The purpose of this policy generally is to outline how APSG handles the personal information of its customers, employees and other individuals.
In particular, this Policy describes the way that APSG will, subject to applicable legal requirements, adhere to all relevant federal and where applicable, provincial legislative privacy requirements.
This Policy describes each principle and the method of implementation.
APSG will strive to meet or exceed federal and provincial state law within each of the countries it operates in, and within the legislative, requirements and will ensure that it remains current with changing technologies and laws.
For the purpose of this Policy, the term “personal information” means any information about an identifiable individual.
Personal information includes, without limitation, an individual’s name, home address, home phone number, e-mail address, identity verification information, social insurance number, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, contents of resume, references, interview notes, performance review notes and emergency contact information.
The Privacy Officer may at his/her discretion enlist assistance from other staff members and/or volunteers within the organization. This will not in any manner mitigate their responsibility for Privacy issues.
The Privacy Officer’s identity is fully disclosed and publicly accessible to APSG members and the public in general. In KSA, the Privacy Officer and designate alternate for APSG are: Director HR, reporting to CEO, alternate as designated by HR
The Privacy Officer will ensure that APSG manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of APSG shall be contractually obligated to adhere to the standards of APSG.
APSG may designate a Privacy Coordinator.
1.1 Personal Information belonging to APSG’ Customers and Customer’s Visitors
APSG shall only collect the information reasonably necessary to perform the security services and deliver the security equipment as agreed to with its customers.
To obtain further information contact APSG Privacy Officer.
APSG collects personal information from its customers and members of the public for the following purposes:
APSG will obtain assurances and representations that the necessary consents have been obtained from its customers before providing and/or implementing the services set forth above.
1.2 Personal Information belonging to APSG Applicants and Employees
Personal information submitted by an applicant to APSG will only be used by APSG to support a responsible and efficient recruitment and selection process. APSG’ recruitment purposes are as follows: matching applicant data with APSG current open positions, communicating APSG recruitment and selection procedures, contacting applicants to schedule interviews/tests, sending information to applicants about other relevant vacancies and, where appropriate, confirming background information.
Processing includes obtaining, recording, holding, organizing, transferring, adapting, amending, recovering, consulting, using, limiting, disclosing by transmission, disseminating or otherwise making available, aligning, blocking destroying and erasing recruitment data.
APSG collects personal information of APSG employees in order to properly establish and maintain our employer/employee relationship. Such information will be protected with appropriate safeguards. APSG recognizes the confidential nature of the personal information in its care and its accountability for compliance in protecting this personal information. Accountability extends to all employees of APSG and its directors, officers, managers, employees, representatives and agents including consultants and independent contractors.
During the onboarding process, after an offer of employment an individual may be asked to provide some or all of the following:
Personal information will be collected, used and disclosed for purposes pertaining to the individual’s employment relationship with the Company, including but not limited to the administration of employee hiring, performance reviews, the administration of employee payroll, processing of employee benefit claims, and for the purpose of complying with all applicable labour and employment legislation.
Purposes for the collection, disclosure and use of personal information:
The purposes for collecting personal information will be documented by the Company. Personal information will only be used for the stated purpose or purposes for which it was originally collected.
The purposes for which personal information is being collected will be identified orally or in writing to the individual before it is collected.
3.1 APSG will use the personal information for the uses specified above in Section 2 and in Sections 3.2 and 3.3 below.
3.2 In addition to using personal information for the providing of security services, APSG may from time to time wish to use customer names, addresses and contact information for the purposes of providing promotional opportunities, including by providing the information to APSG’s marketing and sales departments and other third parties who APSG believes provide services or goods that may be of interest to an individual. APSG and any such third parties may contact an individual with promotional information. APSG will provide an opportunity for the recipient to consent to these opportunities during the registration process.
If a recipient consents but later wishes to opt out of this use of information later, they may do so by contacting us as described at Section 3.3 below.
3.3 If at any time an individual wishes to withdraw their consent to the use of their information for any purposes, they may do so by contacting the Privacy Officer for APSG. We will do our best to accommodate this request in a timely fashion without diminishing the services we provide. We will explain the impact of such withdrawal on any services or provisions we provide.
3.4 APSG may collect personal information without consent where reasonable to do so and where it is permitted by law.
APSG shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fulfill our identified purposes.
Subject to applicable legislation, APSG shall limit use of personal information it collects to purposes that we have disclosed in Section 2 (Identifying Purposes) and Section 3 (Consent).
APSG shall maintain documents for certain periods of time dependent upon necessity. More specifically:
Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by APSG
In the event that APSG or a service provider to APSG uses collects, stores, uses or discloses personal information outside of country of origin, APSG will first provide such notices, policy directions and/or obtain such consents as may be required by applicable legislation.
APSG shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.
Security safeguards have been implemented to ensure that the personal information collected by APSG is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.
The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.
Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.
APSG will, upon request, disclose the methods by which it handles personal information. The information available includes:
Honest, Open and transparent communications between employer & employees
Subject to applicable legislation, upon request by the individual concerned, APSG shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.
APSG may request sufficient information to confirm the requestor’s identity before releasing their personal information.
Subject to applicable legislation, APSG shall endeavour to provide this information within 30 days of receipt of the request for information and only charge nominal fees for the purpose of off-setting expenses incurred in supplying the requested information. This information shall be provided in an understandable format. APSG may under specific circumstances, extend such 30 day period by up to an additional 30 days by contacting the requestor within the first 30 days to explain the reason for the delay, and to advise the individual of their right to complain to the Privacy Commissioner of operating country about the delay.
The specific circumstances must be warranted and verifiable for example, if responding to the access request would;
(a) interfere to an unreasonable degree with the company’s activities; (b) undertake consultations that would make it impracticable to meet the 30-day deadline, (c) if the individual requires the information in an alternate format and it would take a significant amount of time to convert it.
Upon receipt of the information, the requestor may be able to demonstrate that the personal information is incomplete or factually wrong.
Inaccurate information that is brought to our attention shall be corrected by APSG as quickly as possible and any pertinent third parties shall be apprised of the corrections in due course.
Upon receipt of a complaint APSG shall make available the complaint procedures which will be simple and easy to access.
APSG shall investigate all complaints. If the complaint is deemed justified APSG shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.
For more information:
All complaints shall be addressed in writing to:
APSG Corporate Office, within Operating country or through APSGWORLD.COM/HR DIRECTOR
Guidelines for APSG Employees – Safeguarding Privacy/Mobile Devices
Thousands of mobile devices go missing every year within APSG group of companies8. Laptops and ‘thumb-drives’ get left behind, back-up portable drives and USB keys get misplaced and cell-phones fall out of pockets. Personally identifiable information is any information which may be used to identify an individual. APSG has taken precautions to encrypt and safeguard personal information while working in the APSG office environment. If it is necessary for you to store personal information on a mobile device, you are responsible for safeguarding such information.
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