APM Privacy Policy

Privacy Policy Statement

This policy applies to APM Human Services International Ltd, and all of its Australian subsidiaries (APM).  To the extent a subsidiary has a specific and more detailed privacy policy pertinent to its operations, then this will apply to the extent of any inconsistency.

APM’s collection, use, disclosure and storage of your personal information is regulated by the Privacy Act 1988 (Cth), the Australian Privacy Principles and related legislation.

Updates to this Privacy Policy will be published on our website.
 
If you have any questions regarding this Policy or our privacy practices generally, please do not hesitate to contact our Privacy Officer at privacy@apm.net.au.

Purpose

The purpose of this Privacy Policy is to:

  • Give you an understanding of the kinds of personal information that we collect and hold.
  • Communicate how and when your personal information is collected, disclosed, used, held and otherwise handled by us.
  • Inform you about the purposes for which we collect, hold, use and disclose personal information.
  • Provide you with information about how you may access your personal information and seek correction of your personal information.
  • Provide you with information about how you may make a complaint, and how we will deal with any such complaint.

What is personal information?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. It includes your name, date of birth / age, gender and contact details as well as health information (which is also sensitive information). In this privacy policy, a reference to personal information includes sensitive / health information.

Collection of personal information

Personal information collected by us will usually fall into one of the following categories:

  • Contact information (name, age, address, email address and telephone numbers).
  • Commonwealth identifiers (e.g. CRN, TFN).
  • Employment information (e.g. employment history, work performance, absences, workplace incidents, next of kin information).
  • Financial information (e.g. bank account details).
  • Sensitive information (e.g. information about your health, medical history, criminal history, religious beliefs, trade union activity).
  • Information obtained to assist in managing client and business relationships.

We may collect your information from you in a variety of ways including when:

  • We provide services to you;
  • You visit our website;
  • You submit your information in response to APM marketing events or activities; or
  • You contact us by any method, such as face-to-face, over the telephone, through an online form or portal, through a paper form or by email.

Sometimes we will collect personal information from a third party or a publicly available source, for example where we have your consent, where we are required by law to do so, or if it is unreasonable or impracticable to collect the personal information directly from you (e.g. checking a candidate’s work history).

You may choose to deal with us anonymously or under a pseudonym. However, in some circumstances, anonymity or the use of a pseudonym will render us unable to provide the relevant service or reasonably conduct our business, and we may request that you identify yourself. For example, it would not be practical to deal with you anonymously if we are providing assistance in securing paid employment for or providing rehabilitative services to you.

You may also choose not to provide us with your personal information.  Depending on the circumstances in which you do so, however, we may be unable to provide you with our services as a result.

Where we are collecting personal information from a child or young person, we will use our judgement to determine if that person has the capacity to consent.  Where we are unsure, we will seek consent from a parent or guardian.

Why do we collect, use and store your personal information?

We collect, use and store your personal information to provide you with our services which include:

  • Recruitment / employment services
  • Employee management
  • Injury management and assessment
  • Labour market research
  • Ergonomic assessments and advice
  • Occupational safety and health
  • Psychological assessments / counselling
  • Insurance claims and assessments
  • Training / education
  • Research
  • Services under the National Disability Insurance Scheme.
  • Client and business relationship management.

We may also collect, use and store your personal information: 

  • For marketing purposes, in order to provide you information about the services we offer;
  • To respond to your questions or suggestions;
  • To improve the quality of our services; or
  • To improve the quality of your visit to our website. 

You may opt out of receiving marketing information by notifying us accordingly, or by using any unsubscribe facility we provide for that purpose.  If you opt out of receiving marketing information, we may still contact you in connection with the services we provide to you, such as for appointment reminders and follow-ups.

Our services, functions and activities, as well as those of our contracted service providers, may change from time to time.

Protecting and storing your personal information

We understand the importance of keeping personal information secure and safe. Some of the ways we do this are:

  • Requiring employees and contractors to enter into confidentiality agreements;
  • Securing hard copy document storage (i.e. storing hard copy documents in locked filing cabinets);
  • Implementing security measures for access to computer systems to protect information from unauthorised access, modification or disclosure and loss, misuse and interference;
  • Ensuring data storage devices such as laptops, tablets and smart phones are password protected;
  • Providing discreet environments for confidential discussions;
  • Implementing access control for our buildings including waiting room / reception protocols and measures for securing the premises when unattended; and
  • Implementing security measures for our website(s).

Personal information may be stored in documentary form but will generally be stored electronically on our software or systems.

Who will we disclose your personal information to?

Like most businesses in Australia, we contract out some of our functions and rely on third party suppliers or contractors to help us conduct our business, for example to provide specialised services such as employment services, “cloud computing” technology and data storage services, legal advice, insurance broking, security services, business advisors and financial services. We may disclose personal information to these third parties in connection with their provision of goods or services to us.

We may also disclose your personal information to other related entities within our corporate group for our own business purposes.

We may also disclose your personal information to government agencies, private sector organisations or other entities where required or permitted by law, which may include the following circumstances:

  • You have consented to such disclosure.
  • We believe that you would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies, and it is being disclosed for a purpose related (or directly related, in the case of sensitive information) to the reason we collected the information.
  • We are required or authorised to make such disclosure by law or the requirements of any professional bodies, including where we are required to do so in accordance with child safety obligations.
  • A permitted general situation or permitted health situation (as these terms are defined in the Privacy Act) exists in relation to the disclosure.
  • We believe it is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. police, ASIC, Immigration Department).

The persons to whom we disclose personal information are normally located in Australia, although personal information related to our staff and for our marketing activities may be disclosed to recipients outside Australia, including to recipients located in countries where APM has offices.

Client personal information collected and stored in respect of any applicable Australian Government contract such as jobactive, Workforce Australia, Transition to Work, Disability Employment Services, ParentsNext, NDIS Local Area Coordinator, as well as applicable Workcover contracts, will not be stored in an offshore cloud host service or transferred outside of Australia.

Accuracy of Personal Information

We take steps to help ensure that all personal information we collect, use or disclose is accurate, complete and up to date. Please contact our Privacy Officer (details below) if you are aware that personal information that we hold about you does not meet this objective.

How can I access my personal information and contact APM?

You can request access to personal information that we hold about you.

The procedure for requesting and obtaining access is as follows:

  • All requests for access to personal information to be made in writing and addressed to our Privacy Officer (see contact details below). All requests should specify how the information is proposed to be accessed (photocopies, electronic copy, or visual sighting).
  • Please provide as much detail as possible regarding the APM business, department and / or person to whom you believe your personal information has been provided and when. This will allow us to process your request more efficiently.
  • We will endeavour to acknowledge your request within 14 days of the request being made.
  • Access will usually be granted within 30 days of our acknowledgment. If the request cannot be processed within that time for whatever reason, we will let you know the anticipated timeframe for a response to be provided.
  • You will need to verify your identity and authority before access to personal information is granted.
  • We may charge a reasonable fee for access to personal information, which will be notified and required to be paid prior to the release of any information. Once the request has been processed by us, you will be notified of our response and proposal for suitable access (provision of photocopies, digital copies or visual sighting, where appropriate).
  • We may refuse to grant access to personal information if there is an exception to such disclosure which applies under relevant privacy legislation.
  • If, as a result of access being granted, you are aware that we hold personal information that you regard as being no longer accurate or correct, you may request the deletion or correction of such information.
  • Upon receipt of a request to correct or delete personal information, we will either make such corrections or deletions or provide written reasons as to why we declined to make such alterations (see below). 

We have a designated Privacy Officer who is responsible for the management of:

  • Requests for access to personal information.
  • Complaints regarding our management of personal information.

For information regarding privacy, our Privacy Officer can be contacted at:

APM Privacy Officer
 
L21, 324 Queen Street
Brisbane, QLD 4000
Facsimile (07) 3229 1577

privacy@apm.net.au
(07) 3055 5500

How do we handle complaints?

If you consider that there has been a breach of the Australian Privacy Principles, you are entitled to complain to APM.

All complaints are to be in writing and directed to the Privacy Officer using the contact details above. In most cases, a Privacy Complaint Form will need to be completed. The Privacy Officer will endeavour to acknowledge receipt of a written complaint within 2 business days.

The Privacy Officer will investigate the complaint and attempt to resolve it within 20 business days after the written complaint was received. Where it is anticipated that this timeframe is not achievable, we will contact the person making the complaint to provide an estimate of how long it will take to investigate and respond to it.

If you are unsatisfied with the outcome of APM’s investigation and decision, you are entitled to raise your complaint with the Office of the Australian Information Commissioner (OAIC) by phoning 1300 363 992 or by email at enquiries@oaic.gov.au

Communications and Marketing Policy

We communicate with users who subscribe to our services on a regular basis via email, and we may also communicate by phone or SMS. We may use your email address and phone number to (i) confirm your information(ii) send notices and other disclosures as required by law or (iii) advise you of programs you are formally registered with and/or (iv) provide information about the services we provide. Generally, users cannot opt out of these communications, which are not marketing related but merely required for the relevant business relationship.

We may also collect, use and store your personal information for marketing purposes in order to inform you of the services we offer. Part of delivering a high quality, personalised digital experience is recognising who we're talking to, so we can provide the services that you want from us. To do that, we may need to request and store some of your personal information. We know your privacy is vital, so these details will only ever be used in accordance with the terms of this Privacy Policy.

APM may also use your personal information for the purpose of marketing its services. 

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 the communication or
  • for hard copy communications, you can email support@apm.com.au
Cookies and other technologies are used by APM on APM’s website and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience (including tailored APM marketing), improve the performance, usability and effectiveness of APM’s online presence and to measure the effectiveness of our marketing activities.

If you register or log into an APM website or social media or advertising site and provide personal information, we will use your information to personalise your user experience. If you register or log into an APM website using a third-party account (such as LinkedIn, Google or Twitter), we may collect personal information you have permitted the third-party service to share, including your name and email address, depending on the privacy settings you have set with the third-party service and their privacy policy.


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 website trend and performance analysis, and to personalise your user experience.


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.

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 website’s 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 website and geographic origin of visitor trends, and not to identify individual visitors.


Analytics Tools

APM uses analytics tools, such as Google Analytics. Reports obtained from Google Analytics are used to help improve the efficiency and usability of this website.

Google Analytics uses first-party cookies and JavaScript code to gather statistics about how the APM website is accessed. It anonymously tracks how our visitors interact with our website, including where they came from, what they did on the site including such things as news registration.  No personal information is collected or stored by APM or Google.  The information generated by the cookie and JavaScript code about your use of the website (including your IP address) will be transmitted to and stored by Google on servers located outside Australia. Google is based in the United States of America (USA). Should you wish to contact Google, you can find contact details on Google's Contact us page.

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

By using our website, you consent to the processing of data about you by Google in the manner described in Google's Privacy Policy and for the purposes set out above. Relevant legislation of the USA will apply. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.


Google Tag Manager

We use Google Tag Manager, a digital marketing service provided by Google Inc. (“Google”). Reports obtained from Google Tag Manager are used to help improve the efficiency and usability of the website by measuring traffic and visitor behaviour to the business.gov.au website.

Google Tag Manager uses tags which are tiny bits of website code that allow us to measure traffic and visitor behaviour, understand the impact of online advertising and social channels, use remarketing and audience targeting, test and improve our site. Google Tag Manager keeps track of a set of tags and tag-firing rules, but it does not collect any personally identifiable information. When a user visits the site, the most up-to-date tag configuration is sent over to the end-user’s browser with instructions to fire appropriate tags. The information generated about your use of the website (including your IP address) will be transmitted to and stored by Google on servers located outside Australia. Google is based in the United States of America (USA). Should you wish to contact Google, you can find contact details on Google's Contact us page.

By using our website, you consent to the processing of data about you by Google in the manner prescribed by Google’s Privacy Policy and for the purpose set out above. Relevant legislation of the USA will apply. You can opt out of Google Analytics if you disable cookies, JavaScript, or use the opt-out service provided by Google.


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 the content was viewed, a browser type, and the existence of cookies previously set by the same server.

APM or its service providers may use web beacons to track the effectiveness of third party website 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.


Location-based tools

APM 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.


Social media widgets and applications

APM’s website may include functionality to enable 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 APM’s website. Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, APM’s website may host 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 APM 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.


Links to third party websites

APM’s websites may contain links to third parties’ websites, including sites maintained by other APM member firms. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of their privacy policy.

APM also does not endorse, approve or recommend the services or products provided on third party websites.


Your choices

You have several choices regarding your use of APM’s website. In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, register for services, events and updates or wish to apply for a job, provision of certain personal information will generally be required.

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 the communication or
  • for hard copy communications, you can email support@apm.com.au

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