IT Privacy Policy

Last updated: 6 February 2025 · POL-IT-0423 · Rev 1.1

1. Introduction

APD Global is committed to protecting the privacy of our employees, clients, contractors, and other stakeholders.

The types of information APD Global collects include, but is not limited to:

• Names, job titles, contact and address details
• Email addresses
• Client information including address, postcode, ABN or ACN
• Bank account details
• Credit Card information
• IP addresses
• Certificates, licenses, and qualifications
• Contracts and Invoice details

2. How we collect & manage personal information

2.1. How we collect personal information

Generally, APD Global collects personal information via a direct request, questionnaire, form, or survey or when you subscribe to our publications, when you use our website or our social media.

Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from your employer where they are our client, from your personal representative, or a publicly available record.

We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites.

2.2. Where you provide us with personal information about someone else

If you provide us with someone else's personal information, you should only do so if you have their authority or consent to provide us with that information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

2.3. Holding personal information

APD Global holds personal information in both hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example, security passes to enter our offices and storage of files in lockable cabinets) and technological (for example, restriction of access, firewalls, two factor authentication, the use of encryption, passwords, and digital certificates).

APD Global may also store, process or back-up your personal information on servers that are in Australia (including through third party service providers).

We also have policies and processes which govern data retention and data breach incidents. In some cases, APD Global engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.

2.4. Purpose for collecting, holding, using & disclosing personal information

APD Global collects, holds, and uses personal information for a number of purposes including:

• to provide and enhance our services
• to respond to requests or queries
• to maintain contact with our clients and other contacts, and keep them informed of our services, industry developments, seminars, and other events
• to verify your identity
• for administrative purposes, including processing payment transactions
• for seeking your feedback
• to meet any regulatory obligations
• As part of an engagement, if you are a customer, an employee, a contractor, or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client.

3. Security

APD Global strives to ensure the security, integrity, and privacy of personal information. We will take all reasonable steps to protect the personal information you may transmit to us. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

Specific security measures APD Global undertakes to ensure the security of personal information includes:

• Two Factor Authentication (2FA) Protections on APD Global systems and networks
• 24 x 7 Monitoring by Security Operations Centre of all logs and systems
• Data at rest encryption for all systems containing client information
• Isolated network and infrastructure for all encrypted backup data
• Stringent cyber security breach policies and processes for employees

4. Direct marketing

APD Global may use your personal information for the purpose of marketing its services to you. If you do not want to receive marketing material from us, you can contact us as detailed below:

• for electronic communications, you can click on the unsubscribe function in communications; or
• through our contact us page on our website.

5. Privacy on our websites

5.1. Automatic collection of personal information

Cookies, web beacons and other technologies are used by APD Global and its service providers on some APD Global websites and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience (including tailored APD Global marketing), to improve the performance, usability and effectiveness of APD Global's online presence and to measure the effectiveness of our marketing activities.

5.1.1. IP address

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another.

Public IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis, and to enhance user experiences.

5.1.2. Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu).

You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites' features.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including public IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends and is not used to identify individual visitors.

Cookies on this website (apdspace.com)

This website is designed to be privacy-friendly. We do not use analytics, advertising, or tracking cookies on it, and fonts are self-hosted (no data is sent to font CDNs). The only cookies that may be set are:

• Strictly necessary — cc_cookie. We use this single cookie to remember your cookie preference so we don't ask you again on every visit. It is set regardless of your choice — it is required for the consent mechanism itself to work and does not require consent.
• Embedded media (YouTube) — only if you accept. Some pages have background/embedded videos hosted on YouTube in privacy-enhanced mode (youtube-nocookie.com). These only load, and only set cookies, if you accept the "Embedded media" category in the cookie banner shown on your first visit. Because the videos autoplay, Google then sets cookies as soon as they load — including VISITOR_INFO1_LIVE, YSC, __Secure-YNID, __Secure-ROLLOUT_TOKEN, and VISITOR_PRIVACY_METADATA — and your IP address is sent to Google to deliver the video. If you decline or haven't yet decided, no video loads and a static image is shown instead, so no data is sent to Google and no cookies are set. These cookies are set by Google, not by us; review Google's cookie practices.

You can change your cookie choice at any time using the "Cookie Preferences" link in the site footer, or by clearing your browser's cookies (you'll be asked again on your next visit).

5.1.3. Analytics tools

APD Global uses analytics tools, such as Google Analytics and Adobe Analytics. To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on.

The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics.

The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

5.1.4. Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer such as an IP address, the time that content was viewed, a browser type, and the existence of cookies previously set by the same server.

APD Global or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

5.1.5. Location-based tools

APD Global may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

5.1.6. Social media widgets & applications

Some APD Global websites and services may include functionality to enable information sharing via third party social media applications, such as the Facebook Like button and Twitter widget.

These social media applications may collect and use information regarding your use of APD Global websites. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to APD Global.

Such interactions that are monitored by social media applications are governed by the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, APD Global websites or affiliate websites may host blogs, forums, crowd-sourcing and other applications, or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content.

Any personal information that you provide on any APD Global social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

5.2. Links to third party websites

APD Global websites may contain links to third parties' websites. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of the relevant privacy policy.

Unless expressly advised, APD Global does not endorse, approve, or recommend the services or products provided on third party websites.

5.3. Your choices

You have several choices regarding your use of APD Global websites. In general, you are not required to provide personal information when you visit our websites. However, if you make an enquiry or subscribe to receive information about our services, events and industry updates or wish to apply for a job, provision of certain personal information will generally be required to facilitate such requests.

6. Individual's right of access

Individuals have the right to request and review the information that may be recorded by the company. Such request must be made in writing to APD Global and is subject to some limited exceptions as permitted or required by law.

7. Complaints

If you wish to make a complaint to APD Global about our handling of your personal information, you can contact APD Global as set out in 'How to contact us'. Following your initial contact, you will be asked to set out the details of your complaint in writing.

APD Global will endeavour to reply to you within 30 days of receipt of the completed complaint and, where appropriate, will advise you of the general reasons for the outcome of the complaint.

In some circumstances, APD Global may decline to investigate the complaint (for example if the complaint relates to an act or practice that is not an interference with the privacy of the person making the complaint).

If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.

8. Responsibilities

8.1. Employees

• All Employees are responsible for reading, understanding, and acknowledging this policy
• All Employees are responsible for referring to this policy or seeking assistance from their Manager, if they are unclear of any part of this policy, prior to acting
• All Employees are responsible for alerting their Manager to a breach or potential breach of this policy

8.2. Manager responsibilities

• Managers are responsible for ensuring their Employees understand this policy and directing them to this policy, when required.

8.3. Corporate Services Manager responsibilities

• The APD Global Corporate Services Manager, is responsible for reviewing and updating this policy, communicating any changes to APD Global and where necessary, providing training to employees around the content of this policy
• The APD Global Corporate Services Manager is responsible for investigating a breach to this policy and providing this information to the Managing Director for management

9. Breaches

Any breach of this policy will be regarded as a serious breach and may result in disciplinary action up to and including termination of employment.

10. How to contact us

If you have a query in relation to this Privacy Policy, or would like to notify APD Global that you:

• no longer wish to receive marketing material from us,
• wish to want to access or correct your personal information, or
• wish to make a complaint about APD Global's handling of your personal information.

Please contact us as follows:

For further information or to provide feedback, please contact our HSEQ Team at hseq@apdglobal.com.

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