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Policies

Purpose

DT Global has issued this Global Privacy Notice (“Privacy Notice”) to provide you working on behalf of the Company and its subsidiaries and affiliates (collectively with DT Global, “DT Global” or the “Company”) with notice about how DT Global collects, uses, and processes your information.

We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Definitions

Personal Information: any information relating to an identified, or an identifiable, natural person.

Process or Processing: any operation or set of operations that are performed upon Personal Information, whether by automatic means or otherwise. This includes the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, disclosure by transmission, dissemination or making available in any other form, linking, alignment or combination, blocking, erasure or destruction of Personal Information.

Sensitive Personal Information: is defined by local law and may include Personal Information relating to an individual’s racial or ethnic origin, political opinions, religious or political beliefs, sexual orientation, trade-union membership, information specifying health or medical conditions, sex life, social security number, or criminal records.

This Policy does not cover data rendered anonymous. Data is rendered anonymous if individual persons are no longer identifiable.

Privacy Notice

The information collected by DT Global about you varies based on the requirements of a particular job position or salary grade, what is appropriate to evaluate and compensate you in an applicable jurisdiction, and what may be required to adhere to applicable employment law or other applicable laws, to ensure the quality of our products and services, and provide a safe workplace for you.

The following are the general categories and some examples of the categories of personal information collected and maintained by DT Global:

Examples of person Information

  • General Information- Name, date of birth, residence address, passport number and holder, national ID number,telephone, e-mail, and professional experience record.
  • Remuneration- Salary, salary grade, bank account numbers, job title

Purposes for Processing Personal Information

DT Global processes personal information to manage business operations, payroll administration, accounting and auditing, assessing qualifications for a particular job or task, you, business and safety and security purposes. These principal purposes include:

  • Human Resources and Personnel Management: DT Global uses information as appropriate to maintain a workforce for DT Global. Some examples are: recruiting, salary calculation and payment, administering labor agreements, managing careers and development, evaluating your performance, training, complying with applicable legal requirements, sharing data with Company affiliates and communicating with you and your representative(s).
  • Business Process Execution and Management: DT Global uses information to run its operations. Some examples are: workforce structuring and restructuring, project management and proposals, managing DT Global assets, hotlines, and employee directories, and business travel management.
  • Safety and Security: DT Global uses information as appropriate to ensure the safety and protection of DT Global employees, resources, and workplaces. Some examples are: protecting occupational health and safety, conducting investigations, recording and monitoring network activity for the purpose of identifying, predicting, and preventing the entry of malicious activity onto or the release of information from DT Global network and computing resources.

As a global company, DT Global transfers your personal information to the United States and to other jurisdictions in order to meet our business and legal requirements. The applicable legal protections in such jurisdictions may not be the same as those afforded in your own jurisdiction.

Special Categories of Personal Information

DT Global may need to collect Sensitive Personal Information. Where required under applicable local law, such Personal Information will only be processed with your consent. Where required by applicable local law or the EU-U.S. Privacy Shield, consent to transfers or uses of Sensitive Personal Information will be opt-in.

Disclosures

  • Affiliates: DT Global entities share information among DT Global subsidiaries and affiliates for the purposes described in this Privacy Notice where consistent with applicable legal requirements.
  • Third Party Agents and Contractors: At times, DT Global entities may decide to share Personal Information to selected affiliated or third-party agents and contractors to perform services on their behalf.
  • OtherThirdParties: DT Global entities disclose certain Personal Information to other third parties: (1) where required by law or legal process (e.g. to tax and social security authorities); (2) where DT Global determines it is lawful and appropriate to perform under an employment or labor agreement or otherwise consistent with the nature of the employment or other relationship; (3) to protect DT Global’s legal rights (e.g., to defend a litigation suit or pursuant to a government investigation or inquiry) or to protect Company employees, resources, and workplaces; or (4) in an emergency where the health or security of you or other person or entity is at stake.

As noted above, DT Global may disclose Personal Information to entities located in the United States and other jurisdictions in order to meet our business and legal requirements. The applicable legal protections in such jurisdictions may not be the same as those afforded in your own jurisdiction. DT Global may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Security and Confidentiality

DT Global takes reasonable and appropriate steps to protect Personal Information against unauthorized access, loss, misuse, disclosure, alteration, destruction and other Processing of Personal Information. These measures take into account the sensitivity of the Processing operation concerned and of the Personal Information concerned, and the risks involved.

DT Global will restrict access to Personal Information to those employees, agents and contractors of DT Global who have a legitimate business need for such access.

Communications and network security controls have been put in place requiring authentication to access computer systems, networks, and other resources. Safeguards are in place to alert DT Global when an actual or suspected unauthorized access takes place. Use of such computer resources is subject to the Electronic Communications Policy, which is not superseded by this Privacy Notice.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider our statutory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal information in our records management retention schedules.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer providing services to us, we will retain and securely destroy your personal data in accordance with our policies and applicable laws and regulations.

Your Rights

You will be provided access to your own Personal Information as required by and in accordance with applicable law. Requests for access, and in general, all data protection related requests, may be made to the local or regional data protection officer, if applicable, or to the local Human Resources department.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

In compliance with the Privacy Shield Principles, DT Global commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding DT Global’s Privacy policy should first contact DT Global at GC lawyer.

You have a responsibility to assist DT Global in keeping the Personal Information DT Global maintains about you accurate, complete and current. If any Personal Information is inaccurate or incomplete, you may request that the Personal Information be corrected or completed. DT Global will correct or delete Personal Information as required by applicable law. You may also request to correct, amend, or delete Personal Information that has been processed in violation of the EU-U.S. Privacy Shield Principles.

Where you have provided your consent to the collection, processing, or transfer of your personal information, you may have the legal right to withdraw your consent. To withdraw your consent, if applicable, contact us at Belen.Nebreda@aecom.com

EU-U.S. Privacy Shield

DT Global complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union to the United States. DT Global has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

DT Global’s participation in the Privacy Shield applies to all Personal Information that is transferred from the European Union, the European Economic Area, and Switzerland to the United States. DT Global will comply with the Privacy Shield Principles in respect of such Personal Information.

DT Global’s accountability for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, DT Global remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless DT Global proves that it is not responsible for the event giving rise to the damage.

If you have a Privacy Shield-related (or general privacy-related) question, we encourage you to contact us at GC lawyer. As explained in the Privacy Shield Principles, a binding arbitration option will be made available to you in order to address residual complaints not resolved by any other means. DT Global is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Other Important Information

This Privacy Notice is effective on July 1, 2019

Privacy laws and guidelines are part of a constantly changing environment. DT Global reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy Notice or any supplemental privacy notice at any time. Any material change to this Privacy Notice will be provided to you. Any questions regarding this Privacy Notice should be addressed to your local Human Resources department, or to our General Counsel at GeneralCounsel@dt-global.com.

Child Protection Policy

DT Global delivers International Development services globally, working with clients in the public and private sectors to achieve a positive and lasting impact on the lives of people around the world.

Our vision in undertaking our work is to create environments that are safe for children, where they are respected, protected and empowered and where staff are competent and well supported in meeting their protection responsibilities.

DT Global has a zero-tolerance policy regarding any employees that engage in or support child exploitation and abuse including possession of child exploitation material. DT Global recognizes that it is the shared responsibility of all adults to prevent child exploitation and abuse. The Child Protection Policy is part of DT Global’s child protection framework and it enables DT Global to uphold the United Nations Convention on the Rights of the Child as well as the requirements of our global clients and donors. DT Global endorses the policies of our global clients and donors including the Department of Foreign Affairs and Trade (DFAT). The full text of the DFAT Child Protection Policy can be located here: www.dfat.gov.au/childprotection

The objective of this policy is to apply these principles across all work that we undertake and ensure that DT Global takes all possible steps to ensure the protection of children against all forms of child abuse.

The DT Global Child Protection policy applies to all DT Global personnel (employees, volunteers, visitors, interns, trustees, board members, sub-contractors/consultants, associates and partners including downstream partners). This policy is intended to be read in conjunction with the DT Global’s Code of Business Ethics and Conduct Policy. All employees, sub-contractors/consultants, associates and partners will be referred to collectively as “staff” for the purposes of readability.Personnel covered by this policy who engage in conduct prohibited by this Policy or against any associated laws will be disciplined which may include termination of employment or contract for service.

3.Principles

Principle 1: Zero tolerance of child exploitation and abuse

  • DT Global has a zero-tolerance approach to child exploitation and abuse. Child exploitation and abuse will attract criminal, civil and disciplinary sanctions.
  • DT Global will not knowingly engage—directly or indirectly—anyone who poses a risk to children.
  • DT Global works to minimize the risks of child exploitation and abuse associated with its functions and programs and trains its staff and partners on their obligations under this policy.

Principle 2: Assess and manage child protection risk and impact

While it is not possible to entirely eliminate risks of child exploitation and abuse, careful management can identify, mitigate, manage or reduce the risks to children that may be associated with DT Global functions and projects.

Principle 3: Sharing responsibility for child protection

To effectively manage risks to children, DT Global requires the commitment, support and cooperation of partner organisations and individuals who help to deliver programs managed by DT Global.

Principle 4: Procedural fairness

DT Global will apply procedural fairness when making decisions that affect a person’s rights or interests. DT Global’s partners are expected to adhere to this principle when responding to concerns or allegations of child exploitation and abuse.

Principle 5: Recognition of the best interests of the child

DT Global is committed to upholding the rights of the child and obligations under the United Nations Convention on the Rights of the Child. In all actions concerning children, the best interests of the child shall be a primary consideration.

4.Definitions

Abuse Child abuse may be a deliberate act, or it may be failing to act to prevent harm. Child abuse consists of anything which individuals, institutions or processes do or fail to do, intentionally or unintentionally, which harms a child or damages their well-being, dignity and prospect of safe and healthy development into adulthood”.

Physical abuse—The use of physical force against a child that results in harm to the child. Physically abusive behavior

Neglect—The failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and well-being.

Emotional abuse—refers to a parent or caregiver’s inappropriate verbal or symbolic acts toward a child or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence.

Sexual abuse—The use of a child for sexual gratification by an adult or significantly older child or adolescent. Sexually abusive behaviors can include fondling genitals, masturbation, oral sex, vaginal or anal penetration by a penis, finger or any other object, fondling breasts, voyeurism, exhibitionism; and exposing the child to, or involving the child in, pornography.

Ill-treatment—disciplining or correcting a child in an unreasonable and seriously inappropriate or improper manner; making excessive and/or degrading demands of a child; hostile use of force towards a child; and/or a pattern of hostile or unreasonable and seriously inappropriate degrading comments or behavior towards a child.

Note: the above includes a child or children being present (hearing or seeing) while a parent or sibling is subjected to any of the above. Includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning.

Behavioral-based interview questions- Interview questions that probe the applicant’s past behavior in specific situations relevant to the position. Behavioral-based questions give interviewers additional information about the applicant’s suitability to work with children.

Changes in circumstances- Personnel should report the following changes in circumstances to management:

  • involvement in criminal activity
  • disciplinary procedures and criminal or civil court proceedings relating to child exploitation and abuse.

Child or Children- In line with the United Nations Convention on the Rights of the Child, a child is defined as any person/s under the age of 18.

Child abuse material- Material that depicts (expressly or implicitly) a child under 18 years of age as a victim of torture, cruelty or physical abuse

Child exploitation- One or more of the following:

  • committing or coercing another person to commit an act or acts of abuse
    against a child
  • possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material
  • committing or coercing another person to commit an act or acts of grooming or online grooming
  • using a minor for profit, labour, sexual gratification, or some other personal or financial advantage.
    • specified personnel nominated in a head agreement with an intermediary company (the contractor) to which payment is made; or
    • if the person performing the service is the service provider, he/she is an individual contractor

Child exploitation material- Material, irrespective of its form, which is classified as child abuse material or child pornography material.

Child pornography- In accordance with the Optional Protocol to the Convention on the Rights of the Child, ‘child pornography’ means ‘any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes.’ For further information about child pornography offenses, refer to the Criminal Code Act 1995.

Child pornography material- Material that depicts a person, or is a representation of a person, who is, or appears to be, under 18 years of age and is engaged in, or appears to be engaged in, a sexual pose or sexual activity, or is in the presence of a person who is engaged in, or appears to be engaged in, a sexual pose or activity, and does this in a way that a reasonable person would regard as being, in all the circumstances, offensive.

Child protection- An activity or initiative designed to protect children from any form of harm, particularly that arising from child exploitation and abuse.

Child protection policy- A statement of intent that demonstrates a commitment to safeguard children from harm and makes clear to all what is required in relation to the protection of children. It helps to create a safe and positive environment for children and to show that the organization is taking its duty and responsibility of care seriously.

Child safeguarding- The broad obligation on staff and partners to ensure that the design and delivery of all programs and organizational operations do not expose children to adverse impacts, including the risk of abuse and exploitation, and that any concerns about children’s safety within the communities where they work are appropriately reported.

Contact with children- Working on an activity or in a position that involves or may involve contact with children, either under the position description or due to the nature of the work environment (also see Working with children definition).

Contractor- The individuals engaged to perform specific services under a contract and includes:

Criminal Record Check- A check of an individual’s criminal history record. In Australia, national criminal record checks are available through state and territory police departments. They take around 20 working days. The type of employment should be specified as ‘overseas employment’.

Overseas, different checking procedures apply in each country and may take six weeks or longer.

Individuals need to consent to a criminal record check and should be informed of the purpose for which it will be used including sighting by the client upon their request.

Grooming- Generally, refers to behavior that makes it easier for an offender to procure a child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualize that relationship (for example by encouraging romantic feelings, or exposing the child to sexual concepts through pornography).

Harm- Any detrimental effect on a child’s physical, psychological or emotional wellbeing. Harm may be caused by financial, physical or emotional abuse, neglect, and/or sexual abuse or exploitation whether intended or unintended.

Impact- The overall long-term effect produced by an investment. This includes positive and negative changes produced by an investment (directly or indirectly, intended or unintended).

Informed consent- Ensures the child and the parent or guardian understand the implications, purpose and potential uses of photographs or videos.

On-line grooming- The act of sending an electronic message to a child, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender; or of sending an electronic message with indecent content to a recipient who the sender believes to be a child.

Personnel- Personnel are either employed by an organization, engaged by an organization on a subcontract basis, or engaged by an organization on a voluntary or unpaid basis. Personnel can include paid employees, volunteers, visitors, interns, trustees, board members, sub-contractors/consultants, associates and partners including downstream partners.

Police clearance- The results of a criminal record check, which is issued by the police or other authority responsible for conducting such checks.

Policy non-compliance- The failure to abide by DT Global’s policy.

Statutory Declaration- A written statement which you sign and declare to be true before an authorized witness

Unacceptable risk- The portion of identified risk that cannot be tolerated, and that must be either eliminated or controlled. For people deemed an unacceptable risk, control mechanisms are not considered appropriate.

Working with Children- Working with children means being engaged in an activity with a child where the contact would reasonably be expected as a normal part of the activity and the contact is not incidental to the activity. Working includes volunteering or other unpaid work.

DT Global recognizes the right of a child to grow up safely and will aid the recognition and implementation of this right by training employees and partner organizations and contractually requiring all employees’ contractors and partner organizations to adhere to these principles.

Managers, Team Leaders and Project Managers are required to introduce this Policy to all personnel and to be responsible for adapting the systems and processes necessary for operating effectively in line with the Policy. Project Managers will ensure that the policy is included in the operations manual for their projects and that training is undertaken by project team members.

DT Global aims to increase awareness of risks relating to children and how to manage these risks. DT Global provides an on line training program to all personnel at the time of induction or activity start up and a refresher every two years or more often if required. The training program addresses child protection issues and personnel obligations under the policy, including mandatory reporting of allegations or suspected child abuse or exploitation. Local programs with appropriate country context may be implemented where it is deemed to be required.

Everyone who works with and engages with DT Global has a responsibility to ensure that they always act within the terms of this policy and must:

  • Never abuse and/or exploit a Child or act/behave in any way that places a child at risk of harm.
  • Report any Child abuse and Child protection concerns they have in accordance with this policy.
  • Respond to a Child who may have been abused or exploited in accordance with this policy.
  • Cooperate fully and confidentially in any investigation of concerns or allegations of Child abuse.
  • Contribute to building an environment where children are respected and encouraged to discuss their concerns and rights.
  • Always treat children in a manner which is respectful of their rights, integrity and dignity, considers their best interests and does not expose them to, or place them at risk of, harm. For example: when taking images/pictures during visits, interacting with children or generating stories of children, ensure that this is done in a manner consistent with the appropriate DT Global policies and procedures.
  • Never make any contact with a Child or family members associated with DT Global’s work that is not supervised by a (or another) member of Staff. Such contact may include but is not limited to visits and any form of communication via social media, emails and letters.
  • At all times, bear in mind the principles of this Policy and heighten awareness of how behavior may be perceived both at work and outside work.
  • Frank Maiolo, Managing Director – frank.maiolo@dt-global.com – phone:+61429 387 828
  • Mel Dunn, Vice President – mel.dunn@dt-global.com – phone:+61429 387 828
  • Robyn Cleggett, Director, People & Culture – robyn.cleggett@dt-global.com – phone: +61 414 682 056.

7.Recruitment and screening processes

DT Global is committed to preventing individuals from working with children if they pose an unacceptable risk to children. DT Global has robust human resources and recruitment procedures to assist with the targeted selection of suitable and qualified staff. DT Global will continue to enhance and improve these processes.

All potential personnel candidates who will be working with children will be informed at the time of interview that hiring will be contingent on a criminal history check. For all personnel who may come in contact with children through their position, recruiting personnel are to employ additional screening processes including:

  • Advice to candidates at the point of application that they will be subject to criminal history checks.
  • Prospective employees and sub-contractors are informed of DT Global’s child protection policy early in the recruitment process.
  • Targeted interview questions with emphasis on previous work with children.
  • Verbal referee checks incorporating questions regarding previous work with children.
  • Criminal history check via police checks and global criminal watch reports.
  • Identity Verification

8.Risk Management

DT Global recognizes that there are potential risks to children in the delivery of our programs. We understand that the effects of abuse on children are both devastating and long term. DT Global will undertake the following preventative measures to eliminate unacceptable risk to children:

  • Undertake risk assessments of all programs and implement strategies to minimize risk.
  • Implement Child Safe recruitment and screening processes.
  • All Personnel are required to comply with this policy and sign off on the Child Protection Code of Conduct.
  • Training will be provided to all Personnel.
  • Reporting of any child abuse and protection concerns is mandatory for all Personnel.Failure to do so may result in disciplinary action.
  • Regular Project Reviews are undertaken ensuring that Personnel have undertaken relevant background checks, signed off on the Child Protection Code of Conduct and behaviors are in accordance with the code of conduct.

9.Reporting Child Exploitation or Abuse

In support of DT Global’s zero tolerance of child exploitation and abuse, all Personnel must report immediately any suspected or alleged case of child exploitation, abuse or policy non-compliance by anyone within scope of this policy in connection with official duties or business. All reports should be made in accordance with the ‘Child Protection Reporting Procedure’ available on the DT Global intranet or in the relevant ‘Project Operations Manual’. All information provided will be treated with the strictest confidentiality and steps taken to ensure the rights of both the alleged victim and alleged offender are respected at all times.

Any person who has knowledge of a potential child protection issue involving DT Global must immediately contact their Project Team Leader or a member of the DT Global Management Team:

Each project will place posters in their reception area with details for reporting any suspected case of child abuse or exploitation.The posters will include information for members of the community wishing to make a report as well as how to make anonymous reports.

The recipient of the report will follow DT Global reporting protocols (including reporting to the client who is funding the activity) and ensure the safety of the child. Furthermore, individual projects will adopt the DT Global reporting procedure and adapt to suit any specific requirements of the Client or the project.If the activity is DFAT funded, the incident is to be reported by completing the DFAT Child Incident Notification form (available at: http://dfat.gov.au/about-us/pibliations/Pages/child-protection-policy.aspx and emailed to DFAT’s Conduct and Ethics Unit via email in the first instance – childwlefare@dfat.gov.au.

In the event of an incident of suspected child abuse, DT Global management will immediately put into effect internal reporting steps; seek instructions, where required, from DT Global legal, and the Client, report to local authorities as required; and also give due regard to the appropriateness of informing local law and judicial mechanisms where this is not a requirement. If an expatriate is suspected, due regard must be given to the potential for extra-territorial proceedings by the expatriate’s country of origin. If the accused is an Australian working internationally, the Australian Federal Police will also be contacted.

Any personnel who are under investigation may be suspended or transferred during the investigation.If a personnel member is found to have breached this policy or the behavioral code of conduct they will be dismissed immediately.

Anonymous reports may be made by emailing idev@dt-gobal.com or by calling +61 429 387 828.

DT Global will monitor compliance with the policy through new and existing methods, including performance assessments and reviews. This policy will be reviewed on a periodical basis and as a minimum every 3 years.

DT Global will request updated criminal record checks every 12 months for personnel who may be in contact with children as a result of their work with DT Global.