COVID-19 Response
In the interests of protecting the health of our employees at workplaces (whether of GHD, GHD’s clients or other third parties), and discharging our duty of care to invitees to our premises or meeting similar requirements of third parties such as our clients, GHD may, with respect to COVID-19, and subject to the requirements of applicable law, collect and use sensitive personal information from our employees, contractors and invitees. This personal information includes but is not limited to vaccine status, temperature and other associated symptoms, contact with anyone infected with COVID-19, and travel to high-risk area/s. Personal information may be collected, used stored or disclosed, as is reasonably necessary for the purpose of preventing or managing COVID-19 in the workplace and meeting legislative and regulatory requirements and other public health directives. Additionally for the purpose of securing and satisfying commercial arrangements with clients GHD may be required in some jurisdictions to provide some of this personal information relating to our employees or contractors to our clients.
This personal information will be managed in accordance with this policy and any applicable legislative requirements, and it will only be disclosed to the persons who need to have access to such personal information for the purposes for which it was collected. The primary purpose for collection of this additional information is to ensure that necessary precautions are adopted in relation to that individual and any other individuals, to meet legislative and regulatory requirements and other public health directives and orders and where necessary, to secure and satisfy commercial arrangements with clients.
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 specific COVID-19 mandatory guidance issued by a relevant regulator.
“GHD” is a reference to GHD Group Limited and includes any company carrying on business that is part of the GHD group of companies.
1. What is personal Information?
2. When do we collect and hold personal information?
We collect and store personal information (including names, telephone numbers, address, email address, occupation, education, and qualifications etc.) both online and offline in a range of contexts, most commonly:
- when individuals interact, have conversations or otherwise communicate with us
- when individuals attend events hosted by us or which we also attend
- when individuals download white papers or other publications of GHD which may be of interest to them
- when entering into relationships with new clients or potential clients
- when individuals apply for employment or other business opportunities with us and enter employment arrangements
- when individuals register online for access to secure sites or collaboration services hosted by GHD or third parties on behalf of GHD including, SharePoint Online, ProjectWise, BIM360, ArcGIS Online, or other services
- when we conduct surveys, community consultation, environmental and other studies as part of our business
- from third parties in the course of, or our related to, our business activities such as our vendors, business or commercial partners
3. What do we do with personal information?
We may use your personal information as necessary which includes:
- in compliance with legal obligations;
- to enable us to provide services to you or our clients;
- to communicate information about our services;
- for our internal administrative, account management, planning, business development, and research requirements;
- to promote contact with you, clients and other business partners via marketing communications, execution and analysis of market surveys, and marketing strategies and campaigns.
- to conduct due diligence and compliance requirements such as screening against publicly available government lists;
- to consider the suitability of applicants for employment with us; and/or
- for any other purpose you provide your consent for.
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 provide relevant information to the website user about GHD, our services, our key people in our regions or our capabilities in a variety of contexts.
4. Reasons we may share or disclose your personal information
Whilst always 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 several circumstances, such as:
- by authorised GHD personnel to the extent such access is necessary to serve the intended purpose and for them to perform their jobs, which may include sharing information between your GHD business contact, and personnel within our People, Finance, Internal Audit, Information Services, Marketing and Legal Services teams.
- with other GHD group entities, and with personnel at other GHD office locations.
- when remotely accessed from the Philippines by GHD personnel providing GHD internal technology support.
- when collecting and analysing empirical data relating to recruitment and personnel and making this available to our Global People team.
- when sharing employee CVs and work experience within our business for the purpose of identifying appropriate communications and resources to clients.
- to third-party service providers (such as those who provide due diligence and screening for compliance requirements such as employment and vendor pre–screening or credit references), professional advisors (such as auditors and lawyers), and law enforcement and regulatory bodies.
- to third-party service providers who support our Information Services function and provide services and technical support, data hosting, data analytics and other similar services for us, who may require access to information about you for this purpose.
We require these people to protect your information as carefully as we do. Third parties will not be authorised to use your personal information for any other purpose than for which it is disclosed or for purposes you might reasonably anticipate as a disclosing person, such as a job applicant, employee, client, or business partner.
Due to the global nature of GHD’s operations, access, use and storage of personal information may be effected across jurisdictions. The third parties we disclose your personal information to may also be based in, or have servers located in, a jurisdiction other than where you reside, including but not limited to
Australia, Asia, North and South America and the Pacific Region. Where an international data transfer takes place, we will comply with the level of data protection required by applicable data privacy laws and take reasonable steps to ensure that this will not negatively affect the level of protection afforded to your personal information. Your consent to us disclosing and transferring your personal information to service providers is provided on the basis that the relevant third parties have the appropriate technical, organisational, and contractual means to protect your personal information.
GHD will not use, share, or disclose your personal information 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 any time by contacting us (as outlined below).
5. Your personal information is never sold or rented
GHD is driven by a client service driven 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.
At any time, you may opt-out of receiving any communications from us (other than as required for the operation of our business, for example, regarding payment of accounts) or change your marketing communication preferences.
Electronic marketing or communications material will have an “unsubscribe” link or contain instructions allowing you to opt-out or change your preferences. Alternatively, you can contact us directly about our marketing and communications by using the contact details below.
5.1 California residents and direct marketing
California residents are entitled once a year, free of charge, to request and obtain certain information regarding GHD’s disclosure of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. It should be noted that GHD does not disclose personal information to third parties for direct marketing purposes, regardless of jurisdiction.
6. How do we use "cookies", "log files", data analytics and other similar technology?
7. Links to third party websites
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.
8. Data security
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. Although GHD is constantly reviewing its information security technology and practices we cannot guarantee absolute data security.
We will only keep your personal information when we consider it necessary for one of the purposes for which you have disclosed it or as required to be retained by law. 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.
9. 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.
Please submit a request to the dataprotection.officer@ghd.com or via the Contact Us link on our website, and we will respond to your request as required by applicable law.
For security reasons, we may ask you to verify your identity to ensure that we do not give information to the wrong person or change or remove your personal information without your express consent.
If there is no applicable legal or regulatory requirement for GHD to respond to your request, GHD will respond at its discretion.
10. Children’s information
11. Data breach notification
12. Future changes to our Privacy Policy
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 12 March 2023
13. How to contact us
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 Data Protection 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: DataProtection.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.