WHAT IS PERSONAL INFORMATION?
“Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is in a material form or not. The types of Personal Information that CASTROL collects from an individual will depend on the circumstances in which the information is collected. Generally, the types of Personal Information that CASTROL collects include name, date of birth, gender, financial details (such as credit card details) and contact details. If an individual applies for employment at CASTROL or is a CASTROL contractor, CASTROL may also collect information relevant to the application or engagement including qualifications, resume, bank details, tax information, family details and reference information.
WHAT IS NOT PERSONAL INFORMATION?
Information where CASTROL has removed any reference to an individual will not be Personal Information, provided that the identity of the individual can no longer be ascertained.
PERSONAL INFORMATION CASTROL COLLECTS AND HOLDS
CASTROL collects Personal Information through various avenues in the course of conducting its businesses, including:
- directly from individuals when they provide Personal Information to CASTROL or its agents or contractors, for example when the individual is involved in acquiring goods or services from CASTROL or supplying goods or services to CASTROL
- directly from individuals via CASTROL websites (including social media pages), service centres or call centres
- directly from individuals when they enter a trade promotion or competition
- from publically available sources
- from related companies
- from third parties, for example service providers who assist CASTROL to manage consumer relationships
- viasecurity video surveillance at CASTROL sites
Where reasonable and practical, CASTROL will collect Personal Information directly from the individual and inform the individual that this is being done. CASTROL does not generally require individuals to disclose “Sensitive Information”, for example information about an individual’s race, religion, sexual orientation or beliefs. If an individual discloses sensitive information to CASTROL for any reason, that individual consents to CASTROL collecting the information and using and disclosing it for the purpose for which it was disclosed and as permitted by the Privacy Act and other relevant laws.
UNSOLICITED PERSONAL INFORMATION
If CASTROL receives Personal Information where it has taken no steps to collect the information, then within a reasonable time it will decide whether it could, under the APPs, have solicited that Personal Information itself. If CASTROL determines that it would not, under the APPs, have been permitted to solicit the Personal Information, CASTROL will as soon as practical (where lawful and reasonable to do so) destroy or de-identify that unsolicited Personal Information. If CASTROL could, under the APPs, have solicited the Personal Information then CASTROL may use and disclose the Personal Information for the purpose for which it was disclosed and as permitted by the Privacy Act and other relevant laws.
USE AND DISCLOSURE OF PERSONAL INFORMATION
The purpose for which CASTROL uses and discloses Personal Information will depend on the circumstances in which it is collected. Generally, CASTROL may use or disclose Personal Information:
- for the purposes for which it was collected
- for a related secondary purpose, if the use or disclosure could be reasonably expected (e.g. disclosure to a delivery contractor for the purpose of delivering goods ordered from CASTROL)
- for other purposes to which an individual has consented
- as otherwise authorised or required by law
Specific purposes for which CASTROL may use or disclose Personal Information include the purposes of:
- supplying good or services to, or acquiring good or services from, an individual or organisation
- to improve CASTROL’s products and services
- contacting individuals for marketing purposes
- considering an individual for a position (e.g. as an employee or contractor) at CASTROL
- responding to an enquiry by an individual
- to administer a trade promotion or competition
- to maintain security over CASTROL premises and systems
CASTROL may disclose Personal Information locally and overseas to other parties including its related companies and to any agent, contractor or third party who provides administrative or other services to CASTROL or its related companies. CASTROL will, where commercially practical, require that any third party to whom Personal Information is disclosed will treat the Personal Information in a manner that is consistent with the APPs. CASTROL may disclose Personal Information to third parties, such as law enforcement agencies or government authorities, without authorisation in some circumstances, in accordance with the APPs. CASTROL will not sell Personal Information to a third party without the consent of the individuals to whom the Personal Information applies. CASTROL may sell de-identified, aggregated data to third parties that cannot be used to specifically identify an individual. Disclosure outside Australia In the ordinary course of business, CASTROL may disclose Personal Information to third parties for use in the following countries: New Zealand, United States, United Kingdom, Malaysia, the Philippines, India. Personal Information held by CASTROL may also be disclosed to companies in the global CASTROL group for specific purposes on particular occasions. Those companies may be in any of a large number of countries around the world.
CASTROL may send marketing communications in line with an individual’s previously expressed marketing preferences or as otherwise permitted under the Privacy Act and other relevant laws. Individuals who do not wish to receive such communications, can contact CASTROL at email@example.com to modify their preferences, or follow the opt-out instructions contained in each marketing communication.
SECURITY OF PERSONAL INFORMATION
HOW YOU CAN ACCESS AND SEEK CORRECTION OF YOUR PERSONAL INFORMATION WHICH CASTROL HOLDS
An individual may request access to, or correction of, their Personal Information held by CASTROL by sending a written request to the CASTROL Privacy Officer – see the “Contact CASTROL” section below. If an individual makes a written request for access to Personal Information held by CASTROL, CASTROL will respond to such request within 30 days and, where reasonable and practical, give access to the Personal Information in the manner requested by the individual. However, CASTROL may refuse a request for access to Personal Information where it is legally entitled to do so and, where reasonable, it will provide the reasons for this. CASTROL may require the person requesting access to provide suitable identification and, where permitted by law, may charge a fee for giving access to Personal Information in response to an individual’s request. The fee (if any) will be disclosed prior to providing the requested information and the costs being incurred. Any such fee will not be excessive and will relate to the reasonable costs incurred in responding to the request, not to making the request itself. CASTROL will take reasonable steps to ensure that the Personal Information it collects is accurate, up-to-date and complete. Correction of Personal Information may be requested by contacting the CASTROL Privacy Officer at the address set out in the “Contact CASTROL” section below. If CASTROL refuses to correct Personal Information in response to a request it will, where reasonable, provide a written notice setting out the reasons for refusal. In this situation an individual may request CASTROL to append a statement to their Personal Information that there is a dispute as to its accuracy.
COMPLAINING ABOUT A BREACH OF THE APPS
Please contact the CASTROL Privacy Officer in relation to privacy matters: Email: firstname.lastname@example.org Mail: BP Privacy Officer BP Australia Pty Ltd GPO Box 5222 Melbourne VIC 3000
In addition to the commitments set out in this privacy statement CASTROL has created a set of global data privacy rules which apply to the processing of all Personal Information by CASTROL. These privacy rules can be found at http://www.bp.com/content/dam/bp/pdf/BP_data_privacy_rules_public_document_16April_2010.pdf