Privacy policy

1. Our commitment regarding the management of your personal information

Australia Pacific LNG Pty Limited (ABN 68 001 646 331) (we, our or us in this Privacy Policy) is a joint venture between Origin Energy Limited (Origin), ConocoPhillips Australia Pacific LNG Pty Ltd (COPA), and Sinopec Australia Pacific LNG Pty Ltd (Sinopec) (collectively, the Shareholders). We respect the privacy of personal information you may provide to us. The way we manage your personal information is governed by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) established under the Privacy Act.

When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, personal information is any information that can be used to identify you; for example, your name, address, telephone number and email address. If the information that we collect identifies you, or your identity can be reasonably ascertained from it, then that information will be personal information.

This Privacy Policy explains how we manage the personal information we hold about you. Please note that this Privacy Policy is to be read subject to any overriding provisions of law or contract.

2. Our management of personal information generally

When you interact or correspond with us, you will ordinarily have to identify yourself, which will involve providing your personal information to us.

This is because it is impractical in most circumstances for you to remain anonymous and we may not be able to do business with you or answer your enquiry if we are not able to identify you or collect your personal information.

If it is practical and appropriate in the circumstances, you may not have to identify yourself when you interact with us or you may use a pseudonym.

The information we collect about you and how we manage your personal information will depend on the nature of your dealings with us. This Privacy Policy contains separate sections under Landholders, Community Engagement & Enquiries and Employees & Contractors. Each section describes how our Privacy Policy applies to you in the ways that you interact or correspond with us.

We may also collect your personal information from third parties you refer to us (for example, your advisers or representatives). If we do so, we will assume and you will ensure that you have made the third party aware of your referral and the purposes involved in the collection, use and disclosure of your personal information.

We may also appoint Origin and/or COPA to collect and manage personal information on our behalf. Where this occurs, Origin or COPA's (as the case may be) Privacy Policy will also apply to any personal information those entities collect about you.

3. Landholders

3.1 What personal information do we collect from landholders?

We (or Origin on our behalf) may collect and hold personal information relating to landholders, including landholders who are contemplating entering into a business relationship with us. Typically, personal information is included in documents that are provided to us (including by you) or which are otherwise associated with our business or other relationship with you.

The types of personal information we may collect include:

  • your contact and identification details such as your name, address, date of birth, telephone number and email address;
  • your banking details and tax details (including your ABN if applicable);
  • any attorneys appointed by you under a power of attorney);
  • any correspondence between you and us; and
  • any other personal information you provide when you make an enquiry, request information, correspond with us or make a complaint.

 

3.2 How do we collect personal information?

We (or Origin on our behalf) will collect your personal information directly from you unless it is unreasonable or impracticable to do so. We may collect personal information directly from you in a number of ways, including through our website, by telephone, through any documents (such as contracts or public records) you provide to us, written correspondence (such as letters and emails), and in person.

We may also collect personal information about you from third parties we deal with, including:

  • our related bodies corporate;
  • our Shareholders;
  • government and law enforcement agencies;
  • our professional advisers (for example, our consultants);
  • our contracted service providers; and
  • any other organisation conducting activities on our behalf.

 

3.3 Why do we collect, hold, use and disclose your personal information?

We collect, use and disclose your personal information to enable us to provide you with the services, products and information you request. In particular, we may use your personal information:

  • our related bodies corporate;
  • our Shareholders;
  • government and law enforcement agencies;
  • our professional advisers (for example, our consultants);
  • our contracted service providers; and
  • any other organisation conducting activities on our behalf.

 

3.4 Disclosing personal information

We may disclose your personal information to other entities in connection with the purpose for which such information was collected.

Some of these entities act or perform functions on our behalf, and if this is the case we will (wherever possible) require that these entities manage your personal information in accordance with the Privacy Act.

These entities may include:

  • our related bodies corporate;
  • our Shareholders;
  • your authorised representative(s);
  • financial institutions (for payment processing);
  • any entity to which we are authorised or required by law to disclose your personal information (such as law enforcement agencies and government and regulatory authorities); and
  • other service providers, for example information technology suppliers, maintenance contractors, mailing services and logistics providers and our professional advisors (such as accountants, auditors and lawyers); and
  • with your consent (express or implied) - other entities.

The above entities may in turn disclose your personal information to other entities as described in their respective privacy policies or notices.

4. Community Engagement & Enquiries

4.1 What personal information do we collect from other members of the community?

We collect personal information from other members of the community who contact us.

Where we interact with community organisations and similar stakeholders, we may also collect personal information about identified individuals or the representatives of these organisations as part of this engagement.

The types of personal information we may collect include:

  • your contact and identification details such as your name, address, date of birth, telephone number and email address;
  • any correspondence between you and us; and
  • any other personal information you provide when you make an inquiry, request information, correspond with us or make a complaint, including information necessary to respond or address any community or other concerns that have been raised with us. If it is relevant to the enquiry or concern, this may include collecting sensitive information (such as health information).

 

4.2 How do we collect personal information?

We will collect your personal information directly from you unless it is unreasonable or impracticable to do so. We may collect personal information directly from you in a number of ways, including through our website, by telephone, through any documents (such as contracts or public records) you provide to us, written correspondence (such as letters and emails) and in person.

We may also collect personal information about you from third parties we deal with, including:

  • our related bodies corporate;
  • our Shareholders;
  • government and law enforcement agencies;
  • our professional advisers (for example, our consultants);
  • our contracted service providers; and
  • any other organisation conducting activities on our behalf.

 

4.3 Why do we collect, use and disclose your personal information?

We collect, use and disclose your personal information to enable us to provide you with the services, products and information you request. In particular, we may use your personal information:

  • to respond to your enquiry or concern;
  • to communicate with you about your business or other relationship with us;
  • if you lodge a complaint with us, to process and respond to your complaint;
  • to update our records and keep your contact details up to date;
  • to do anything which you authorise or consent to us doing; or
  • take any action we are required or authorised by law to take.

 

4.4 Disclosing personal information

We may disclose your personal information to other entities in connection with the purpose for which such information was collected.

Some of these entities act or perform functions on our behalf, and if this is the case we will (wherever possible) require that entities manage your personal information in accordance with the Privacy Act.

These entities may include:

  • our related bodies corporate;
  • our Shareholders;
  • any entity to which we are authorised or required by law to disclose your personal information (such as law enforcement agencies and government and regulatory authorities);
  • our contracted service providers (such as information technology suppliers and mailing and logistics providers);
  • our professional advisors (such as accountants, auditors and lawyers); and
  • with your consent (express or implied) - other entities.

The above entities may in turn disclose your personal information to other entities as described in their privacy policies or notices.

5. Employees & Contractors

5.1 Applicants

If you are applying for a position with us (either as an employee or a contractor), we will ask you to provide specific personal information, such as your name, email address, telephone number, proof of right to work documents, qualifications and career history.

We may also ask you provide other personal information in relation to your application, such as your interests and the position(s) you are interested in.

Any personal information that you provide to us in connection with your application may be used to consider you for current and future employment or engagement as an employee or a contractor. We may disclose any personal information that you provide to our external advisors to assist us in the selection and recruitment process.

If your application is unsuccessful, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. We may retain this information for a reasonable period, for example to enable us to contact you in relation to other employment or contracting opportunities that you may be interested in.

 

5.2 Employees

If you are or become one of our employees, we will collect employee records and personal details, referee reports and other information about you. The handling of your personal information as an employee is exempt from the Privacy Act if it is directly related to your current or former employment relationship with us. However, we will not disclose your personal information for any other purpose, other than as required or authorised by law or to manage your employment relationship with us.

 

5.3 Contractors

If you are engaged by us as a contractor, the Privacy Act will apply to any personal information that we collect, use, hold and disclose about you. The types of personal information we may collect include:

  • your contact and identification details such as your name, address, date of birth, telephone number and email address;
  • your banking details and tax details (including your ABN if applicable);
  • contact and identification details of any third party that you have authorised to negotiate on your behalf;
  • any correspondence between you and us; and
  • any other personal information you provide when you make an enquiry, request information, correspond with us or make a complaint.

We may use your personal information:

  • in order to manage and administer our engagement of you as a contractor;
  • to communicate with you about your business or other relationship with us;
  • to update our records and keep your contact details up to date;
  • to do anything which you authorise or consent to us doing; or
  • take any action we are required or authorised by law to take.

We may disclose your personal information to other entities in connection with the purpose for which such information was collected. Some of these entities act on our behalf, and if this is the case we will require (wherever possible) that these entities manage your personal information in accordance with the Privacy Act.

These entities may include:

  • our related bodies corporate;
  • our Shareholders;
  • any entity to which we are authorised or required by law to disclose your personal information (such as law enforcement agencies and government and regulatory authorities);
  • our employees and other contractors so that these people may contact you in relation to your engagement as a contractor, including to provide instructions or to review and pay invoices related to your engagement;
  • our professional advisors (such as accountants, auditors and lawyers); and

The above entities may in turn disclose your personal information to other entities as described in their privacy policies or notices.

6. Security, quality and location of your information

We rely on the personal information that we receive and hold to conduct our business.

We may store your personal information in different ways, including in hardcopy and electronic form. We have implemented controls around technology and our organisational processes to assist us in protecting your information from misuse, interference and loss and from unauthorised access, modification or disclosure. This includes having in place confidentiality requirements for our employees, document storage security policies, systems and site access restrictions and requiring third parties to satisfy identification requirements. Except to the extent specified otherwise in this Privacy Policy, we will hold your information in an electronic system located in Australia.

We do not sell, rent or trade personal information to or with third parties.

We may be required by law to retain certain information for a set period of time. Once this period of time expires, or where we hold personal information about you and we no longer have any need for the personal information, we will take reasonable steps to destroy, delete or de-identify your personal information in a secure manner. We expect all our employees and contractors to comply with the Privacy Act and our Privacy Policy, and will take appropriate actions to address breaches by employees and contractors of the obligations imposed by the Privacy Act and this Privacy Policy. However we do not accept responsibility for the misuse of personal information by third parties.

7. Our website

7.1 Privacy when browsing our website

This Privacy Policy also applies to your use of our website at www.aplng.com.au and any personal information that you provide to us via our website.

7.2 Information collected through our website

Some of the information that may be collected by us during your visit to our website is not personal information, because it does not reveal your identity. For example, we may record the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used.

If collected, this information will be used and disclosed by us in anonymous, aggregated form only, for purposes including statistical analysis and web site development. However, we reserve our right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

Our websites have electronic security systems in place, including the use of firewalls and data encryption. We take care to store your information in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

However, no data transmission over the internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect users’ personal information, we cannot guarantee or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once we receive your information, we make every effort to ensure its security on our systems. If you are concerned about sending your information over the internet, you can contact us by telephone, email or post.

7.3 Cookies

We may send a “cookie”, a small summary file (containing a unique I.D. number) to your computer. This enables us to recognise your computer and greet you each time that you visit our website. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research the use of our website so that we can improve our online services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

We may log IP addresses (which is the electronic address of a computer connected to the Internet) to analyse trends, administer our website, track users’ movements and gather broad demographic information.

7.4 Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

8. Access and correction

To effectively conduct our business with you, it is important that the personal information we hold about you is complete, accurate and current. At any time while we hold your personal information, we may ask you to tell us of any changes to your personal information.

Alternatively, if you believe that any personal information that we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading and needs to be corrected or updated, please contact us using our details listed in Part 9 below.

If we correct any personal information that we hold about you, you may request that we notify a third party that we have corrected any personal information that we hold about you. We will take reasonable steps to comply with such a notification request if made by you.

You can also ask to obtain access to your personal information that we hold by contacting us at the contact details in Part 9 below. We will always try to provide you with suitable means of accessing your personal information (such as by mailing or emailing it to you). We will also try to provide access to you within a reasonable time, where possible.

We will not charge you for making a request for access or for making any corrections to your personal information. However, we may in some circumstances charge a reasonable fee to cover our costs of providing you with access to your personal information, for example, if you make multiple requests for information, the information requested is voluminous or we incur third party costs in providing you with access to your personal information.

We may not be required to provide you with access or correct your personal information under some circumstances in the Privacy Act (for example, if providing access would be unlawful or would have an unreasonable impact upon the privacy of other individuals). Also, we may not be able to require other entities to provide access to personal information about you. If we decide not to provide you with access to or correct your personal information, we will give you reasons for our decision. Where we do not agree that there are grounds for amendment of your personal information then we will (if you request) add a note to the personal information stating that you disagree with it.

9. Our complaints handling process

Depending on the complaint, our complaints process is handled by us, or by either Origin or COPA. If you believe that your privacy has been breached or you have a complaint in relation to our handling of your personal information, please contact:

  • for contractors directly engaged by us, then APLNG at contact@aplng.com.au;
  • for matters relating to the LNG Plant at Laird Point - COPA; or
  • for all other matters - Origin.

Using the details below for COPA and Origin and provide details of the incident so that it can be investigated:

COPA Contact Details:

ConocoPhillips Privacy Officer

Human Resources
4th Floor, 53 Ord Street
West Perth WA 6005
(PO Box 1102, West Perth WA 6872)
Tel:08 9423 6607
Fax: 08 9423 6659
Email: pauline.a.hastie@conocophillips.com
Attn: Pauline Hastie

Origin Contact Details:

Origin Privacy Officer (LNG Landholder and Stakeholder)
Group Manager, Risk, Assurance & Compliance - Business Integrity

PO Box 148, 135 Coronation Drive, Milton, QLD, 4064

Email: contact@aplng.com.au
Toll free number: 1800 526 369

Details of how Origin and COPA handle privacy-related complaints can be found at www.originenergy.com.au and www.conocophillips.com.au respectively.

 

If you are not satisfied with how your complaint is handled, then you may lodge a formal complaint with the Office of the Australian Information Commissioner at:

Telephone: 1300 363 992 (if calling from outside Australia including Norfolk Island please call: +61 2 9284 9749)

National Relay Service:

  • TTY users phone 133 677 then ask for 1300 363 992 
  • Speak and Listen users phone 1300 555 727 then ask for 1300 363 992
  • Internet relay users connect to the National Relay Service then ask for 1300 363 992

Post: Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
Fax: +61 2 9284 9666
Email
: enquiries@oaic.gov.au
Website
: oaic.gov.au/privacy/making-a-privacy-complaint

10. Changes to our privacy policy

We may change this Privacy Policy from time to time, including in order to comply with the Privacy Act as amended. Any updated versions of this Privacy Policy will be posted on our website at www.aplng.com.au and will be effective from the date of posting.

This Privacy Policy was last updated on 6 March 2014.