This Policy sets out the requirements for privacy across Fleetco Pty Ltd and entities it controls (the Group).
This Policy applies to all employees of the Group, third parties engaged by the Group, and all alliances and joint ventures in all jurisdictions.
Any employee of the Group found to have breached this Policy may be subject to disciplinary action.
The objectives of this Policy are to treat personal information:
- in Australia including that of its Australian customers and business partners, in accordance with the Australian Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles (APPs); and
- outside Australia, in accordance with the applicable law.
What personal information do we collect?
Personal information is any information (including an opinion) which can be used to identify an individual. Sensitive information is a subset of personal information which includes information about an individual’s race or ethnicity, political or religious beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record and health information.
Personal information will not be shared, sold or disclosed other than in accordance with this Policy, without an individual’s permission, or in accordance with the Privacy Act.
The Group only collects, holds, uses or discloses personal information where it is reasonably necessary to:
- enable the Group to deliver services or information to individuals or to an organization;
- maintain or establish a business relationship, including as a customer, supplier, contractor, or employee;
- enable the Group to assist to provide services; or to improve, and better understand preferences in respect of the Group services; and
- fulfil legal or regulatory obligations.
Situations in which the Group may collect personal information include:
- recruitment and engagement of employees, including contractors;
- when receiving services from third party suppliers, including subcontractors;
- when providing services to clients or customers;
- when required by law;
- when dealing with certain government agencies;
- when visitors to the Group’s websites provide their personal information, such as name and email address; and
- during safety and operational environment monitoring (including video and two-way radio monitoring).
Personal information that may be collected includes:
- personal details, such as name, mailing address, email address, telephone numbers, age and gender;
- human resource information relating to employees including directors and officers;
- details of visitors to the Group’s premises or sites;
- applications for employment, including information relating to personal skills, work history, experience and details of performance, education, qualifications and skills, professional memberships, hobbies and affiliations;
- details of referees and personal references;
- answers to questions asked to assist the Group to conduct business, including as part of the employment process; and
- stated or likely individual preferences, for example an interest in receiving particular investor or marketing publications.
Personal information can be collected orally, in writing, by telephone, by e-mail, via the Group websites and through other methods of communication.
The Group generally collects personal information directly from the individual to whom it relates, except where that individual has consented to the Group collecting the personal information from a third party or the law otherwise permits the Group to do so, or where it is unreasonable or impracticable to collect it directly.
The Group only collects sensitive information directly from individuals with their consent, or where required, authorised or otherwise permitted to collect the information from a third party by law.
Personal information may also be collected from, and disclosed to, third parties in the course of business activities. For example, steps may be taken to verify that an individual’s academic, training and professional qualifications are accurate and complete and, in appropriate circumstances due to the nature of the available position, health checks, credit checks or criminal records checks may be carried out.
An individual has the option, where lawful and practicable, not to be identified when communicating or entering into transactions with the Group (including by the use of a pseudonym). However, in most circumstances, it will be impracticable for the Group to do business with an individual or provide the services required by an individual unless personal information is provided.
Purposes for which we collect, hold, use and disclose personal information
Personal information will be stored in the Group’s systems for immediate business and administration purposes, as detailed above, and may be used or disclosed for the purpose for which it was collected, or for a related purpose which someone may reasonably expect. Sensitive information will only be disclosed for a purpose which is directly related to the purpose for which it was collected.
Personal information may be disclosed between related bodies corporate within the Group worldwide, and used by those entities for the same purposes for which the collecting company is entitled to use it.
The Group may also disclose personal information to third party service providers and business associates, including our joint venture and alliance partners, who provide services in connection with its business. These third parties may be located locally or overseas.
Disclosure outside Australia
As detailed above, in some circumstances the Group may disclose personal information to entities located outside Australia, including to its own related bodies corporate, third party service providers and business associates.
There are certain safeguards which must be met before the Group is allowed to transfer personal information outside Australia, which are set out in the Privacy Act. Where personal information is disclosed overseas, all reasonable steps will be taken to ensure that the recipient will handle the information in a manner consistent with the Privacy Act.
The Group has operations in many countries. The entities to which personal information may be disclosed may be located in India, Indonesia, Mongolia, southern Africa, South and North America.
The Group may also use or disclose personal information (including to overseas recipients):
- with the individual’s consent;
- where required, authorised or permitted to do so by law; or
- to a person authorised to act on the individual’s behalf.
Information may be disclosed to any person as required by law and specifically to any government agency if the Group believes in good faith that it must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting it.
Confidentiality and security
The Group is committed to:
- safeguarding all personal information provided to the Group;
- ensuring that personal information remains confidential and secure; and
- taking all reasonable steps to ensure that personal privacy is respected.
The Group maintains physical, electronic, and procedural safeguards to protect personal information from misuse, interference, unauthorised access, modification or disclosure, and loss or corruption by computer viruses and other sources of harm. Access to personal information is restricted to those employees, joint venture partners, subsidiary companies, and third parties who need to know that information.
Accessing or correcting personal information
In most circumstances, the Group will make available to an individual upon their request any personal information held about them. Requests to access personal information may be made at any time. The Group will respond to a request within a reasonable time, and in the manner requested, unless there is a legal or administrative reason preventing the Group from do so. In some cases, a reasonable fee may be charged for providing access.
Reasonable steps will be taken to ensure the personal information held is accurate, complete, up to date, relevant and not misleading before it is used or shared.
An individual may request that personal information be corrected or supplemented if the individual believes the information held by the Group is inaccurate or misleading. If the Group agrees, the change will be made. If the Group disagrees, it will advise the individual and include a notation on the record that the information’s accuracy is disputed.
If personal information changes, or if an individual believes that the personal information held by the Group is no longer accurate or complete, the individual should contact the Privacy Officer.
Privacy Officer contact details
The Privacy Officer, Level 5, 179 Grey Street, South Brisbane QLD 4101 Australia
The Group will respond to requests to correct or supplement personal information within a reasonable time period.
Destruction and de-identification of personal information
Records management policies govern the archiving and destruction of records which include personal information.
If unsolicited personal information is received, reasonable steps will be taken to destroy or de-identify that personal information.
A cookie is a small text file downloaded onto a computer or mobile device when a website is accessed, including the Group websites. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website’s owners and third parties.
Cookies allow a website to recognise a computer or mobile device. Cookies do not identify the individual, but do identify the computer or mobile device used to access the Internet, and can therefore be used to collect information about the individual’s use of the Internet. Cookies do not allow access to any information stored on the individual’s computer or mobile device.
Cookies are used:
- to determine the number and global location of visitors to the Group’s websites and to identify how visitors move around the site and, in particular, which pages they visit. This allows the Group’s websites and services to be improved;
- to collect information, where available, about a computer or mobile device for system administration purposes, such as IP address, operating system and browser type.
Links to other websites
The Group’s websites provide hyperlinks to websites owned and controlled by others. The Group is not responsible for the privacy practices of these websites. By accessing or using the Group’s websites, an individual consents to the collection, use and disclosure of personal information as described in this Policy, as amended from time to time.
If an individual has a question, concern or complaint regarding the way in which personal information is handled, or believes that the Group or one of its Operating Companies has breached its obligations under the Privacy Act or has failed to comply with this Policy, they should make a complaint in writing to the Group’s Privacy Officer (contact details above).
The Group will review and respond to any complaint as soon as possible, and generally within 30 days of receiving it. If an individual is not satisfied with the Group’s response, the complaint can be referred to the Office of the Australian Information Commissioner (OAIC). The OAIC will generally only consider a complaint if the individual has first written to the Group and given the Group a reasonable opportunity to resolve the complaint (usually 30 days).
Owner: Legal Manager
Approved by: General Counsel, Managing Director, Executive Chairman, Fleetco Pty Ltd
Effective date: 01 January 2021
Note: The Group reviews and updates this Policy from time to time to reflect its current information handling practices. The Group will notify changes by posting an updated version of the Policy to the Group’s websites.