Privacy Policy

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

Policy Statement

This policy sets out how we will comply with our obligations under the Privacy Act 2020 (Act). APM Workcare is bound by the 13 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 you.

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.

Collection of personal information

We do not collect personal information unless it is for a lawful purpose connected with a function or activity of APM Workcare and the collection of the information is necessary for that purpose.

Personal information collected by us will usually fall into one of the following categories:

  • 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


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.

Sometimes we will collect personal information from a third party if it is not reasonably practicable  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; 
  • your interests are not prejudiced through the collection of information from another source; 
  • collecting the information from you would prejudice the purpose of collecting it;
  • the information will not be used in a form that identifies you; 
  • the information is publicly available;
  • 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:

  • 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
  • Research
  • Client and Business Relationship Management

Our services, functions and activities, as well as those of our contracted service providers / supply chain partners, may change from time to time.

Protecting and storing your personal information

We are committed to keeping personal information secure and safe. Some of the ways we do this are:

  • 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

Although we take all reasonable steps within our powers 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.

Who will we disclose your personal information to?

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.

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 prevent the supplier or supply chain partner from unauthorised use or disclosure of the personal information. 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
  • APM Workcare obtained the information from a public source
  • Disclosure is to you
  • Disclosure is authorised by you
  • Disclosure is necessary to prevent or lessen a serious threat to public health or safety, or the life or health of any individual
  • Disclosure is necessary to avoid prejudice to the maintenance of the law by any public sector agency
  • Disclosure is necessary to facilitate the sale of a business as a going concern
  • The information is to be used in a form in which you are not identified
  • 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 to date. 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?”

Will my personal information be transferred overseas?

We may transfer personal information to APM Workcare’s affiliates in  Australia (APM)  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 to a standard equivalent to that set out in the Act.

If the disclosure is to another person or entity (the other person) in a country outside of New Zealand, we will ensure that:

  • The privacy laws of that country overall provide comparable safeguards to those in New Zealand (comparable safeguards)
  • We believe that the other person will be required to protect he information in a way that provides comparable safeguards
  • You have authorised the disclosure of your personal information to the other person, after being told the other person may not be required to protect the information in a way that overall provides comparable safeguards

How can I access my personal information and contact APM?

Please contact us if you would like to seek access to or correct the personal information we hold about you:

Under the Act, we may refuse to grant access to personal information if such a disclosure:

  • Poses a risk to New Zealand’s security or defence
  • Breaches confidences with another government
  • Would prevent detection of criminal offences or the right to a fair trial
  • Endangers the health or safety of an individual
  • Would be likely to risk serious harassment of an individual
  • Involves a trade secret or unreasonably prejudices someone’s commercial position
  • Involves an unwarranted breach of another individual’s privacy
  • 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
  • Is contrary to the interests of an individual under the age of 16
  • Breaches legal professional privilege
  • Constitutes contempt of court of the House of Representatives

 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.

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.

How do we handle complaints?

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.

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

Compliance with this Privacy Policy is subject to internal and regulatory audit. APM Workcare will comply with all reporting requirements of the Act as they exist from time to time.

All staff will receive training with regard to privacy and the application of this Privacy Policy as part of their induction.

Communications and marketing policy

We communicate with users who subscribe to our services on a regular basis via email, and we may also communicate by phone or SMS. We may use your email address and phone number to (i) confirm your information(ii) send notices and other disclosures as required by law or (iii) advise you of programs you are formally registered with and/or (iv) provide information about the services we provide. Generally, users cannot opt out of these communications, which are not marketing related but merely required for the relevant business relationship.

We may also collect, use and store your personal information for marketing purposes in order to inform you of the services we offer. Part of delivering a high quality, personalised digital experience is recognising who we're talking to, so we can provide the services that you want from us. To do that, we may need to request and store some of your personal information. We know your privacy is vital, so these details will only ever be used in accordance with the terms of this Privacy Policy.

APM may also use your personal information for the purpose of marketing its services.

If you do not want to receive marketing material from us, you can contact us as detailed below:

  • for electronic communications, you can click on the unsubscribe function in the communication or
  • for hard copy communications, you can email

Cookies and other technologies are used by APM on APM’s website and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience (including tailored APM marketing), improve the performance, usability and effectiveness of APM’s online presence and to measure the effectiveness of our marketing activities.

If you register or log into an APM website or social media or advertising site and provide personal information, we will use your information to personalise your user experience. If you register or log into an APM website using a third-party account (such as LinkedIn, Google or Twitter), we may collect personal information you have permitted the third-party service to share, including your name and email address, depending on the privacy settings you have set with the third-party service and their privacy policy.

IP address

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. Public IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis, and to personalise your user experience.


Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our website’s features.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including public IP addresses, but this is for the purpose of identifying the number of unique visitors to our website and geographic origin of visitor trends, and not to identify individual visitors.

Analytics tools

APM uses analytics tools, such as Google Analytics. Reports obtained from Google Analytics are used to help improve the efficiency and usability of this website.

Google Analytics uses first-party cookies and JavaScript code to gather statistics about how the APM website is accessed. It anonymously tracks how our visitors interact with our website, including where they came from, what they did on the site including such things as news registration. No personal information is collected or stored by APM or Google. The information generated by the cookie and JavaScript code about your use of the website (including your IP address) will be transmitted to and stored by Google on servers located outside Australia. Google is based in the United States of America (USA). Should you wish to contact Google, you can find contact details on Google's Contact us page.

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

By using our website, you consent to the processing of data about you by Google in the manner described in Google's Privacy Policy and for the purposes set out above. Relevant legislation of the USA will apply. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

Google Tag Manager

We use Google Tag Manager, a digital marketing service provided by Google Inc. (“Google”). Reports obtained from Google Tag Manager are used to help improve the efficiency and usability of the website by measuring traffic and visitor behaviour to the website.

Google Tag Manager uses tags which are tiny bits of website code that allow us to measure traffic and visitor behaviour, understand the impact of online advertising and social channels, use remarketing and audience targeting, test and improve our site. Google Tag Manager keeps track of a set of tags and tag-firing rules, but it does not collect any personally identifiable information. When a user visits the site, the most up-to-date tag configuration is sent over to the end-user’s browser with instructions to fire appropriate tags. The information generated about your use of the website (including your IP address) will be transmitted to and stored by Google on servers located outside Australia. Google is based in the United States of America (USA). Should you wish to contact Google, you can find contact details on Google's Contact us page.

By using our website, you consent to the processing of data about you by Google in the manner prescribed by Google’s Privacy Policy and for the purpose set out above. Relevant legislation of the USA will apply. You can opt out of Google Analytics if you disable cookies, JavaScript, or use the opt-out service provided by Google.

Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server.

APM or its service providers may use web beacons to track the effectiveness of third party website that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

Location-based tools

APM may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

Social media widgets and applications

APM’s website may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of APM’s website. Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, APM’s website may host applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any APM social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

Links to third party websites

APM’s websites may contain links to third parties’ websites, including sites maintained by other APM member firms. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of their privacy policy.

APM also does not endorse, approve or recommend the services or products provided on third party websites.

Your choices

You have several choices regarding your use of APM’s website. In general, you are not required to provide personal information when you visit our website. However, if you apply to receive information about our services, register for services, events and updates or wish to apply for a job, provision of certain personal information will generally be required.

If you do not want to receive marketing material from us, you can contact us as detailed below:

  • for electronic communications, you can click on the unsubscribe function in the communication or
  • for hard copy communications, you can email


Updated March 2024

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