GBG has offices in 16 locations; our registered head office is located within the United Kingdom.
GB Group Plc
The Foundation
Herons Way
Chester Business Park
Chester United Kingdom
CH4 9GB
Company Registration Number: 02415211
This Privacy Policy explains to you how GB Group plc and its group companies including GBG (Australia) Pty Ltd (jointly referred to as 'GBG') collect, hold, use and disclose (‘process’) your personal information:
GBG take the protection and security of your personal information very seriously and this policy sets out our responsibilities under the Privacy Act 1988 (Cth) (‘Australian Privacy Act’) and the Privacy Act 2020 (‘New Zealand Privacy Act’) and other applicable laws in Australia and New Zealand relating to the processing and security of personal information. We refer to the Australian Privacy Principles as the APPs and the New Zealand Information Privacy Principles as the IPPs. We refer to the Australian Privacy Act and the New Zealand Privacy Act together as ‘the Privacy Acts’. Where your personal information is transferred overseas, it will be treated in accordance with Australian and New Zealand laws at a minimum.
We have offices in 22 locations, and our registered head office is located within the United Kingdom.
GB Group Plc
The Foundation
Herons Way
Chester Business Park
Chester
United Kingdom
CH4 9GB
Company Registration Number: 02415211
If you have any questions about how your personal information is used by GBG, please email us at compliance@gbgplc.com or call + 61 (0)3 8595 1500.
Our Australian office is located at:
GBG (Australia) Pty Ltd (‘GBG AU’)
Level 4 / 360 Collins St
Melbourne
Victoria 3000
Australia
GBG AU has a registered overseas branch in New Zealand.
GBG review our Privacy Policy on an annual basis, sooner if changes to regulation require it or GBG change the way we process personal information.
What information do we collect about you?
Browsing our website: When you browse our website www.gbgplc.com, we will collect the Internet Protocol (IP) address of the device you are using, but will be unable to identify you at this point. We collect this data so that we can identify where customers are dropping out of the website and to identify areas of improvement to make the experience more engaging for our customers.
We use cookies on our website, so please see our Cookie Policy for more information.
Requesting a brochure: When you request a brochure from us, we will collect the following information from you:
Requesting a call back: when you request a call back from us, we will collect the following information from you:
Subscribing to our marketing lists: Where you have consented to receive marketing from GBG, we will collect the following information from you:
Requesting further information from us: Where you request further information from us by completing a form on our website in relation to our products and services, your details will be added to our marketing database to receive marketing from GBG relevant to the products and services you have an interest in. We will collect the following data from you:
Conferences and events: As a global organisation, GBG attends worldwide events and have marketing team members located around the world. GBG will obtain from the event organiser a delegate list of all attendees who have consented to their personal information being shared with GBG.
Entering into an agreement with GBG: When your organisation enters into an agreement with GBG to provide products and services, we will collect additional information, which is necessary for:
All personal information we collect is held electronically within our Customer Relationship Management systems (CRM) which are located in the United Kingdom.
GBG will share your information with third party service partners who are acting on behalf of GBG as our data processor. Below are the details of whom GBG will share your personal information with and why:
HubSpot Inc.: provides GBG with an email marketing solution, which delivers marketing emails on our behalf. HubSpot is headquartered in the US and their product infrastructure is hosted on Amazon Web Services in the United States, with some services being routed through the Google Cloud Platform in Germany. We share the following personal information with HubSpot:
Price Waterhouse Coopers: supports GBG with our CRM systems and, as a result, their team located in Poland may access the live system for technical support.
Microsoft: our Dynamics 365 CRM system is cloud-based and hosted by Microsoft in the UK. In addition, when you visit our website you will be directed to the Microsoft Azure instance in the region nearest to you (Ireland, Hong Kong, California, or London) and the data will be stored in Ireland.
CustomerSure: carries out our Voice of the Customer surveys and is based in the UK. In order to determine customers’ level of satisfaction following their interaction with GBG at various pre-defined trigger points, CustomerSure will receive personal information from GBG's CRM systems. This is used to facilitate the sending of an email requesting completion of a survey and, following that, analysis of and appropriate reaction to the feedback received. The data is processed by CustomerSure in the UK with the exception of the disaster recovery backups, which are hosted in Ireland.
Brace Digital: provides development and technical support of our website and is located in the UK.
GBG can assure you that we have taken all reasonable technical and organisational measures necessary to protect the personal information that our third party service partners may access.
Marketing and the use of your personal information
As stated above, we use a third party service provider, HubSpot, to manage our email marketing solution. When you receive an email from GBG it will include an unsubscribe link, which you can click on if you wish to unsubscribe from our marketing lists. We will then add your email address to our suppression list, which will ensure you do not receive any further marketing from GBG.
Where you have opted out of marketing materials, you may still receive technical and product support communications from GBG related to any product or service you have purchased from us.
Please be assured we do not sell your personal information to third parties for marketing purposes.
How long do we retain your personal information for and why?
Where we have collected your personal information for marketing purposes, we will retain your personal information for as long as you remain subscribed to our mailing lists or until you inform us that you no longer wish to receive marketing from us.
For account management purposes, we will retain the personal information for as long as we have the relationship with your organisation. If GBG no longer have a relationship with your organisation, then we will only keep the relevant information, such as invoices, for audit purposes for 7 years after the relationship with GBG has ended.
Once GBG are informed you are no longer the contact we need to liaise with or you leave your organisation, we will remove your details from our system.
How long do we retain your personal data for and why?
Where we have collected your personal information for marketing purposes, we will retain your personal information for as long as you remain subscribed to our mailing lists or until you inform us that you no longer wish to receive marketing from us.
For account management purposes, we will retain the personal information for as long as we have the relationship with your organisation. If GBG no longer have a relationship with your organisation, then we will only keep the relevant information, such as invoices, for audit purposes for 7 years after the relationship with GBG has ended.
Once GBG are informed you are no longer the contact we need to liaise with or you leave your organisation, we will remove your details from our system.
Analytics
We use Google Analytics to measure how users interact with our website in order to understand which parts of our sites are doing well, how people arrive at our site and so on. We use this information to improve our website. Google will not associate your IP address with any other data held by it. You can learn more about Google Analytics here or opt out if you wish here.
Cookies
We use various types of cookies in order to identify and track users and to store information about your preferences. Users may disable cookies; however, please keep in mind that if you decide not to accept all of the cookies, some parts of the site might not work properly. You can read more about how we use cookies in our Cookie Policy.
Search facility
The search facility on our website does not collect any personal information. Search queries and results are logged anonymously to help us improve the website and search functionality, but we do not have the ability to identify any individuals.
Security and performance
We keep a record of traffic data, which is logged automatically by our server, such as your IP address and any error messages visitors may encounter. Any traffic data we process in order to monitor our website is anonymised when required for analytics.
Purpose and legal basis for processing
We process the information mentioned above for carefully considered and specific purposes mentioned in each section, which are in our legitimate interests to enable us to enhance the services we provide, which we believe also benefits our customers. This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose.
Visitor book
We meet visitors at our offices, including:
Our visitors are asked to sign in and out at reception, or via an online link. The information collected will be name, company, contact details, who you’re visiting, time in/time out, vehicle licence plate number (if applicable), Covid related health information and date. The app used to collect this information is supplied by ‘Proxyclick’, and may be transferred overseas to the EU and USA. Where any overseas transfer of your data occurs, GBG will ensure your information is handled securely and managed in accordance with Australian and New Zealand privacy laws.
Visitor details are held for a period of 30 calendar days, in line with our CCTV recordings.
Purpose and legal basis for processing
It is important GBG capture the details of visitors to our offices for various reasons, including but not limited to health and safety, fire safety, building security, and safety of our team members. This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose.
Wi-Fi
In order to access our on-site guest Wi-Fi, you will need to be on the list of authorised users to access the network. When connecting to the GBG GUEST WI-FI network, you will be asked to enter in the email address of a GBG nominee, who will authorise your request for internet access. Once the GBG nominee has granted you permission, you will have access to the network. We monitor access to our internet, and log traffic information such as the IP address, sites visited, times and dates, log on times and log off times. This data is held for 12 months.
Purpose and legal basis for processing
The purpose for processing this information is to provide you with access to the internet while visiting our office. This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose.
CCTV
Closed-circuit television (CCTV) operates both inside and outside our Melbourne, Canberra, and Sydney offices.
Generally, recordings will be retained for up to 30 calendar days, after which they will be deleted. Imagery required for investigative or evidential purposes may be retained beyond 30 days and is securely disposed of upon completion/conclusion of the purpose for which it was retained.
Recordings are retained in a secure environment and are only accessible by authorised personnel who have a legitimate reason to do so.
Purpose and legal basis for processing
GBG uses CCTV imagery for the purposes of maintaining the safety and security of our building and team members, and for investigative purposes as evidence to support the effective management of any incidents. This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities.
When you apply online for a position with GBG we will use the information you provide to assist in the recruitment and selection process. There is information we require in order to process your application, which within the software is depicted as mandatory fields. GBG may also seek additional information from other sources, for example, by using your references in the final stages of the recruitment process.
You have the opportunity to provide information in relation to additional adjustments required for the recruitment process to assist you. This is to ensure we enable all individuals to compete on equal terms. You may choose to provide some special category data here, such as ethnicity, religious beliefs or medical conditions, but it is not required and can optionally be provided at a later date.
Purpose and legal basis for processing
Our purpose for processing your data in the event of a job application is to assess your suitability for the role. This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose.
With regard to any special category data you provide, we collect this information to monitor equality and diversity to ensure we comply with legislation such as the Australian Human Rights Commission Act 1986 (Cth) and the Equal Opportunity Act 2010 (Vic). This is in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose.
Data retention
Information provided on the application form and any information obtained from other sources will be retained in all cases in hard copy format and/or electronically only for as long as is required for the purposes of:
Your data is retained for 3 months within be/hired, our internal HR platform, then it is automatically deleted. If you would like your data deleted sooner, please contact compliance@gbgplc.com so we can raise this as a request for Access UK Ltd to complete on our behalf.
If your recruitment process goes beyond 3 months, you will be aware of this, with your personal information then held by GBG for the duration of the recruitment process.
If you are successful with your application, the personal information you have supplied to us will form part of your employment record.
Use of data processors
GBG will share your information with third party service partners, who are acting on behalf of GBG as our data processor:
Access UK Ltd: provides GBG with the software which controls the be/hired process. This is hosted in the UK. GBG is unable to change the questions which have been asked or the process within the system you are taken through. Whilst Access UK controls the “how” from a software perspective and hosts this platform, your personal information is gathered by GBG as the data controller, so we decide on why this is processed, who it is shared with, etc. The aCloud Recruitment Team at Access UK (Deployment/Development & support) appoints one individual in the hosting team with access to the server for support and maintenance purposes only.
CEB Inc: provides GBG with a global talent assessment platform which is hosted in the US. As part of your application you may be requested to complete this assessment via a separate link. To generate this link, GBG will need to have shared your name and email address. The data entered is then determined by you.
Other third parties
Where you have engaged with an external recruitment agency they will have shared your details with GBG for a role they have notified you about. The recruitment agency also acts as a data controller.
We are unable to be more explicit in this statement as to who they are as we work with a large number of agencies globally. If you would like more information regarding your personal information, please contact us by email at compliance@gbgplc.com or by writing to: Data Protection Manager, GBG, Level 4 / 360 Collins St, Melbourne, Victoria 3000, Australia.
We may also contact the named referee(s) you have supplied in order to provide a reference on you. Or once your application has been successful, your details may be shared with other third parties, such as a payroll provider. You will be notified of any further processing at the appropriate time.
Accuracy of your personal information
You enter your own information, so please ensure it is correct. If this needs to be updated, please contact behired@gbgplc.com who will be able to facilitate your request.
International data transfers
As a global organisation, a transfer taking place will depend on where in the world you are based and the role you have applied for.
The platform on which be/hired is hosted by Access UK is in the United Kingdom, so your personal information will be transferred to the UK. If you complete a talent assessment, your name and email address will have been transferred to CEB Inc., which is based in the US.
Depending on the role you have applied for, we may need to transfer your personal information to other companies within GBG for administrative purposes. For example, if you are based in Australia or New Zealand, we may need to transfer your personal information to our head office in the UK and to any territory in which you have applied for a role.
GBG’s customers access IDscan products and services to prevent and detect fraud. Using a combination of automated document recognition, digital tampering detection, advanced face-matching technologies and real-time online support from trained document examiners, our clients are able to on-board individuals while improving customer experience, fighting fraud and meeting compliance obligations.
What personal information GBG holds and why
IDScan obtains a copy of your identification document. Where GBG provides a hosted cloud storage solution to our clients, we hold your identity documents (IDs). We hold this data in order to provide our services, including storage, support and maintenance.
We also require sample documents to train and test our document recognition engine, so that we can improve our ability to recognise, extract from, validate and authenticate our customers’ documents. Where our customer has agreed to it, a copy of your ID or proof of address document might be provided to GBG to train the IDscan document recognition engine to recognise underperforming or unrecognised documents. The nature of the documents means that they include personal information such as photograph, name, address and date of birth. This information cannot be anonymised or pseudonymised without compromising the ability to train and test GBG’s document recognition engine. Our aim is to be fully transparent, which is why we suggest our Australian and New Zealand customers include a link to this Privacy Policy in their own notices so that individuals are informed of GBG’s involvement as part of the service we provide and so that individuals may exercise their rights under the Privacy Acts.
Purpose and legal basis for processing
Our purposes for processing your data in connection with IDscan are: (i) to provide support services to our clients who use IDscan to verify your identity and to conduct maintenance and testing of our IDscan systems (in accordance with APP 3.2, which allows us to collect personal information when it is reasonably necessary for one or more of GBG’s functions or activities and IPP 1 which allows us to collect information for a lawful purpose connected with one of our functions or activities where the collection of the information is necessary for that purpose); and (ii) to train the IDscan document recognition engine to recognise underperforming or unrecognised documents (with your consent).
At the end of the Retention Period, we will take reasonable steps to destroy or de-identify the ID.
International Transfers
For our Australian and New Zealand customers, IDScan is hosted from Australia. For any New Zealand customers there will be a data transfer from New Zealand to Australia of personal information. PII from our Australian and New Zealand customers will generally be stored in Australia, unless product support is required (as detailed below).
If product support is required, this will be provided by our team based in the United Kingdom and Malaysia and our technical and support teams in Turkey. Should they be required to access or view any identification documents, this is considered to be a transfer of data to the United Kingdom, Malaysia or Turkey in order to facilitate that support.
Where there is an international data transfer to our United Kingdom, Malaysian or Turkey offices, your personal information will be handled in accordance with the Australian Privacy Act and APPs (at a minimum) in relation to the collection, use, disclosure, storage and destruction or de-identification of personal information.
Data retention
IDs captured by GBG IDscan will be retained until the earlier of the following events occurs (the ‘Retention Period’):
IS0 27001 Certification
GBG are a global specialist in identity data intelligence for some of the largest organisations in the world, which is why GBG aim to set the highest standards of information security and in doing so, have developed an Information Security Management System (ISMS) to meet the requirements of the ISO 27001:2013 standard. Its aim is to protect the confidentiality, integrity and availability of GBG and client held information resources and assets, thus safeguarding GBG and its clients from unauthorised access, compromise and/or disclosure of data.
PCI-DSS Certification
Some of the services we provide are compliant with the Payment Card Industry Data Security Standard (PCI DSS). Being compliant with PCI DSS means that we are doing our very best to keep our customers’ valuable information safe and secure and out of the hands of people who could use that data in a fraudulent way. PCI ensure technical and operational strengths to raise the bar on our security.
Cyber Essentials Certification
In addition to the above, we have services that are Cyber Essentials accredited, this helps prevent the vast majority of cyber-attacks. Having a Cyber Essentials badge enables us to:
Protect our organisation against common cyber threats.
GBG acquired VIX Verify Pty Ltd in 2018. Vix Verify is the provider of “greenID” which is a product used to verify the identity of individuals. greenID aims to improve the customer onboarding experience whilst providing accurate and reliable identity verification to our clients.
What personal information does GBG collect and why
GBG may collect information from you in the following circumstances:
Business users of greenID
In order to provide you with access to greenID and to provide support to you under our contract with your organisation, GBG is required to collect the following information from you:
How we use your personal information
We use these details in order to provide you with access to greenID, and to retain appropriate audit logs of activity within the system. The above information will be held by GBG until the conclusion of the arrangements between the organisation and GBG, or until we are advised you no longer require access to greenID.
Accuracy of your personal information
You can request an amendment to your personal information at any time by requesting your greenID administrator to do so. If this is not possible, you can email greenid.support@gbgplc.com for assistance.
Individuals undertaking identity verification
GBG provides online identity verification services to businesses to assist them to onboard their customers. If you apply for a product or service with any of our customers, we will collect information about you (from you and/or from our customer) in order to verify your identity. In order to do this we will need to provide your information to our data partners to confirm your details.
To verify your identity, we are required to collect a variety of information from you including your:
If you undertake your identity verification via our greenID mobile or web channels, we may also collect:
This information is processed by our IDScan product and you should refer to the relevant section of this privacy notice to understand any potential cross border transfers of your data.
How we use your personal information
We use the personal information we collect about you for the following purposes:
Your information will be held for a period of time in order to support our customers onboarding processes. That timeframe is negotiated between GBG and it’s business users depending on their requirements.
Who will we share your data with and why?
We will always disclose your personal information and identify verification to our clients with whom you apply for a product or service.
We will need to provide some of your personal information to the third-party service providers we use to help us provide our services e.g. credit reporting bodies, government agencies, external data storage providers etc. We may also disclose your personal information to our affiliates and related companies in order to undertake our normal business practices.
If we provide your personal information to any of these entities, we will always require them to manage it in accordance with the Australian Privacy Principles and/or the Information Privacy Principles in New Zealand. We may also provide your information to third parties if we are required to do so by law or under some unusual circumstances which are permitted under the Privacy Act 1988 (Cth), or the Privacy Act 2020 in New Zealand.
Accuracy of your personal information
The information that GBG holds on you is a record of an identity verification at a point in time. Whilst it is unlikely we would amend that information, should you have any queries in relation to that data you can email us compliance@gbgplc.com.
We may pass any correction request to our customer or such other third party which collected the information from you.
Transfer of personal information between Australia and New Zealand
If you are the customer of an Australian business using greenID, your personal information will be collected and stored in Australia.
For customers of our New Zealand businesses, your personal information will be collected in New Zealand, and transferred to Australia to be stored.
Loqate Inc. and Mastersoft (collectively,”Loqate”) take the protection and security of your personal information very seriously. Loqate is part of the group of corporate companies belonging to GB Group PLC group of entities (collectively, “GBG”).
This Privacy Policy applies to the Loqate (www.loqate.com/anz/) website and Loqate products and services offered in Australia and New Zealand.
What personal information does GBG collect and why?
The majority of personal information that we collect on individuals, with the exception of any B2B personal information (detailed below), is provided to us by our B2B clients for us to process on their behalf as their service provider. We perform these services to help our business clients better serve their consumers and to help with their cost-savings. The services we perform for our B2B business clients as their service provider includes the following: name, phone, email, and address validation, cleansing, and de-duplication and deceased suppression.
We may collect the following personal information on you from our B2B clients or from other service providers that we use to provide our B2B clients with the information we need to perform our contractual obligations to those clients. This information may include the following categories of personal information: name, phone, IP address, email address and physical address.
If you are a B2B client or prospective B2B client, we may also collect the following information from you: name, title, business contact details such as business address and business phone number, business credit/debit card billing information, user IDs and passwords, IP address, survey responses, and any additional information that you provide to us directly or through our websites or software applications. We use this for business and commercial purposes, such as being able to reach out to potential business prospects and to transact with our clients.
Who will we share your data with and why?
We will always disclose your personal information and identify verification to our B2B clients with whom you apply for a product or service.
We will need to provide some of your personal information to the third-party service providers we use to help us provide our services e.g. credit reporting bodies, government agencies, external data storage providers etc. We may also disclose your personal information to our affiliates and related companies in order to undertake our normal business practices.
If we provide your personal information to any of these entities, we will always require them to manage it in accordance with the Australian Privacy Principles and/or the Information Privacy Principles in New Zealand. We may also provide your information to third parties if we are required to do so by law or under some unusual circumstances which are permitted under the Privacy Act 1988 (Cth) in Australia, or the Privacy Act 2020 in New Zealand.
Accuracy of your personal information
The information that GBG holds on you is a record of a transaction at a point in time. Whilst it is unlikely we would amend that information, should you have any queries in relation to that data you can email us compliance@gbgplc.com.
We may pass any correction request to our B2B client or such other third party which collected the information from you.
Cross-Border Data Transfers
Loqate ANZ is part of a global organization with business clients located all over the world. The Loqate servers that Loqate uses to process personal information are located in Australia, the United States and the United Kingdom. However, we may collect and transfer information we collect on you from our business clients who use servers located in other countries, where the privacy laws may be different from the country in which you reside or are located in. GBG will take appropriate technical, contractual, and organizational measures to ensure the security of your personal data when processed.
How long do we retain your personal information for and why?
For account management purposes, we will retain the personal information we collected from you for as long as we have the relationship with your organization. If GBG no longer has a relationship with your organization then we will only keep the relevant information such as invoices for audit purposes 6 years after the relationship with GBG has ended. Once GBG are informed, you are no longer the contact we need to liaise with or your leave your organization, we will remove your details from our system.
For information that our B2B business clients provided to us on you for us to perform our contractual obligations to them as their service provider, we will retain this information for as long as it is reasonably necessary for us to complete performance, for the duration of our legitimate business interests, and/or comply with any audit or legal obligations.
As an individual, you have rights regarding the processing of your personal information, these are:
Please keep in mind that some of these rights are subject to an internal assessment that one of the grounds set out in the applicable Privacy Act is satisfied.
You can send these requests to compliance@gbgplc.com or by post to:
Data Protection Manager
GBG
Level 4 / 360 Collins St
Melbourne
Victoria 3000
Australia
Or call us on +61 (0)3 8595 1500.
You are not required to pay any charge for exercising your rights. We will always aim to provide you with access within 30 days (if the Australian Privacy Act applies) or within 20 working days (if the New Zealand Privacy Act applies) but in some cases, it may take longer. If GBG are unable to comply with your request, we will provide you with an explanation.
We appreciate that at GBG we may not always get things right and it is regrettable for us as an organisation when we receive a complaint. We take all complaints seriously and can assure you we will do our best to deliver a satisfactory outcome. If you do wish to complain about how your personal information is used by GBG then please write to us at:
Data Protection Manager
GBG
Level 4 / 360 Collins St
Melbourne
Victoria 3000
Australia
Or call us on +61 (0)3 8595 1500.
You can also email us at compliance@gbgplc.com.
GBG will investigate and respond within 10 working days of receipt of your complaint. This allows us time to investigate your complaint thoroughly.
Where you believe that GBG have not taken our responsibilities with your personal information seriously, you have the right to complain to the applicable Supervisory Authority. If your complaint arises under the Australian Privacy Act/APPs you must first raise your concerns with us and give us 30 days to satisfactorily resolve your complaint If your complaint arises under the New Zealand Privacy Act/IPPs, we ask that you do the same. The details for the Supervisory Authorities are as follows:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney
NSW 2001
Australia
Telephone number: 1300 363 992
Email: enquiries@oaic.gov.au
Office of the Privacy Commissioner
PO Box 10094
Wellington 6143
New Zealand
Telephone number: 0800 803 909
Email: enquiries@privacy.org.nz
