Perenti Global Privacy Policy

Overview – the key information you should be aware of

The detail – the key information you should be aware of

How we obtain your personal information

You may provide us with your personal information voluntarily. We may also receive information about you from third parties such marketing agencies, market research companies, our suppliers, contractors and consultants at our sites, group companies, public websites and public agencies, which we refer to as “third party sources” or “suppliers” throughout this policy.

You may give us personal information about yourself by using the online forms provided on our website, or by contacting us by phone, email or other means. This includes, for example, where you or your employer provide your personal information to us in order to receive products, deliveries, information or services from us. If you or your employer are a supplier, you or your employer may also give us personal information about you when offering or providing services to us.

Collection of your personal information and how we use it

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as “personal information” throughout this policy.

Visitors to our website
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us;
(vi) any updates to information provided to us;
(vii) personal information we collect about you or that we obtain from our third party sources;
(viii) the following information created and recorded automatically when you visit our website:
(A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages.
(B) Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to allow you to access and use our website;
(ii) to receive and respond to enquiries from you through the website about our business;
(iii) for improvement and maintenance of our website and to provide technical support for our website;
(iv) to ensure the security of our website and IT systems;
(v) to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and
(vi) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
Please also see here for more details about how we use your personal information.
(c) A word about cookies
(i) Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
(ii) Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.
(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy.

Clients, and employees of clients
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your car registration number;
(vi) information provided when you correspond with us;
(vii) any updates to information provided to us;
(viii) information about the business and associated services we provide to you or your employer:
(A) information needed to provide the services to you or your employer (including information on joining forms, order details, order history ,payment details, tax file number and ABN);
(B) client services information; and
(C) client relationship management and marketing information;
(ix) health and safety information, including any accidents you have at one of our properties;
(x) closed circuit television (CCTV) recordings, if you visit one of our sites; and
(xi) information you provide to help us provide you with improved service, for example if we ask you to fill in a survey or questionnaire.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to provide or facilitate the supply of our business and services to you or your employer;
(ii) to keep a record of our dealings with you or your employer;
(iii) to deal with any enquiries or issues you or your employer have about our business and services;
(iv) to send you certain communications (including by email or post) about our business and services such as administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
(v) to ensure your safety and security and that of others, by the use of CCTV;
(vi) to carry out statistical analysis and market research on people who may be interested in our business and services;
(vii) if it is in our legitimate interests for business development and marketing purposes, to contact you (including by telephone or post) with information about our business and services which either you request, or which we feel will be of interest to you; and
(viii) if you are a sole trader or a non-limited liability partnership and if you have consented, to contact you by email with information about our products and services or the products which either you request, or which we feel will be of interest to you.
Please also see sections 2.8 and 2.9 for more details about how we use your personal information.
(c) Special categories of data. Please note that we do not generally collect any sensitive information or special categories of personal information.
(d) Information we need to provide services to you. We need certain types of personal information so that we can provide services to you or your employer and perform contractual and other legal obligations that we have to you or your employer. If you do not provide us with such personal information, or if you ask us to delete it, you or your employer may no longer be able to access our business or services.

Prospective clients to whom we send marketing communications
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number; and
(v) information about your preferences.
(b) How we use your personal information
We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by telephone, email or post) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters).
Please also see here for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third party sources, such as referrers, publically available data sets and information services providers.

Investors
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your date of birth;
(v) your telephone and/or fax number;
(vi) your tax file number and/or ABN;
(vii) details in respect of your shareholding, including number and type of shares held; and
(viii) your voting record.
(b) How we use your personal information
We will use your information for the purposes of managing your shareholding, providing you with information about your shareholding and/or Perenti and to comply with the shareholders’ agreement.
Please also see here for more details about how we use your personal information.

Our suppliers, and employees of our suppliers
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) work contact information (phone number, postal address, mailing address, email address);
(iii) your job title;
(iv) your gender;
(v) your date of birth;
(vi) information provided when you correspond with us;
(vii) any updates to information provided to us;
(viii) personal information we collect about you from third party sources such as LinkedIn:
(ix) CVs, pitch and tender information;
(x) proof of identification and address;
(xi) visa or work permit documentation;
(xii) details of compensation, expense claims and bank details;
(xiii) information required to access company systems and applications (such as system ID);
(xiv) work hours (overtime and hours worked); and
(xv) if you attend our sites, CCTV recordings.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to enable us to purchase and receive products and services from you or your employer (including supplier due diligence, payment and expense reporting and financial audits);
(ii) to assess your working capacity;
(iii) to deal with enquiries from you or your employer;
(iv) to confirm information on CVs and performance reference checks, to assess you or your employer’s suitability to work for us;
(v) for equal opportunities monitoring;
(vi) for health and safety records and management;
(vii) for security vetting and criminal records checks (where applicable and allowed by law); and
(viii) for CCTV monitoring and other security of company facilities.
Please also see here for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third party sources, such as your employer or your employer’s company website. We may also collect this personal information from publicly available sets and information service providers, such as LinkedIn.
(d) Special categories of data. Please note that we do not generally collect any sensitive information or special categories of personal information.
(e) Information we need to provide services to you. Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer ask us to delete it, you or your employer may no longer be able to provide services to us.

Prospective employees
(a) We, or third parties on our behalf, may collect and use any of the following information about you when you apply for a job with us and during the recruitment process:
(i) your name including your title;
(ii) your postal address;
(iii) your email address
(iv) your telephone and/or fax number;
(v) your age;
(vi) your gender;
(vii) your citizenship;
(viii) your right to work;
(ix) your employment history, professional experiences, qualifications, education history, professional certifications and/or professional memberships;
(x) your photograph;
(xi) your language capabilities;
(xii) your corporate interests (including but not limited to directorships in third parties);
(xiii) your health;
(xiv) your financial probity;
(xv) personal information we collect about you from third party sources such as LinkedIn:
(xvi) any information provided to us pursuant to us running background checks for the purpose of considering your application, including but not limited to identity, criminal history and social media checks;
(xvii) any information provided to us when you correspond with us and/or are interviewed by us;
(xviii) health and safety information, including any accidents you have at one of our properties; and
(xix) CCTV recordings, if you visit one of our sites.
(b) How we use your personal information
(i) to manage and consider your application;
(ii) to contact you throughout the recruitment process and provide you with updates on the status of your application;
(iii) to verify your personal information, including to conduct background checks for the purposes of considering your application, which may involve us using and sharing your personal information with a third party supplier for this purpose;
(iv) to deal with any enquiries you may have;
(v) to ensure your safety and security and that of others, by the use of CCTV;
(vi) to carry out statistical analysis on our applicants; and
(vii) where you have requested or agreed that we do so, contact you with details of vacancies that you may be suitable for and/or interested in.
Please also see here for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third parties, such as recruitment agents, vetting or background check service providers and search providers.
(d) Special categories of data. Some of the personal information which you may provide to us in your job application may be sensitive information or special categories of personal information. This includes information regarding physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data. If you choose to not provide or object to us obtaining such information, we may not be able to place you into a job.

People who contact us with enquiries
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us; and
(vi) any updates to information provided to us.
(b) How we use your personal information
We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our products and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for client services purposes.
Please also see here for more details about how we use your personal information.

Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for client services purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities and systems, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

Further processing
If you are based in the EU, before we use your personal information for any purposes which fall outside those set out in this section 2, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out here. Please contact us using the details here if you want further information on the analysis we will undertake.

Legal basis for use of your personal information

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or
(b) our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
(c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
(i) run, grow and develop our business, including but not limited to forming and maintaining business relationships and engaging in business sales, acquisitions or joint ventures;
(ii) operate our website;
(iii) respond to your enquiries or other communications;
(iv) keep a record of our dealings with you;
(v) select appropriately skilled and qualified suppliers;
(vi) ensure a safe environment for our employees and suppliers;
(vii) carry out marketing, market research and business development;
(viii) place, track and ensure fulfilment of orders with our suppliers;
(ix) manage and consider your job application; and
(x) for internal group administrative purposes.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. If you are based in the EU, you can ask us for information on this balancing test by using the contact details here.

If you are based in the EU, we may use your special categories of data (such as health and wellbeing information) where you have provided your consent (which you may withdraw at any time after giving it, as described below).

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

How and why we share your personal information with others

We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

We will share your personal information with the following third parties or categories of third parties:
(a) subcontractors, who we use to indirectly provide you with our business or services. Such suppliers will also share your personal information with us;
(b) our IT service providers, such as My Recruitment, MYOSH, Pronto, Moodle, SAP, and Salesforce, who may access personal information stored within their respective solutions when providing support and maintenance purposes;
(c) we may share anonymised and aggregated statistical information with our suppliers to demonstrate what interest there has been in any marketing campaigns we have assisted our suppliers in carrying out;
(d) our other service providers and sub-contractors, including those that assist us with archiving, auditing, accounting, customer contact, legal, business consulting, banking, payment, debt collection, delivery, data processing, data analysis, information broking, research, investigation and insurance;
(e) companies that assist us with our recruitment process, for example, background check services;
(f) companies that assist in our marketing, advertising and promotional activities; and
(g) analytics and search engine providers that assist us in the improvement and optimisation of our website.

Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

We will also disclose your personal information to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop our business, such as:
(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
(ii) if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials, rules of any stock exchange and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(c) in order to enforce or apply our terms of use, our terms and conditions for clients or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity;
(d) to protect the rights, property, or safety of Perenti, our staff, our clients or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction; or
(e) where you have provided your consent to such sharing or, if you are based outside of the EU, where your consent can be reasonably inferred from the circumstances.

We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable you to be personally identified.

Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at privacyofficer@perentigroup.com at any time.

All individuals have the following rights:
(a) Right of access. You have a right of access to any personal information we hold about you.
(b) Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.

If you are based in the EU, you have the following additional rights:
(a) Right of access. In addition to the right of access, you can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA”).
(b) Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details here.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details here.
(c) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details here.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details here.
(d) Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
(e) Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.
This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(f) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Marketing

We may collect and use your personal information for undertaking marketing by email telephone and post.

We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.

However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

If you wish to stop receiving marketing communications, you can contact us by email at privacyofficer@perentigroup.com.

Where we may transfer your personal information

Your personal information may be used, stored and/or accessed by staff operating outside of your country of residence working for us, other members of our group or suppliers. These countries include: Australia; Botswana; Burkina Faso; Canada; Cote D’Voire; Denmark; European Union; France; Germany; Ghana; Guinea; Hong Kong; Ireland; India; Mali; the Netherlands; New Zealand; Norway; Senegal; Singapore; South Africa; Spain; Switzerland; Tanzania; United States; the United Kingdom; and Zambia. Further details on to whom your personal information may be disclosed are set out here.

You expressly consent to the disclosure of your personal information to overseas recipients, including to third party service providers’ information systems. Such overseas disclosures may be to recipients located in those countries identified above.

If you are located in Australia, you acknowledge that we have informed you that we will not be required to comply with Australian Privacy Principle 8.1. As a result, Perenti will not be accountable and you will not be able to seek redress under the Australian Privacy Act 1988 (Cth) if an overseas recipient handles your personal information in breach of the Australian Privacy Principles.

If you are based in the EU and we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:
(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
(b) in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them. (This does not apply to entities based in countries which the EU considers provides adequate protection for personal information, including Canada, New Zealand and Switzerland.)

Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at privacyofficer@perentigroup.com at any time.

Risks and how we keep your personal information secure

The main risk of our processing of your personal information is if it is lost, stolen or misused, this could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

For this reason, Perenti is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. In particular, we:
(a) embed privacy protections into the design of information handling practices to protect personal information from unauthorised access, modification, deletion and disclosure;
(b) periodically review our IT systems for vulnerabilities;
(c) ensure that the personal information stored is accurate and up-to-date; and
(d) where personal information is no longer required by law or for the primary purpose it was obtained, destroy or de-identify it.

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted by you to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

In the event that we become aware of a data breach, we will contain, assess and respond to the breach appropriately to minimise potential damage to the affected people and resolve issues promptly. Where appropriate, we will notify the affected individuals and/or the relevant data protection authority in your country.

Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page (perentigroup.com/privacy-policy) and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.

Further questions and how to make a complaint

If you:
(a) have any queries or complaints about our collection, use or storage of your personal information;
(b) wish to exercise any of your rights in relation to your personal information; or
(c) believe that we may have breached our obligations under applicable privacy law or have failed to comply with this privacy policy,
please contact our Privacy Officer using the contact details here. We will respond as soon as possible, and generally within 30 days of receiving your correspondence.
We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

If we refuse to your request to exercise your rights in relation to your personal information, we will notify you in writing setting out a written explanation of the reasons for the refusal (unless unreasonable to do so).

If you would like to contact our Privacy Officer, please:
(a) email privacyofficer@perentigroup.com;
(b) telephone +61 8 9321 6520; or
write to Privacy Officer, Perenti Global Limited, Level 2, 202 Pier Street, Perth, WA 6000, Australia.

If you are dissatisfied with the our response to your request or complaint, you may also make a complaint to the data protection regulator in the country where you usually live or work, or where an alleged infringement of the relevant data protection legislation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of 30 June 2020.