Australia Privacy Policy

PURPOSE
To define Abt Global policies in regard to the privacy and treatment of personal information.

SCOPE
This Policy applies to Abt Global Australia group of companies including Abt Global Australia Pty Ltd and its subsidiaries (referred to as ‘Abt Global’s for the purpose of this Policy). This Policy does not apply to “employee records” which are defined in the Privacy Act 1988 Cth as records of personal information relating to the employment of an employee.

BACKGROUND
Abt Global (we, our, us) in its day to day business considers, collects, deals with and stores personal information from consultants, advisers, prospective employees and other individuals we do business with (you, your) across its numerous programs in Australia and abroad. In doing so, we are committed to protecting your privacy and personal information. This commitment is demonstrated through the implementation of this Policy.

PERSONAL INFORMATION PRIVACY POLICY

1. Abt Global and Privacy
We recognise your rights in relation to privacy under the Australian Privacy Principles (APPs) (1.) and consider your privacy a serious and important part of conducting our business. For that reason we place great emphasis on complying with our obligations under the APPs as these relate to the collection, management and disclosure of your personal information.

2. Terminology
The term personal information used in this Policy has the same meaning as provided in the Act. In general terms, it is the information that can be used to personally identify you. Sensitive Information, also used here with the same meaning as provided under the Act, is a subset of personal information that is considered sensitive by nature, for example medical records and information relating to racial or ethnic origin.

3. Collection of your personal information
We collect your personal information where the information is reasonably necessary to perform a function to progress our commercial business activities. The types of personal information we may collect include (but are not limited to):

• Name and gender
• Date of Birth
• Postal Address
• Telephone or facsimile number
• Email address
• Occupation, references and previous employment history, qualifications and skills
• Relationship or marital status
• Names of family members or next of kin
• Information provided by you through our website.

Personal information will be collected using lawful means and may be collected in a variety of ways, including:

• Applications submitted by you or responses to employment advertisements
• Enquiries made by you through our websites
• When you register or subscribe to our mailing lists
• Through government agencies or third party employment services companies
• Through direct contact between you and our staff – for example: email, mail, by telephone and direct meeting.

Privacy Consent form

Before engaging in business with us you are required to review and sign the Abt Global Privacy Consent Form to indicate your understanding of this Policy and agreement with its provisions in regards to the collection and management of personal information.

Use of cookies

We use “cookies” on our website to enhance the experience of our visitors, such as retaining user preferences between sessions. In some circumstances we may collect your personal information via our website and through the use of cookies. A cookie is a small text file that is stored on your computer. Information collected may include your Internet Protocol or IP addresses, type of browser that you use, and other technical data about your computing environment. This information is stored in server logs that we maintain and review for the purpose of improving and supporting the secure operation of our website.
Cookies cannot be used to deliver viruses to your computer, they are uniquely assigned to you, and our cookies can only be read by our web servers. You have the ability to accept or decline cookies or, if you prefer, you can modify your web browser settings to decline all cookies or selectively decline cookies as they are offered. Our website may contain links to other websites. You should carefully review the privacy notices and practices of other websites, as we cannot control or be responsible for the privacy practices of sites not affiliated with Abt Global.

4. Storage of your personal information

We will store your personal information in both physical and electronic forms. We will take reasonable steps to ensure that all information collected from you is stored in a secure environment accessible only by our authorised personnel.
We will endeavour to protect any personal information transmitted by you or received from us over the Internet, however we cannot ensure or warrant the security of this information. These activities are conducted at your own risk. Once we receive your transmission, we will take reasonable steps to ensure its security.

5. Use and disclosure of your personal information

We collect, hold and use personal information about you for purposes including:
• Provision of services to you
• Responding to enquiries
• Assessing your suitability for potential employment or contracting
• Submission of documents to our clients including expressions of interest, capability statements and tenders
• Compliance with an Australian law, court/tribunal order or enforcement related activities.
We may disclose personal information that we collect from you for the purpose that it was collected. We may disclose the information for other purposes where we have received your consent to do so or are required to do so by law.
Examples of where we may disclose your information include, but are not limited to:
• Employees and contractors within our group of companies and our external providers
• Clients, potential clients, insurers, solicitors, accountants and others where we have a commercial relationship in place
• Government departments and agencies.
We will take reasonable steps to ensure that the personal information we use or disclose is accurate, up to date, complete and relevant to the purpose of the use or disclosure.

6. Sensitive information

We may need to collect sensitive information such as health information or your membership of a professional association. We will not collect this information without providing you with a purpose for collection and obtaining your consent. All sensitive information collected by us will be dealt with strictly in accordance with the requirements of the Act.

7. Unsolicited personal information

If we receive unsolicited personal information we will make a determination whether the information is reasonably necessary for, or directly related to our functions or activities. If it is, we will ensure that the information is stored in the same manner as if we received the information directly from you. If we find that it is not, we will destroy or de-identify the information.

8. Disclosure of your personal information outside Australia

We are a global company and may disclose your personal information to our related bodies corporate, employees, suppliers and services providers located overseas for the purposes listed above. When doing so we will take reasonable steps to ensure that the overseas recipients do not breach the privacy obligations relating to your personal information.
We may disclose your information to our external IT and data providers and centres located in and outside of Australia including but not limited to the following:

▪ our related bodies corporate, located in the United States of America, Papua New Guinea, Philippines, United Kingdom, East Timor, Indonesia, Vietnam and Myanmar.
▪ our data hosting and other IT service providers located in Australia, the US and program locations.

9. Your option not to provide personal information

You may not wish to provide us with your personal information. However, in this circumstance we may be unable to assist you through answering your query and may not be able to do business with you.

10. Access to and correction of your Personal Information

You may request access to your personal information that we hold, and we will attempt to accommodate your request. However, there may be instances where we cannot provide you with the requested information. For example, we may need to refuse such if providing the information to you would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
We may charge you reasonable costs in relation to making this information available to you.
You may request us to correct the personal information we hold if you believe that the information is inaccurate, out of date, incomplete, irrelevant or misleading. In such cases we will consider if the information requires amendment based on the documentary evidence you provide. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
Requests to access or amend personal information we hold in relation to you should be directed to the contact details outlined below.

11. Contact and Complaints about breach of privacy

If you would like further information on our policy, or if you believe that your privacy has been breached by us, you may wish to contact our Privacy Officer at the details stated below.

Privacy Officer
Abt Global
Level 2, 5 Gardner Close
Milton, Brisbane QLD 4000

Email: privacy@abtassoc.com.au
Web: www.abtglobal.com.au

If raising a complaint please provide us with sufficient detail of the incident to assist us with the investigation along with your contact details. We will acknowledge receipt of your complaint. We will investigate the matter and will advise you of the outcome usually in writing.

If you are unsatisfied with the outcome you may wish to contact the Office of the Australian Information Commissioner with details as follows:

GPO Box 5218
Sydney NSW 2001; or
GPO Box 2999
Canberra ACT 2601

Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Web: www.oaic.gov.au

12. Changes to our Policy
We may review and amend our Policy from time to time. Any updated versions of this Privacy Policy will be posted on our website and it is your responsibility to check our website for any updated policy versions.

Footnotes

1. See Australian Privacy Principles (APPs), as enacted 12 March 2014 and contained in schedule 1 of the Privacy Act 1988 (Cth): https://www.oaic.gov.au/individuals/privacy-fact-sheets/general/privacy-fact-sheet-17-australian-privacy-principles