure that:

  • The recipient is subject to binding privacy obligations that offer comparable protection to Australian law
  • The individual has consented to the transfer where required
  • Appropriate data transfer agreements are in place between our entities
  • We remain accountable for any breach of the APPs by the overseas recipient

8. Individual Rights

Individuals whose data we hold have the following rights under the Privacy Act 1988 (Cth) and DPDP Act 2023:

RightHow to Exercise
AccessRequest a copy of personal data we hold about you
CorrectionRequest correction of inaccurate or incomplete personal data
Erasure (DPDP)Indian data principals may request erasure where data is no longer needed for original purpose
Withdraw ConsentWithdraw consent for non-essential processing at any time
ComplaintLodge a complaint with the OAIC (Australia) or Data Protection Board of India (India)

To exercise any of these rights, contact us at hello@peoplepriorities.com. We will respond within 30 days.

9. Notifiable Data Breaches

Under the Notifiable Data Breaches (NDB) Scheme (Part IIIC, Privacy Act 1988), we are required to notify the Office of the Australian Information Commissioner (OAIC) and affected individuals of any eligible data breach — that is, a breach that is likely to result in serious harm to individuals whose data is involved.

In the event of a suspected data breach, People Priorities will:

  • Contain the breach immediately and take steps to limit any ongoing exposure
  • Assess whether the breach is likely to cause serious harm within 30 days
  • Notify the OAIC and affected individuals as soon as practicable if the threshold is met
  • Document the breach, its cause and our response regardless of whether notification is required

Under the DPDP Act 2023, a personal data breach must also be reported to the Data Protection Board of India. We maintain an incident register for all data security events.

10. Contact & Complaints

If you have any questions about this policy or wish to exercise your rights, contact our HR Director at hello@peoplepriorities.com.

If you are not satisfied with our response, you may lodge a complaint with:

  • Australia: Office of the Australian Information Commissioner (OAIC) — oaic.gov.au  ·  1300 363 992
  • India: Data Protection Board of India — once established under the DPDP Act 2023

Disclaimer: This policy reflects the Privacy Act 1988 (Cth) including the Australian Privacy Principles, the Privacy Regulations 2025, and the DPDP Act 2023 as at June 2026. Data protection law is subject to change. People Priorities recommends seeking independent legal advice for specific compliance questions.

Privacy Policy  ·  peoplepriorities.com  ·  Version 1.0, June 2026

This Privacy Policy explains how People Priorities Pty Ltd (ABN pending) and People Priorities India Pvt Ltd collect, use, disclose and protect your personal information when you visit our website or engage our services. We are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Who We Are

People Priorities provides HR consulting, Employer of Record (EOR) services, and workforce solutions to businesses in Australia and globally. Our Indian operations are conducted through People Priorities India Pvt Ltd, registered in Thane, Maharashtra.

Contact: hello@peoplepriorities.com  |  peoplepriorities.com

2. Personal Information We Collect

We may collect the following categories of personal information depending on your relationship with us:

  • Website visitors: Name, email address, phone number, and any information you submit via our contact form
  • Prospective clients: Business name, role, contact details, and information about your HR needs shared in initial consultations
  • Clients: Contact details, business information, and employee data you share with us in the course of our services
  • Candidates & employees: Identity documents, employment history, qualifications, salary details, tax information, and statutory identifiers

We only collect personal information that is reasonably necessary for the conduct of our business. We do not collect sensitive information (health, racial or ethnic origin, religious beliefs, sexual orientation) unless strictly necessary and with your explicit consent.

3. How We Collect Personal Information

  • Directly from you — when you complete our contact form, email us, speak with us by phone or video call, or enter into a service agreement with us
  • From third parties — such as referees, background check providers (with your consent), or recruitment platforms
  • Automatically — standard web server logs may capture your IP address and browser information when you visit our website. We do not currently use tracking cookies or analytics platforms that collect personal data without consent

4. How We Use Your Personal Information

We use your personal information to:

  • Respond to your enquiries and provide the services you have requested
  • Provide HR consulting, EOR, payroll and compliance services
  • Communicate with you about your engagement with us — including service updates, invoicing and reporting
  • Meet our legal obligations including tax, payroll and statutory reporting requirements
  • Improve and develop our services based on feedback and usage patterns
  • Send you relevant updates or newsletters — only where you have opted in, and you can unsubscribe at any time

We will not use your personal information for any purpose that is incompatible with the purpose for which it was collected, without your consent.

5. Sharing Your Personal Information

We do not sell, rent, or trade your personal information. We may share personal information with:

  • People Priorities India Pvt Ltd — for cross-border EOR and HR services (with appropriate safeguards in place)
  • Payroll and HR technology providers — who process data on our behalf under binding confidentiality and data processing agreements
  • Government and statutory bodies — as required by law (e.g. tax authorities, EPF/ESI, Fair Work Commission)
  • Professional advisers — such as lawyers or accountants, bound by confidentiality obligations

Any third party with whom we share personal data is required to maintain equivalent data protection standards and to use the data only for the specified purpose.

6. Cookies & Website Tracking

Our website may use minimal, essential cookies required for the website to function correctly. We do not currently use advertising cookies, tracking pixels, or third-party analytics that collect personal data without your consent.

If we introduce analytics or tracking tools in future, we will update this policy and obtain appropriate consent in accordance with the Privacy Act 1988 and applicable requirements.

7. Your Rights

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

  • Access the personal information we hold about you
  • Correct personal information that is inaccurate, out of date or incomplete
  • Complain if you believe we have breached the APPs
  • Opt out of direct marketing communications at any time

To exercise any of these rights, email us at hello@peoplepriorities.com. We will respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.

8. How We Protect Your Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Our security measures include encrypted data storage, access controls, secure communication channels, and regular staff training on data handling obligations.

Despite these measures, no method of electronic transmission or storage is completely secure. If you have concerns about the security of information you have provided to us, please contact us immediately.

9. Third-Party Websites

Our website may contain links to third-party websites, including LinkedIn and other platforms. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies. This Privacy Policy applies only to People Priorities' website and services.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Where changes are material, we will notify existing clients by email. The current version is always available at peoplepriorities.com. This policy was last reviewed in June 2026.

11. Contact Us

For any questions about this Privacy Policy, to exercise your privacy rights, or to make a complaint, please contact:

DetailInformation
Contact NameHR Director, People Priorities
Emailhello@peoplepriorities.com
Websitepeoplepriorities.com
Response TimeWithin 30 days of receipt
Complaints (AU)Office of the Australian Information Commissioner — oaic.gov.au  |  1300 363 992

Disclaimer: This Privacy Policy has been prepared with reference to the Privacy Act 1988 (Cth), the Australian Privacy Principles and the Privacy Regulations 2025, current as at June 2026. Privacy law is subject to change. This document does not constitute legal advice — please seek independent legal advice for specific privacy compliance questions.

Remote Working Policy  ·  People Priorities India Pvt Ltd  ·  Version 1.0, June 2026

This Policy sets out the terms, conditions, rights and obligations of employees of People Priorities India Pvt Ltd who work remotely from their home offices in India while delivering services to clients based in Australia. It ensures compliance with all applicable Indian labour laws, a productive and safe remote working environment, data security, and consistent standards of conduct.

Document Information

Document TypeRemote Working Policy — Version 1.0
Issued ByPeople Priorities India Pvt Ltd
Registered OfficeThane, Maharashtra, India
Applicable ToAll employees hired in India under People Priorities India Pvt Ltd, working remotely from their home offices and servicing Australian clients
Governing LawsCode on Wages 2019 (w.e.f. Nov 2025) · Code on Social Security 2020 · Maharashtra Shops & Establishments Act 2017 (as amended Oct 2025) · IT Act 2000 · DPDP Act 2023
Approved ByHR Director — People Priorities
Effective DateJune 2026
Review CycleAnnual (or upon material change in applicable law)

1. Purpose & Scope

This Policy applies to all full-time, part-time and fixed-term employees of People Priorities India Pvt Ltd whose primary work location is their approved home office. It does not apply to independent contractors or consultants.

Legal Note: Remote work is fully lawful in India. Under the Draft Model Standing Orders (IR Code Rules 2025), work-from-home and virtual workplaces are formally recognised as valid employment arrangements. All statutory employee rights and protections remain unaffected by the remote work location.

2. Employment Terms & Applicable Jurisdiction

All employees are employed by People Priorities India Pvt Ltd, registered in Thane, Maharashtra. The following state-level laws apply in addition to central legislation:

  • Maharashtra Shops and Establishments Act 2017, as amended by the Ordinance effective 1 October 2025
  • Maharashtra Minimum Wages Act
  • Maharashtra State Professional Tax Act 1975

Cross-State Note: If an employee's home office is located in a state other than Maharashtra, the labour laws of that state will apply. This affects minimum wages, professional tax rates, and Shops Act entitlements.

Under the Labour Codes 2025, basic salary plus Dearness Allowance must constitute at least 50% of total CTC.

3. Working Hours & Availability

ParameterStatutory Limit (Maharashtra S&E Act 2017, as amended Oct 2025)
Maximum daily hours10 hours (excluding breaks)
Weekly hours cap48 hours per week
Daily spread-over12 hours maximum
Continuous work without break6 hours maximum; minimum 30-minute rest interval required
Weekly rest day1 day off per week (mandatory)
Overtime limit144 hours per quarter; paid at 2x standard wage rate
Overtime consentOvertime is not mandatory for employees

Given the IST/AEST time difference, employees may work morning shifts (6:30 AM–3:30 PM IST) or standard shifts (9:00 AM–6:00 PM IST). All shift arrangements are confirmed in writing and cannot be altered without reasonable notice and the employee's written consent.

Night Shift (Women Employees): Women employees may work between 9:30 PM and 7:30 AM IST only with written consent. The Company must provide adequate safety measures and transport reimbursement.

4. Statutory Entitlements & Benefits

Leave TypeEntitlementNotes
Earned / Privilege Leave18 days per yearAfter 240 days worked; min. 3 months service
Casual Leave8 days per yearCredited quarterly; lapses if unused; not encashable
Sick / Medical LeaveMin. 7 days (per contract)Certificate required beyond 2 consecutive days
Public HolidaysAs notified by Maharashtra GovtList provided at start of year
Maternity Leave26 weeks (first 2 children)12 weeks for 3rd child onwards; 10+ employees

Statutory Contributions: EPF (12%/12% employee/employer), ESI (0.75%/3.25%), Professional Tax (up to ₹2,500/year), Gratuity (15 days wages per completed year), TDS (per IT Act slabs), Labour Welfare Fund (₹12/₹24 per month).

5. Home Office Setup & Requirements

The employee's home office address in their employment contract is the approved work location. Changes require 14 days' written notice to HR and Company approval.

  • Dedicated, private workspace free from background noise during client calls
  • Reliable internet connection (minimum 20 Mbps recommended)
  • Adequate lighting, ventilation and ergonomic desk and chair
  • Screen protected from view by unauthorised persons

The Company will provide a Company-owned laptop, licensed software (including VPN), and headset. A monthly connectivity allowance may be provided as agreed in the employment contract.

6. Data Security & Confidentiality

Employees must comply with the IT Act 2000 and DPDP Act 2023. Obligations include:

  • Use only Company-approved, encrypted devices and storage systems
  • Access client systems exclusively via the Company-issued VPN
  • Never store client or personal data on personal devices or cloud accounts
  • Lock device screen when stepping away from the workspace
  • Report any actual or suspected data breach within 72 hours of becoming aware
  • Never share login credentials or access tokens with any other person

All client information, business strategies, pricing, HR data and internal communications are strictly confidential. Confidentiality obligations survive the termination of employment.

7. Performance Management & Conduct

Remote employees are held to the same performance standards as office-based employees, managed through clear KPIs, fortnightly check-ins and formal performance reviews. Employees must:

  • Be professional in appearance and conduct during video calls
  • Accurately maintain time and attendance records
  • Not represent themselves as being based in Australia or as employees of any Australian entity
  • Not allow personal obligations to impede availability during agreed working hours

8. Termination & Notice

Notice PeriodAs per contract; minimum 30 days. Payment in lieu of notice is permitted.
Full & Final SettlementWithin 2 working days of last working day (Code on Wages 2019)
GratuityAfter 5 continuous years (1 year for fixed-term under Labour Codes 2025)
Return of EquipmentAll Company equipment returned by last working day
Access RevocationAll system access revoked on last working day
Relieving LetterIssued within 5 working days of full and final settlement

9. Grievance Redressal & POSH

Employees may raise grievances directly with their manager, in writing to HR, or escalate to the HR Director if unresolved within 10 working days. All grievances acknowledged within 3 working days.

The POSH Act 2013 applies fully to remote workplaces, including virtual interactions, video calls, emails and messaging platforms. An Internal Complaints Committee (ICC) has been constituted. Annual POSH awareness training is mandatory.

10. Employee Acknowledgement

Acknowledgement Required: All employees are required to sign and return the Employee Acknowledgement Form upon commencement of employment and upon each material update to this Policy. The form captures: full name, employee ID, designation, home office address, state of residence, and signature with date.

Disclaimer: This policy reflects Indian labour laws current as at June 2026, including the four Labour Codes (in force November 2025) and the Maharashtra S&E Amendment Ordinance (October 2025). This document does not constitute legal advice. People Priorities recommends review by a qualified Indian employment lawyer admitted to practice in Maharashtra before formal adoption.

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