Privacy Notice – Austral Facility Services

Last updated: 25/08/2026, Version 1.0

Austral Facility Services (“AFS”, “we”, “us”, “our”) is committed to handling personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This policy explains what personal information we collect through the AFS Connect mobile app and the systems it connects to, why we collect it, how we hold it, who we disclose it to, and how you can access it, correct it, export it, or complain about how we have handled it.

Entity details:

Name: EMG Facility Services Pty Ltd, trading as Austral Facility Services

ABN: 66 623 184 529

Head Office: 25/23 Ashtan Place, Brisbane 4014

1. Who this policy applies to

AFS Connect is used by contractor personnel engaged by contractor companies that supply services to AFS client sites, and in some cases by sole traders contracted directly. Users of the app are generally not direct employees of AFS.

Because of this, AFS does not rely on the “employee records” exemption in section 7B(3) of the Privacy Act in relation to information handled through AFS Connect. We treat all personal information collected through the app as fully within the scope of the Privacy Act and the APPs.

This policy applies to:

• individuals who use AFS Connect to take up shifts and to clock in and out (“users”, “you”);
• managers at contractor companies, who hold their own AFS Connect accounts; and
• parents or guardians who provide details in connection with a user under 18 (see section 16).

2. The systems this policy covers

SYSTEM                                               ROLE

AFS Connect                                  The contractor mobile app (iOS and Android) – shift information and geofence-verified clock-in and clock-out.

AFS middleware                            AFS-operated integration layer between AFS Connect and Deputy. It holds the record linking each AFS Connect user to a

                                                          placeholder position in Deputy. 

Deputy                                             Third-party workforce management platform used for rostering, timesheets and location mapping. Deputy holds placeholder

                                                                  positions, not named individuals. See section 8.

AFS internal systems                    AFS-operated hosting and administration, in Microsoft Azure (Australia East).

This policy does not cover the separate privacy practices of your own employer, of AFS’ clients, or of any third-party service you reach from a link in the app. Those organisations have their own privacy policies.

3. What personal information we collect

CATEGORY                                                               EXAMPLES                                                                                        SOURCE

Identity and contact                                        First and last name, email address,                                     Your account activation; details

                                                                             phone number                                                                         supplied by your employer

Engagement                                                      Contractor company, role                                                     AFS Connect

                                                                             (contractor or manager), site

                                                                             assignment

Shift and attendance                                       Shifts taken up, rostered start and                                       AFS Connect, synchronised with

                                                                             end times, clock-in and clock-out                                        Deputy against a placeholder

                                                                             timestamps                                                                               position (see Section 8)

Location                                                             GPS coordinates and distance from                                     AFS Connect (device location

                                                                             the assigned site, captured at the                                         services), only while you are

                                                                             moment of clock-in and clock-out                                        actively clocking in or out

Guardian details                                               Name and contact details of a parent                                   Contractor onboarding (see

                                                                             or guardian, where a user is under 18                                   Section 16)

What we do not collect

• No background location tracking. See section 4.
• No camera, photo library, contacts, microphone or biometric access. The app does not request these permissions and does not use facial or fingerprint verification.
• No free-text notes. AFS Connect does not provide a notes field.
• No push notification tokens. The app does not use push notifications.
• No sensitive information as defined in section 6 of the Privacy Act – no health information, racial or ethnic origin, religious beliefs, or union membership.
• No payment or bank account details. You are paid by your employer, not by AFS. AFS Connect does not handle payment information and is not a payroll system.

4. Location – how the geofence works

Location is the most sensitive information the app handles, so we set out our practices in full.

When location is read

Location is read only at the moment you take an explicit clock-in or clock-out action. It is not read at any other time.

We do not track your location in the background or when the app is closed. On iOS the app requests “when in use” permission only and does not request “always” or background location. On Android the app requests ACCESS_FINE_LOCATION and ACCESS_COARSE_LOCATION only and does not request ACCESS_BACKGROUND_LOCATION.

We do not use location to build a movement history, to monitor you between clock-in and clock-out, or for any purpose unrelated to confirming site attendance.

What we use it for

We compare your location against the boundary of your assigned site – a “geofence” check. The purpose is to establish the hours actually spent on site, so that these can be compared against the hours invoiced by your contractor company. The purpose is the hours, not your whereabouts.

The app never blocks you

AFS Connect will not stop you clocking in or out. This matters, so we are explicit about each case:

• If location is unavailable – no signal, no GPS fix, or permission declined – the app records your clock-in or clock-out immediately, without a location, rather than making you wait. If the location permission is granted, the app then keeps trying quietly in the background for up to around 10 minutes, for as long as the app stays open, and fills in the location on your existing record if it succeeds. Either way, your attendance is recorded straight away and never help up waiting on a location fix. The record is marked as not location-verified unless and until that happens.
• If you are outside the site boundary, the app tells you so, and still records the clock-in or clock-out. It notifies your contractor company’s manager and the AFS Client Service Manager so the difference can be discussed. It does not block you and does not automatically affect anything.
• If you decline the location permission entirely, you can continue to use the app and to clock in and out. Your records will not be location-verified.

You control the location permission through your device settings and can withdraw it at any time, with no consequence to your ability to use the app.

Data held briefly on your device

If your device has no network connection when you clock in or out, the event – including the location captured at that moment – is held on your device, encrypted, and sent to AFS automatically once connectivity returns. It carries the time recorded on your device at the moment of the action.

Events held on the device for more than 12 hours are marked as unverified.

Workplace surveillance

Recording your location at clock-in and clock-outs is “tracking surveillance” under the Workplace Surveillance Act 2005 (NSW) and the Workplace Privacy Act 2011 (ACT), and is regulated as use of a tracking device under surveillance devices legislation in Victoria, Western Australia, South Australia and the Northern Territory. Under the NSW and ACT Acts, AFS is treated as an employer in relation to labour-hire personnel working at AFS sites, even though AFS is not  your direct employer.

AFS therefore issues a separate Workplace Surveillance Notice, applying nationally, which sets out the kind of surveillance, how and when it is carried out, and how the information may be used. This privacy policy does not replace it.

The clock-in and clock-out screen also display a visible notice telling you that taking that action will record your location.

5. How we collect personal information

We collect personal information:

• directly from you, when you activate your account, take up a shift, or clock-in or out; and
• from your employer, which supplies your name, contact details, role and site assignment so your account can be created, and which identifies users under 18.

Where we collect information about you from your employer rather than from you directly, we take reasonable steps to ensure you are made aware.

6. Why we collect, hold, use and disclose it

We collect and use personal information to:

• give you the shift information you need to do your work;
• record when you start and finish at an AFS client site;
• establish the hours actually worked onsite, and compare them against the hours invoiced by your contractor company under a purchase order;
• identify differences between recorded attendance and invoiced hours, so they can be discussed;
• communicate with you, and with your contractor company, about shifts, attendance and your account;
• administer, secure and support AFS Connect, including investigating misuse;
• meet our obligations under work health and safety law and our contracts with clients and contractor companies; and
• comply with any other legal obligation, or respond to a lawful request from a court, regulator or law enforcement agency.

AFS does not use this information for payroll. You are paid by your employer. AFS uses attendance records to verify invoices from your employer against purchase orders, which is a different purpose.

We do not sell personal information, and we do not disclose it to third parties for their own marketing purposes.

8. Deputy and how we minimise what is shared

AFS Connect and Deputy do not exchange your name.

Rostering in Deputy is done against placeholder positions rather than named individuals. A shift is published through the AFS middleware to AFS Connect, where you take it up. Attendance data is written back against the placeholder.

The record connecting you to a placeholder is held only in the AFS middleware, under AFS’ control. It is never sent to Deputy.

Placeholder do not identify you individually. Deputy allocates each shift to a placeholder position to satisfy its own scheduling rules – for example, so that shifts on the same day don’t conflict with each other in its system. This allocation happens independently of, and separately from, the decision about which of AFS’ contractors will actually perform the shift; whoever allocates the placeholder in Deputy has no way of knowing, and has no need to know, who that will be. In practice the same placeholder is often used across several different people’s shifts, including more than one person on the same day. Deputy holds no record connecting a placeholder to your name, email address, or contact details.

What Deputy does receive: shift and roster data, clock-in and clock-out times, and the location coordinates captured at those moments. AFS uses Deputy’s built-in mapping and geofencing to display where a clock-in or clock-out occurred relative to the site, rather than building a duplicate capability.

What Deputy does not receive: your name, email address or phone number; any free-text content, since AFS Connect has no notes field; and the record linking you to a placeholder.

AFS has confirmed that no identifying information about any user has been provided to Deputy’s support personnel.

Two things this does not mean, which we state plainly rather than overclaim:

• The information is pseudonymous, not anonymous. AFS holds the link, so in AFS’ hands the combined record is personal information and is protected under this policy.
• It does not remove all possibility of identification. A location recorded away from a work site, or at a site where very few people work, may in some circumstances point to an individual even without a name attached.

9. Disclosure of personal information overseas (APP 8)

Under APP 8 (Australian Privacy Principles, Section 8), before we disclose personal information to an overseas recipient we must take reasonable steps to ensure that the recipient does not breach the APPs, unless an exception applies. Under section 16C of the Privacy Act, we generally remain accountable for acts of an overseas recipient that would breach the APPs.

AFS systems. All AFS-operated systems – the app back end, the middleware, and the record linking you to a Deputy placeholder – are hosted in Microsoft Azure, Australia East. This information is stored in Australia.

Backups are held in Australia East, and all administrative and support access to these systems is handled in-house by AFS, based in Australia – no offshore support access. 

Deputy. The AFS tenant is hosted on AWS (Amazon Web Services) infrastructure, in an Australian region, and Deputy’s support for AFS is also Australia-based. 

10. How we store and secure your information 

Personal information is held in AFS’s systems in Microsoft Azure (Australia East), and – in the limited form described in section 8 – in Deputy. 

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, including: 

• restricting access to authorised AFS personnel and to your own contractor company’s management users, on a role-based basis; 
• keeping the record that links you to a Deputy placeholder separate from operational data, and restricting access to it; 
• encrypting the clock events held temporarily on your device before they are sent, in a dedicated on-device queue; 
• caching your current shifts, site location and attendance status on your device in your device’s standard app storage, so the app remains usable briefly offline – this is the same information already described elsewhere in this policy, held locally rather than transmitted, and is not separately encrypted; 
• multi-factor authentication, mandatory on all AFS employee accounts including administrators; 
• logging and monitoring of administrative access; and 
• contractual security obligations on our third-party providers. 

Application usage monitoring. AFS’s backend systems use Microsoft Application Insights to monitor performance and diagnose faults. This records technical details of each request (the web address called, response time, and status) but not the content of what you submit – for example, a clock-in request is recorded as “a clock-in request was made,” not with the location or other details you sent. Your device’s IP address is recorded but truncated for privacy. This data is kept for 30 days. 

11. How long we keep it 

We keep personal information only for as long as it is needed, or for as long as we are required to keep it by law. 

Because AFS is not your employer, the employee record-keeping obligations in the Fair Work Act 2009 (Cth) apply to your employer rather than to AFS. AFS’s retention is driven by our contract with your employer and the period during which an invoice may be queried or audited, by Commonwealth tax law, by work health and safety obligations, and by the limitation periods for bringing a claim. 

INFORMATION                                                                                                           RETAINED FOR

Attendance records – date, site, times, verification status                    6 years

Raw location coordinates                                                                                     60 days, then reduced to a geofence result plus distance from site

Identity and contact details                                                                        For the time using the app, and then 90 days after

Guardian details (section 16)                                                                      While using the app, or age reaches 18 (whichever is first)

Acknowledgement of the surveillance notice                                        1 Year (renewal required each year)

The six-year period for attendance records aligns with the limitation period for contractual claims in Queensland and with the period for recovering underpaid wages, so the record remains available to you as well as to us if a question arises about hours worked. 

Reducing raw coordinates after 60 days means that, beyond that point, we retain whether you were at the site rather than exactly where you were. 

When information is no longer needed and we are not required to retain it, we take reasonable steps to destroy it or de-identify it. 

12. Data breaches 

AFS is subject to the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act. If we suspect a data breach, we will assess it promptly. If we conclude there has been an eligible data breach – one likely to result in serious harm – we will notify the affected individuals and the Office of the Australian Information Commissioner as required by law. 

13. Automated decision-making 

From 10 December 2026, subclauses 1.7 to 1.9 of APP 1, inserted by the Privacy and Other Legislation Amendment Act 2024 (Cth), require an APP entity to include information in its privacy policy where a computer program uses personal information to make, or substantially assist in making, a decision that could reasonably be expected to significantly affect an individual’s rights or interests. The obligation covers rule-based automation, not only artificial intelligence. 

AFS’s assessment is that this obligation does not apply to AFS Connect. The reasoning is set out here so that the assessment is on the record: 

• The geofence comparison is automated, but it produces no automated consequence. The app does not block a clock-in or clock-out in any circumstance. 
• Where a clock-in or clock-out falls outside the site boundary, the result is a notification to your contractor company’s manager and to the AFS Client Service Manager. What follows is a conversation between people. 
• Your access to the app is not determined by geofence results, and your ability to perform contracted work does not depend on the app at all – work is contracted through the purchase order process. 
• The commercial effect of a difference between recorded and invoiced hours falls on the contractor company under its purchase order, and does not automatically stop payment. 
• You can review your own attendance records in the app before your contractor company invoices, so differences can be identified and raised before they reach a decision point. 

14. Accessing, correcting and exporting your information 

In the app. You can see your own attendance history in AFS Connect at any time, and export it as a CSV or PDF file. The export covers your own records only. 

The export is a record of activity in the app – when clock-in and clock-out actions were recorded, and whether each was location-verified. It is not a record of hours worked or hours payable. Hours payable depend on your engagement terms and are determined by your employer, not by AFS.

Requests to us. You may also request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact afsconnect@australfs.com.au.  

We will respond within a reasonable period. Typically within 7 business days. There is no charge for making a request. 

If we refuse access or a correction, we will tell you why in writing and explain how you can complain. 

If a record looks wrong. Tell your contractor company, or contact us, as soon as you can so it can be checked and corrected. 

15. Deleting your account 

You can delete your AFS Connect account:

• from within the app, under Settings; or 
• from our website at /App/DeleteAccount on the AFS Connect web host, if you have already uninstalled the app.