This Privacy Policy outlines how GHD1 and its related entities and affiliates (collectively “GHD”) collects, uses and stores personal information in the course of its business from employees, applicants for employment, contractors, clients, suppliers and other individuals (referred to as “you” or “your” in this Privacy Policy).
GHD respects and upholds your right to privacy protection. GHD recognises applicable local laws and regulations and relevant data protection standards in respect of the collection, use, disclosure storage and transfer of personal information from individuals.
This Privacy Policy details the practices we have adopted to protect your privacy so that you can understand how we manage your “personal information”, any “personally identifiable information” or “personal data” (as defined under the European Union's General Data Protection Regulation or “GDPR”) (together collectively referred to as “personal information” in this Privacy Policy), you entrust to us.
This Privacy Policy also sets out how you can contact us in relation to your personal information and, if requested by you, opt-out of this Privacy Policy, limit the use of, or amend, any personal information we may have about you.
By providing us with personal information about yourself through our website, any GHD webpage or otherwise, you consent to the collection, use, disclosure, storage and transfer of that personal information as set out in this Policy. If at any time, you wish to withdraw your consent to the collection, use, disclosure, storage and transfer of your personal information in accordance with our Privacy Policy, you may opt-out by contacting us (refer to the Contact Us information below) or by immediately ceasing to provide any further personal information about yourself to GHD via its website or otherwise.
COVID-19 Response
In the interest of protecting our employee’s health and discharging our duty of care to invitees to our premises, GHD may, during the COVID-19 Pandemic, collect and use additional sensitive personal information from our employees and visitors [to be specified if possible, e.g. such as whether they have flu-like symptoms, have been in contact with anyone infected with COVID-19, or travelled to a high-risk area]. Only the minimum necessary personal information reasonably necessary in order to prevent or manage COVID-19 in the workplace will be collected, used or disclosed. It will be managed in accordance with this policy and it will only be disclosed to the persons who need to have access to such personal information for the performance of their duties. The primary purpose for collection of that additional information is to ensure that necessary precautions are adopted in relation to that individual and any other individuals. Under most jurisdictions an exemption from any requirement for consent to collect and use is permitted in circumstances of serious threat to health or safety of an individual. GHD will comply with an specific COVID-19 guidance issued by a relevant regulator.
Overview of this Policy
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1. When do we collect and store personal information? |
| Personal information is any information that can be used to identify you (either directly or indirectly), and may be collected directly from you, by a third party you have given consent to disclosing your personal information, or by a credit agency, government or statutory body.
We collect and store personal information (including names, telephone numbers, address, email address, occupation, education and qualifications, etc) in a range of contexts, such as:
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2. What do we do with personal information? |
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We may use your personal information:
As an example, one of the key objectives of GHD’s website is to provide information about who we are, what we do and our local and global professional capabilities. We may collect personal information to update our website and in order to provide relevant information about GHD, our services, our key people in our regions or our capabilities in a variety of contexts. |
| 3. Reasons we may share or disclose your personal information |
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Whilst at all times complying with this Privacy Policy and having primary regard for the protection of your personal information, GHD may share or disclose your personal information in a number of circumstances, such as:
Some examples:
GHD employee personal information and employment/personnel records are stored securely and used in the jurisdiction in which it is collected and relevant to the particular GHD employee. If we disclose your personal information to an office in a country other than the country in which it is collected, we will take all reasonable steps to ensure a level of data protection at least as protective of that required in the European Union's GDPR, which offers high levels of personal information protection. We will also require any GHD employees, subcontractors or agents who are outside your jurisdiction and to whom we transfer information about you to ensure a similar level of data protection as required by the European Union's GDPR when it comes to protecting your personal information. GHD will not use, share or disclose your personal information that was collected for a particular purpose for another secondary purpose (which you would not reasonably expect) without your consent unless we are required or authorised by law, or compelled for legitimate legal reasons by government authority or law enforcement agency. GHD must seek additional consent from you to use or retain your personal information other than as set out in this Privacy Policy and you have the choice to opt-out at all times by contacting us (as outlined below). Your personal information is never shared, sold, rented or otherwise disclosed except if required by law or with your consent. |
| 4. Marketing and communications |
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GHD is driven by a client-service led culture. For this reason, we may send marketing material or communicate information that we think may be relevant or of interest to you or your industry or provide you with details about our latest services that you may benefit from. 4.01 California residents and direct marketing |
| 5. How do we use "cookies", "log files", data analytics and other similar technology? |
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5.01 Cookies You may disable cookies by changing the settings on your browser – please refer to your browser options or instructional material. If you disable cookies, it is likely to affect how your browser works. For more information on cookies visit: www.allaboutcookies.org. 5.02 Log files A log file or log is the automatically produced and time-stamped documentation of events relevant to a particular system. From the server’s log files, an administrator can identify numbers of visitors, the domains from which they are visiting, the number of requests for each page and usage patterns. 5.03 Data analytics (such as Google Analytics™) and other technologies The GHD website located at http://www.ghd.com uses log files and Google Analytics™. We may collect and use data relating to the geographical location of your computer or mobile internet device. We use this to provide country and region-specific information. This information collected is not “personal information” and you cannot be identified from its collection. It is only used to assist GHD in optimising the content and effectiveness of our website. 5.04 HTML5 local storage HTML5 local storage is used to store information locally and survives browser sessions. Its main purpose within the GHD website relates to automatically logging IP addresses to allow for region specific websites to load. Many Internet browsers allow you to disable HTML5 local storage or delete information contained in HTML5 local storage using browser controls. |
| 6. Links to third party websites |
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Websites operated by us may contain links to other websites that are operated by third parties. Whilst GHD tries to link only websites that share our high standards and respect for privacy, we make no representations or warranties as to the privacy practices of any third-party site and cannot be responsible for the privacy policies, content or security of other sites. This Privacy Policy does not apply to, or cover, linked websites. If you access or share information to websites linked to our website, the operators of those websites may collect your information in accordance with their own privacy policies that may differ to ours. You should review the privacy, “cookie” and other policies displayed on these websites to find out how your personal information may be used and stored. |
| 7. Data security |
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We will take all reasonable steps and apply appropriate technical and organisational measures to maintain the security of any personal information we receive from you and protect it from loss, misuse, and unauthorised access, disclosure or modification. We use a variety of secure techniques to store and protect your information, including secure GHD IT systems and firewalls. Any digital transfer of personal information is secured using a range of security methods. GHD is constantly reviewing its information security technology and practices. We will only keep your personal information when we consider it necessary for one of the purposes for which you have disclosed it. If it is no longer necessary to keep your personal information, we will take reasonable steps to destroy or de-identify your personal information safely, if required. |
| 8. How can you access and correct information? |
| You may have a right in certain circumstances to request a copy of the personal information about you we may hold, request the removal of personal information from our records and to have inaccurate information changed or out-of-date information amended. For example, persons in the European Union, have a right under the GDPR to request the deletion or erasure of their personal information, where that information is no longer required for the purpose for which it was collected.
Please submit a request to the relevant GHD office, the Integrity Officer, or via the Contact Us link on our website, and we will respond to your request as required by applicable law. |
| 9. Children’s information |
| GHD websites and collaboration services hosted by GHD or third parties on behalf of GHD are intended to be used by adults and corporate entities interested in GHD. They are not intended for children, and GHD does not knowingly collect or store personal information about children under the age of 13. |
| 10. Data breach notification |
| In the highly unlikely event of a data breach, GHD will act promptly to comply with applicable local laws. Where it is reasonably foreseeable that an individual will suffer as a result of a data breach, the relevant regulatory body and, where possible, the affected individual will be contacted without undue delay. This notification shall include the nature of the breach, the personal data possibly involved and measures taken to address the breach (including to reduce the harm of negative consequences), the contact details for whom affected individuals can obtain further information and details of any assistance being provided to affected individuals. |
| 11. Future changes to our Privacy Policy |
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Your privacy is important to us and GHD is committed to our privacy practices being up-to-date with prevailing best practices and changes in local laws, regulations and data protection standards and technology. Given this, we may change our Privacy Policy from time to time and will notify you by posting an updated version of our Privacy Policy on our website. The amended policy will apply between us as and when it is posted on our website. This document represents GHD’s Privacy Policy as at 1 April 2020. |
| 12. How to contact us |
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If you have any questions about our Privacy Policy, wish to opt-out of our Privacy Policy or have any complaint regarding the treatment of your privacy or personal information by us, please contact a local GHD office, use the Contact Us link on our website, or contact our Integrity Officer using the details set out below. Any genuine concerns or complaints will be investigated and responded to in line with local law. Integrity Officer c/- Office of the Company Secretary
Level 15, 133 Castlereagh Street
Sydney NSW 2000
Email: integrity.officer@ghd.com
Website: www.ghd.com
If you are not satisfied with a response, dependent on your location, you may have an option to refer your complaint to a relevant privacy regulator. We will provide you details of any relevant regulator on request. |
1"GHD” is a reference to GHD Group Pty Ltd and includes any company carrying on business that is part of the GHD group of companies.