APA Privacy Statement
Your rights in relation to privacy
APA Group, including APA Group Limited as responsible entity of APA Infrastructure Trust and APA Investment Trust (APA) understands the importance of protecting the privacy of an individual’s personal information. This statement sets out how APA aims to protect the privacy of your personal information, your rights in relation to your personal information managed by APA and the way APA collects, holds, uses and discloses your personal information.
In handling your personal information, APA will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act.
This policy statement may be updated from time to time.
What kind of personal information does APA collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. While providing its services and carrying out its functions and activities, APA may collect your personal information.
Generally, the kinds of personal information APA collects are:
- contact and identification information such as your name, address, telephone number, email address, facsimile number, and age or date of birth;
- profession, occupation or job title and name and contact details of your employer;
- information about your education, work history, qualifications and skills and other information obtained through reference or background checks;
- information about your interests and hobbies and employment aspirations;
- opinions of others about you or your work performance (whether true or not);
- information about your work rights and your eligibility to work within Australia which may include details, copies or presentation of the originals of any applicable visa, passport, birth or citizenship certificate, or other relevant documentation;
- sensitive information (e.g. information about your health, medical history or specific condition, criminal record, professional memberships, etc), which will only be collected with your consent. This includes where it is supplied to APA by third parties associated with ensuring supply of energy to your home or business;
- tax file numbers, ABN numbers and relevant bank and superannuation account information necessary to facilitate the payment of wages, superannuation contributions and fees and to ensure appropriate taxation treatment;
- information about dates and hours worked (for example, by contractors), generally contained in timesheets;
- driver’s licence number and relevant information about your driving history or infringements and any other applicable licences and certificates; and
- other information relevant in the circumstances.
APA may also collect information that may not be personal information by itself but could be personal information when combined with other information. This includes your IP address, browser type, operating system, browser language, time zone, access times and any referring addresses as well as location information.
How does APA collect your personal information?
Generally, APA collects your personal information directly from you, through the completion of a manual or online form, an interaction or exchange in person or by way of telephone (including through our Call Centre, and videoconferencing), facsimile, email, post or through the use of APA websites.
For example, personal information may be collected when you:
- subscribe to Newsletters and ASX Releases;
- apply for an opportunity or role at APA;
- contact our Call Centre; or
- submit any messages or comments via the website enquiry form or an email.
There may be occasions when APA collects your personal information from other sources such as:
- your employer or former employer;
- educational and training institutions to verify enrolments and academic performance;
- regulatory authorities;
- energy retail companies where APA supplies gas services to your residence or business;
- a publicly maintained record or other publicly available sources of information including social media and similar websites;
- if for recruitment purposes, an external recruitment or background screening services provider; or
- an information services provider.
Generally, APA will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you, if you consent or it is otherwise required by law.
Why does APA need your personal information?
APA collects, holds, uses and discloses your personal information where it is reasonably necessary for one or more of APA’s functions or activities, including:
- the provision of APA’s services, including network services provided through our Call Centre;
- to allow you to subscribe to Newsletters and ASX Releases;
- its internal recruitment processes for potential employment with APA;
- in connection with the engagement of contractors or contracting with suppliers;
- in connection with the holding of securities in APA or other financial products issued from time to time by APA Infrastructure Trust and/or APA Investment Trust;
- for operational functions associated with the management of employees and contractors;
- for accounting, billing and other internal administrative purposes;
- for business management purposes;
- for surveys regarding APA’s business activities, including regarding safety;
- for marketing purposes and to identify and inform you of products or services that may be of interest to you; and
- any other legal requirement.
APA may also use your personal information for purposes related to the above purposes and for which you would reasonably expect APA to do so in the circumstances, or where you have consented or the use is otherwise in accordance with law.
Where personal information is used or disclosed, APA takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.
You are under no obligation to provide your personal information to APA. However, without certain information from you, APA may not be able to provide its services to you.
Our share registry service provider, Link Market Services Limited (Link), collects, uses and handles personal information of securityholders of APA.
Once you become a securityholder of APA, Chapter 2C of the Corporations Act 2001 (Cth) (Corporation Act) requires information about you, including your name, address and details of the securities you hold, to be kept in APA’s public register. This information must continue to be included in APA’s public register even if you cease to be a security holder. These statutory obligations are not altered by the Privacy Act.
Link has a policy designed to maintain the confidentiality of all personal information. Link has undertaken to APA that Link will take all reasonable steps to protect your personal information from misuse and loss, and from unauthorised access, modification or disclosure, and Link does not sell, rent or trade personal information to or with third parties.
Anyone who provides us with notice may have access to APA’s public register of security holders, or obtain a copy of the public register in accordance with the Corporations Act. In doing so, we are obliged to provide details of security holders, which may include your name, address and details of the securities you hold. In some cases, our registry service provider for this information may charge a service fee.
Website and cookies
You can generally visit APA’s website without revealing personal information unless you choose to provide the information to us. The information we collect depends upon what you do when visiting the site.
Cookies do not contain personal information but enable APA to recognise your browser. Information from a single cookie does not identify any individual on its own, but it does identify your computer or device.
Cookies are optional for the user and your browser can be set either not to accept cookies or to prompt you to accept them or not case by case.
To whom APA discloses your personal information?
APA discloses your personal information for the purposes for which it is collected. That is, generally APA will only disclose your personal information for a purpose set out in the section above called ‘Why does APA need your personal information?’. This may include disclosing your personal information to:
- your referees;
- consultants and professional advisers;
- agents or contractors acting on APA’s behalf;
- third party service providers, contractors and suppliers, including parties to whom APA has outsourced various functions or engaged to perform administrative or other business management functions such as:
- services of printing and posting related information;
- data and records storage services;
- information technology services;
- surveys, marketing, marketing research, website development and usage services in relation to services; and
- computer software supply, installation, upgrade and maintenance services;
- related bodies corporate and other related entities of APA;
- insurance providers;
- APA’s share registry service provider, Link, in connection with security holders to the extent required under the Corporations Act ;
- regulatory authorities and government agencies, and otherwise as required by law or court/tribunal order; and
- any other entity, with your consent, or to whom disclosure is required or authorised by law.
APA’s disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law.
APA may disclose personal information to overseas recipients in order to provide its services and for administrative or other business management purposes, including to cloud service providers for data storage purposes.
Recipients of such disclosures are located in the United Kingdom, European Union (including Germany, Ireland and Hungary), India, USA, Canada, Philippines, Japan.
Overseas recipients of personal information may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, APA will take reasonable steps in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
If you have any queries or objections to such disclosures, please contact APA’s Privacy Compliance Officer on the details set out in the section below called ‘Enquiries’.
APA may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting APA’s Privacy Officer via the contact details set out in the section below called ‘Enquiries’ or through any opt-out mechanism contained in a marketing communication to you.
Security of your personal information
APA takes reasonable steps to protect your personal information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure. Your personal information received by APA is held securely, either in electronic files on APA’s computer systems or in physical files stored at APA’s premises accessible only by authorised staff. APA takes reasonable steps to protect all personal information it holds by using technology (e.g. firewalls), controls and processes.
APA will destroy or de-identify personal information in circumstances where it is no longer needed, unless APA is otherwise required or authorised by law to retain the information.
There may be risks associated when you transfer personal information to us, including from internet facilities or by email. Using email and the internet may not always be successful or secure. We cannot be held responsible for the security or confidentiality of any information sent to us by e-mail or over the internet.
Your rights of access and correction of your personal information
APA takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and correct your personal information that is collected and held by APA. If at any time you would like to access or correct the personal information that APA holds about you, please contact APA’s Privacy Officer on the details set out below.
APA will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- APA requests that you be reasonably specific about the information you require; and
- APA may charge you a reasonable administration fee, which reflects the cost to APA, for providing access in accordance with your request.
If APA refuses your request to access or correct your personal information, APA will provide you with written reasons for the refusal and details of complaint mechanisms. APA will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of APA.
APA will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
You can contact our Privacy Officer at any time if you would like details of your personal information we hold, if you would like us to update or correct your personal information that we hold or to opt out of marketing communications. You may contact our Privacy Officer by writing to the following address:
PO Box R41
Royal Exchange NSW 1225
If you have questions about this Privacy Statement you can contact APA’s Privacy Officer.
Please direct privacy complaints to the Privacy Officer at the address provided above. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect commercial arrangements between you and APA.
APA’s Privacy Officer will investigate your complaint. You will be informed of the outcome of your complaint following completion of the investigation. If you are dissatisfied with the outcome of your complaint, you may refer your complaint to the Office of the Information Commissioner (OAIC) by contacting the OAIC inquiries line on 1300 363 992 or see the OAIC website at www.oaic.gov.au