Confidentiality & Non-Disclosure Policy

1. Purpose

The purpose of this policy is to protect Divergent Edge Strategies’ ("we", "our", "us") confidential information and the confidential information of our clients, partners, and suppliers. This policy ensures compliance with:

• Contractual confidentiality obligations
• The Privacy Act 1988 (Cth) and Australian Privacy Principles
• Common law duties of confidence

2. Scope

• All employees, directors, contractors, consultants, and suppliers engaged by Divergent Edge Strategies
• All information created, received, stored, or transmitted in the course of our work
• All business locations, whether physical or virtual

3. Definitions

• Confidential Information: Any information not publicly available that relates to business operations, clients, suppliers, intellectual property, finances, strategies, or trade secrets.
• Non-Disclosure Agreement (NDA): A legal contract protecting confidential information shared between parties.
• Need-to-Know Basis: Limiting information access to individuals who require it to perform their duties.

4. Policy Statement

• Protect all confidential information from unauthorised disclosure or misuse
• Limit access to information strictly on a need-to-know basis
• Require NDAs before sharing sensitive information externally
• Honour all contractual confidentiality commitments

5. Types of Confidential Information

• Client contact details and project information
• Business strategies, marketing plans, and pricing models
• Intellectual property, source code, algorithms, and designs
• Financial records, forecasts, and performance data
• Supplier agreements and commercial terms

6. Handling Confidential Information

• Store physical documents in locked cabinets or secure offices
• Protect digital files with strong passwords and access controls
• Avoid discussing confidential information in public or unsecured locations
• Encrypt sensitive data before electronic transmission
• Destroy confidential records securely when no longer required

7. Disclosure Requirements

• The owner of the information has provided prior written consent
• Required by law, court order, or regulatory request (and the owner is notified where legally permitted)
• Necessary to prevent serious and imminent harm, in accordance with legal obligations

8. Breaches of Confidentiality

Examples of breaches include:

• Sharing sensitive documents with unauthorised individuals
• Uploading confidential files to personal cloud storage without approval
• Failing to secure sensitive client data

Breaches may result in disciplinary action, termination of contract, and/or legal proceedings.

9. External Engagements & NDAs

• All contractors, consultants, and third-party providers must sign an NDA before receiving confidential information
• NDAs must specify the permitted use, storage, and return/destruction of information

10. Responsibilities

• Management: Ensure confidentiality obligations are built into all relevant contracts and projects
• Employees/Contractors: Comply with this policy and report suspected breaches immediately
• Suppliers/Partners: Maintain confidentiality standards equal to or greater than those of Divergent Edge Strategies

11. Review & Updates

This policy will be reviewed annually or upon significant changes to operational, legal, or contractual requirements.