This Policy applies to the use of your Personal Information by OceanaGold and its subsidiaries, unless otherwise stated.
To the extent this Policy is inconsistent with applicable local laws, those local laws will prevail over this Policy to the extent of such inconsistency in relation to the collection, storage, use and disclosure of Personal Information in those jurisdictions.
“Personal Information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified or identifiable individual. Personal Information also includes any information within the meaning given to that term or to similar terms (such as “personally identifiable information” or “personal data”) under applicable local laws.
Whose Personal Information do we collect?
We collect and record Personal Information in the course of our business activities from a range of individuals, including representatives of our suppliers, customers, agents, community groups, industry associations, financiers, joint venture or business partners, our shareholders and investors, employees and contractors, job applicants, and users of our website.
What Personal Information do we collect and hold?
OceanaGold may collect a range of Personal Information in the course of our business activities, including your name, age and/or date of birth, contact details including telephone numbers and contact addresses, email address, geographic location, gender, identification information (eg driving licence details and number), certain financial and payment details, occupation and employment details, including employment status and any previous work experience, information about our employees and shareholders (including tax file numbers, social security numbers and similar information, where relevant), information from or in connection with your resume or job application if you apply for a position with us, health and medical information about our employees, contractors and visitors, and other information relevant to the context of the collection, eg for business-related purposes such as managing business relationships.
How and when do we collect Personal Information?
Generally, we collect personal information directly from the relevant individual who we deal with in the course of carrying out our business and corporate activities, where reasonable and practicable.
We may also collect Personal Information about you from third parties and other sources such as our share registry service and corporate reporting services providers, our related entities, or other third parties (such as a recruitment agency or referee in connection with a job application). We may also supplement the information we collect with information from other sources, such as publicly available databases and publications and social media platforms. We will generally only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
Where the Personal Information we collect includes sensitive information, such as health and medical information (including biometric information eg fingerprints) or information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record/criminal history, we will ask for your consent to collect that information, unless the law allows us to collect it without your consent.
Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
In most cases, if you choose not to provide your Personal Information to us, we may not be able to provide you with requested information or effectively conduct business activities with you. In some circumstances the collection of Personal Information and sensitive information from employees or contractors is required in accordance with our policies and/or the requirements of a particular role. In those circumstances (subject to applicable local laws), if an individual chooses not to provide the Personal Information requested, we may not be able to employ or engage that person.
Employee, contractor and visitor health information
We undertake medical assessments and drug and alcohol testing of employees, contractors, and visitors, in accordance with our more detailed policies and procedures and in order to comply with relevant laws and to protect the health and safety of our workers. This may include pre-employment, exit from employment, post-incident, reasonable cause, random, and periodic testing.
Subject to applicable local laws, medical assessments may be required for all personnel:
- prior to employment to ensure ability to perform job requirements and that the task requirements do not impact on personal health;
- periodically during employment to monitor personnel health and potential impacts of exposures; and
- upon termination of employment to assess if workplace exposures have impacted adversely on the individual’s health.
Information collected via our Website including via cookies and other technology
Your Personal information may be collected by us and by our third party service providers when you access or use our website.
This includes information such as your access times, time zone setting, pages accessed, your IP address and any information downloaded.
Our Website(s) may also use ‘cookies’ from time to time. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We may use this information to enhance the content and services offered on our Website.
Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer’s hard drive. Cookies may also be used for other purposes on our Website.
Some of the content on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.
How do we use your Personal Information?
We use the Personal Information we collected from you for business-related purposes and community engagements, including entering and managing contracts, recruitment and rostering, managing payments and accounts, monitoring workers’ health and potential impacts of exposures ensuring safety and security of workers and onsite visitors including undertaking drug and alcohol testing of staff and visitors to our sites and operations, undertaking administration in relation to our shareholders and share registry, promoting our industry and provide you with any requested information (such as subscribers to our e-newsletters), undertaking regulatory and company-required reporting, investigating and managing incidents and return to work plans, monitoring and ensuring adherence to and compliance with our policies and procedures, investigating and notifying individuals about potential or actual data breaches, and for complying with our statutory and legal obligations.
We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or our corporate email systems or to retain the content of any user session. We may monitor emails sent to and from our workforce and may collect Personal Information of third parties in doing so. We may use this information in connection with our business and corporate activities, for example for internal investigations or in connection with legal proceedings.
You consent to us using your Personal Information in the above ways and as set out in this Policy.
Subject to applicable local laws, we may also collect, use, disclose or otherwise process Personal Information for other purposes not listed in this Policy, for the purpose for which it has been collected, for reasonably related secondary purposes, for purposes which have been consented to by the individual, and for any other purpose required or permitted under applicable law. We may otherwise handle Personal Information in accordance with any exemptions available to us under the law.
When do we disclose your Personal Information?
We may share your Personal Information within the group who need to know for business and legal reasons, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
We may also disclose your Personal Information to professional service providers and advisors who perform functions on our behalf (such as lawyers), medical providers including medical and rehabilitation practitioners for investigating incidents or assessing claims, service providers who assist us in administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development), and to government and regulatory authorities and other organisations as required or authorised by law (eg government authorities for the purposes of statutory submissions relating to an individual’s employment).
We may also disclose your Personal Information to third parties in the event that we buy, sell or merge any business or assets, including to prospective sellers or buyers and financiers.
Given the global nature of our operations and business, your Personal Information may be disclosed to personnel situated outside your own country and we may use off-shore providers in the collection, transfer, storage and handling of the Personal Information. Such country may provide a lower level of Personal Information protection than your own country. By agreeing to this Policy, you consent to the collection, use, storage, and handling of your Personal Information outside of your country.
In particular, your Personal Information may be disclosed to third parties in Australia, the Philippines, Canada, USA, Singapore and New Zealand, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries, which may provide a lower level of protection than applicable data protection laws in your country.
We will however take reasonable steps to require that any overseas recipient deals with Personal Information in a manner that is consistent with the law.
Storage and security of Personal Information held by us
We take reasonable steps to secure Personal Information we collect (for example, it is stored either electronically or in hard copy and protected by safeguards including physical, technical and procedural methods).
If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it, subject to applicable local laws requiring its retention.
Our Website does not provide facilities for secure transmission of information across the Internet. Users should be aware that there are inherent risks in transmitting information across the Internet.
You can access and update your Personal Information
If you would like to access or obtain a copy of the your Personal Information we hold about you, please contact our Privacy Officer. Sometimes, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
We take reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. If you consider your Personal Information is inaccurate, incomplete or out of date, please contact our Privacy Officer to rectify your Personal Information.
It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
How do we deal with complaints about privacy?
If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Policy, please contact our Privacy Officer. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the query or complaint and notify you of the outcome of our investigation.
Updates to this Policy
We may, from time to time, review and update this Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Policy, posted on our website . Any changes to this Policy may be advised to you by updating this page on our website.
What to do if you have a question, problem or want to contact us about our use of your Personal Information or this Policy
- have a query or concern about this Policy or our Personal Information handling processes
- wish to make a complaint in relation to a breach of your privacy
- would like to access your Personal Information held by us
- would like to update or correct your Personal Information held by us, or
- would like to opt out of receiving particular electronic communications (where possible),
please contact our Privacy Officer:
Attention: Privacy Officer
Email: [email protected]
Level 14, 357 Collins Street
Melbourne, VIC, 3000
Phone: +61 3 9656 5300
For the Philippines:
The Data Protection Officer
2F CJV Building, 108 Aguirre Street
Legaspi Village, Makati City
Email: [email protected]
Please refer to our Collection Statements for personal information handling practices of OceanaGold for a specific purpose