Govern · jurisdiction
Australia
APP 8 accountability means an Australian breach at a Singapore processor remains an Australian liability. more
The regime that applies here
Privacy and artificial intelligence obligations, as they stand.
Privacy regime
Privacy Act
Privacy Act 1988 and the Australian Privacy Principles
Artificial intelligence regime
Voluntary AI Safety Standard
Voluntary framework — No binding regime. Adherence is a choice and should be described as one.
Transfer adequacy
No adequacy decision
Default mechanism: Standard contractual clauses, EU module two
Supervisory authority
Office of the Australian Information Commissioner
Local obligations that change how work is run
These are operating constraints, not footnotes.
Localization rule
No general localization. APP 8 makes the discloser accountable for the overseas recipient.
Employee consultation
No works council duty. The employee records exemption is under active reform.
What is stored and processed here
One row per class of record, per role, per system.
| Record class | Role | System | Facility | Volume | Note |
|---|---|---|---|---|---|
| agent-telemetry | Stored | This platform platform-core | AWS ap-southeast-2, Sydney | 1,530 | |
| candidate-applications | Processed | Recruiting and Applicant Tracking ats | Vendor cloud, Singapore | 12,858 | |
| compensation | Stored | Core HR and Payroll hcm | Vendor cloud, Sydney | 6,802 | |
| customer-contact | Processed | Customer Relationship Management crm | Vendor cloud, Sydney | 80,316 | |
| employee-master | Processed | Core HR and Payroll hcm | Workday APAC pod, Singapore | 6,802 | |
| health-safety | Stored | Occupational health record store ehs | Vendor cloud, Sydney | 460 | No agent access. |
| performance-records | Processed | Core HR and Payroll hcm | Workday APAC pod, Singapore | 4,124 | |
| supplier-bank | Stored | Group ERP — Financials erp-fi | AWS ap-southeast-2, Sydney | 3,458 | |
| support-transcripts | Processed | Contact Center Platform ccaas | Vendor cloud, Sydney | 77,040 |
Inbound — records arriving here
Lawful basis and impact assessment state for each route.
No routes recorded.
Outbound — records leaving here
Lawful basis and impact assessment state for each route.
XFER-010AU→SGCleared
Shared-service HR administration for the Australian population.
Standard contractual clausesAPP 8 contractual arrangement, executed 2024-08-15Assessment current6,800/mo
Cleared, but APP 8 leaves the Australian entity accountable for anything the Singapore processor does. more
XFER-015AU→SGCleared
Out-of-hours contact center handling for Australian customers.
Standard contractual clausesAPP 8 contractual arrangement, executed 2023-07-14Assessment current33,700/mo
Which functions run work here
Rolled up from the jurisdiction stamped on individual units.
Sales46
Information Technology46
AI GBS & Global Business Services45
Human Resources45
Revenue Growth Management40
Administration37
Research & Development35
Supply Chain32
Legal32
Procurement & Source-to-Pay32
Marketing29
Finance27
Engineering26
Customer Service24