APM Workcare Ltd is strongly committed to maintaining the privacy of personal information it collects as part of the services it offers. APM Workcare places great importance on protecting the privacy of its employees, valued clients, customers and other stakeholders.
References in this policy to ‘APM Workcare’, ‘us’, ‘we’ or ‘our’ mean APM Workcare Ltd.
- Give you a better and more complete understanding of the kinds of personal information that we collect and hold
- Clearly and concisely 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
- Advise you of the circumstances in which we are likely to disclose your personal information to overseas recipients
This policy sets out how we will comply with our obligations under the Privacy Act 1993 (Act). APM Workcare is bound by the 12 Information Privacy Principles which regulate how we may collect, use, disclose and store your personal information, and how you may access and correct personal information held about them.
We will ensure that all of our officers, employees and subcontractors / supply chain partners are aware of and understand APM Workcare’s obligations and their own obligations under the Act and are provided with training to enable them to fulfil these obligations.
We will also achieve this through maintaining internal policies and processes to prevent personal information being collected, held, shared / exchanged, accessed or disposed of improperly.
What is personal information?
Personal information means information about an identifiable individual. It includes your name, date of birth / age, gender and contact details as well as health and other information that would enable you to be identified.
We do not collect personal information unless it is for a lawful purpose connected with a function or activity of APM Workcare or directly related to the purpose for which the information was obtained.
Collection of personal information
Personal information collected by us will usually fall into one of the following categories:
We may collect your information from you in a variety of ways including face-to-face, over the telephone, through an on-line form or portal, through a paper form or by email.
- Contact information (name, age, address, email address and telephone numbers);
- Unique identifiers – an identifier that is assigned to an individual by an agency other than APM Workcare for the purposes of the operations of that agency;
- 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. health, medical history, criminal history, religious beliefs, trade union activity);
- Information obtained to assist in managing client and business relationships
Sometimes we will collect personal information from a third party or a publicly available source if it is unreasonable or impracticable to collect the personal information directly from you (e.g. checking a candidate’s work history).
We may also collect information about you from another source if:
- you have given your consent for us to collect your information from another source; or
- your interests are not prejudiced through the collection of information from another source; or
- the information will not be used in a form that identifies you; or
- the Privacy Commissioner has authorised the collection of information in this manner
Why do we collect, use and store your personal information?
We collect, use and store your personal information to provide you with services including:
Our services, functions and activities, as well as those of our contracted service providers / supply chain partners, may change from time to time.
- 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
- Client and Business Relationship Management
We are committed to keeping personal information secure and safe. Some of the ways we do this are:
Protecting and storing your personal information
Although we take all reasonable steps to secure personal information from loss, misuse and unauthorised access, there is an inherent risk of loss, misuse or unauthorised access to such information. APM Workcare will not be held responsible for such actions where the security of the personal information in not within our control or we cannot reasonably prevent such an incident.
- Requiring employees and contractors / supply chain partners to enter into confidentiality agreements
- Secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets)
- Security measures for access to computer systems
- Password protected data storage devices such as laptops, tablets and smart phones
- Providing a discreet environment for confidential discussions
- Access control for our buildings including waiting room / reception protocols and measures for securing the premises when unattended
- Security measures for our websites
We will only use and disclose personal information for the purpose for which it was initially collected, or for purposes which are directly related to one of our functions or activities.
Who will we disclose your personal information to?
Like many other businesses in New Zealand, APM Workcare contracts out some of its functions and relies on contracted service providers, third party suppliers or supply chain partners to provide specialised services such as employment services, vocational rehabilitation, assessment, “cloud computing” technology and data storage services, legal advice, insurance broking, security services, and financial services. If personal information is provided to these suppliers and supply chain partners in order to enable them to perform the agreed tasks, we will take reasonable measures to ensure that the supplier or supply chain partner handles the personal information in accordance with the Act and the Information Privacy Principles.
We will not disclose your personal information to government agencies, private sector organisations or any third parties unless one of the following applies:
- The disclosure is in connection with, or directly related to, one of the purposes for which it was obtained; or
- APM Workcare obtained the information from a public source; or
- Disclosure is to you; or
- Disclosure is authorised by you; or
- Disclosure is necessary to prevent or lessen a serious threat to public health or safety, or the life or health of any individual; or
- Disclosure is necessary to facilitate the sale of a business as a going concern; or
- The information is to be used in a form in which you are not identified; or
- Disclosure is authorised by the Privacy Commissioner.
Accuracy of personal information
We will ensure that all personal information we collect, use or disclose is accurate, complete and up-todate. Please contact APM Workcare’s Privacy Officer (details below) if you are aware of any personal information that does not meet this objective.
If we are aware that we hold personal information that (having regard to the purpose for which it was collected) is inaccurate, out of date, incomplete, or irrelevant, we will take reasonable steps to correct that information.
You may seek access to, and correction of, personal information held by us in accordance with the section below “How can I access my personal information and contact APM Workcare?”
We may transfer personal information to APM Workcare’s parent company (APM) in Australia in order to perform one or more of our functions or activities. In these circumstances, we have a legally binding agreement between APM and APM Workcare to ensure the integrity and confidentiality of your information.
Will my personal information be transferred overseas?
Please contact us if you would like to seek access to or correct the personal information we hold about you:
How can I access my personal information and contact APM?
A: APM Workcare Privacy Officer – PO Box 302 501, North Harbour, Auckland 0751.
P: 0800 967 522
Under the Act, we may refuse to grant access to personal information if such a disclosure:
We may also refuse requests for access to personal information if we do not hold the information or if the request is frivolous or vexatious.
- Poses a risk to New Zealand’s security or defence; or
- Breaches confidences with another government; or
- Would prevent detection of criminal offences or the right to a fair trial; or
- Endangers the safety of an individual; or
- Involves a trade secret or unreasonably prejudices someone’s commercial position;
- Involves an unwarranted breach of another individual’s privacy; or
- Breaches confidence where the information has been gained solely for reasons to do with the individual’s employment, or to decide whether to insure the person; or
- Is contrary to the interests of an individual under the age of 16; or
- Breaches legal professional privilege; or
- Constitutes contempt of court of the House of Representatives
If we do not agree to provide access to personal information or to correct the personal information, we will provide you with written reasons for the refusal and the mechanisms available to complain about the refusal.
If we do not agree to make a correction to personal information, you may provide a statement about the requested corrections, and we will ensure that the statement is apparent to any users of the relevant personal information.
If you consider that there has been a breach of the Act, the Information Privacy Principles or this policy, you are entitled to complain to APM Workcare.
How do we handle complaints?
All complaints are to be in writing and directed to the APM Workcare Privacy Officer using the contact details above. A Privacy Complaint Form can be completed. APM Workcare will acknowledge receipt of a written complaint within 2 business days.
APM Workcare’s 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.
Monitoring and training