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.
Where reasonable and practical, CASTROL will collect Personal Information directly from the individual and inform the individual that this is being done.
Where you have subscribed to receive our newsletter(s), we are able to ensure you receive further relative and informative communications by following your interactions with that communication, such as whether you receive, open or click on a link within an email communication. We offer you an ability to unsubscribe in all our further communications.
CASTROL does not generally require individuals to disclose “Sensitive Information”, which includes health information about individuals and information about an individual’s race, religion, sexual orientation or beliefs. In some limited circumstances, CASTROL may ask for your consent to collect sensitive information about you, such as if CASTROL requests that you agree to a background check or national police history check in connection with applying for employment at CASTROL.
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 and, if applicable, subsequently administering and managing CASTROL’s engagement or employment of that individual (including in relation to training, performance management and disciplinary action if required)
· for individuals that are an employee or contractor of any of CASTROL distributors, suppliers or customers, to transact with you, your employer or the party that is engaging you as a contractor and to manage our relationship with you, your employer or the party that is engaging you as a contractor
· responding to an enquiry or complaint 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. This may include disclosing your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on CASTROL. In the event that CASTROL (or one of its businesses) is subject to a takeover, divestment or acquisition, CASTROL may disclose your Personal Information to the new owner of the business.
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.
Other specific collections, uses and disclosures
Where CASTROL holds personal information about you that it has collected from different sources, CASTROL may combine this personal information into a single record. CASTROL may also combine or share any information that we collect from you with information collected by any of our related bodies corporate (whether within Australia or overseas), including companies that are part of the BP group of companies.
CASTROL may then use and disclose this combined set of information to:
· assess and determine your likely preferences and needs and to develop other insights about you;
· tailor or personalise our products and services for you; and
· deliver communications and information and provide you with offers that CASTROL thinks are relevant and may be of interest to you.
We may disclose this information to our service providers so that they can conduct customer and data analytics on our behalf.
If you (or your business, if you are a director of a company or a partner in a partnership, as applicable) has a business account with us, CASTROL may also collect additional personal information about you for the purpose of operating and administering this business relationship. This may include additional identifying details (including your date of birth, current and past residential addresses and drivers’ licence number) and other bank account details necessary to set up a direct debit arrangement. CASTROL may use and disclose this personal information to:
· provide its products and services to you (or your company or other business, as applicable); and
· obtain payment for the products and services that CASTROL has provided to you.
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, the United States, the United Kingdom, Malaysia, the Philippines and India.
Personal Information held by CASTROL may also be disclosed to companies in the CASTROL group for specific purposes on particular occasions and to other companies that are part of the BP group of companies. 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 such as the Spam Act 2003 (Cth). These marketing communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. Individuals who do not wish to receive such communications, can contact CASTROL at firstname.lastname@example.org to modify their preferences, or follow the opt-out instructions contained in each marketing communication.
As the internet is not always a secure environment, CASTROL cannot provide any assurance regarding the security of transmission of information you communicate to us online. CASTROL also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you send or transmit to CASTROL online is transmitted at your own risk.
However, once CASTROL has received your Personal Information, CASTROL will take appropriate security measures to prevent unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss of personal information once it is under CASTROL’s control.
CASTROL uses, accesses and stores “cookies” and similar technology on its websites and in other technology applications. These cookies include “first party” cookies created by or on behalf of CASTROL, as well as “third party” cookies that are created by other websites and third parties, including advertisers. The use of such technologies is an industry standard, and helps CASTROL monitor the effectiveness of its advertising and how visitors use its websites/applications. CASTROL uses such technologies to generate statistics, measure activity, improve the usefulness of its websites/applications and enhance the user experience.
When CASTROL websites are accessed, CASTROL may deliver customised information, including ads, to individuals based on the data stored in a cookie. Third party vendors may serve CASTROL ads on Internet sites based on a user’s prior visits to CASTROL websites and other Internet activity. CASTROL may also use analytics data supplied by third party vendors to inform and optimise its ad campaigns.
SECURITY OF PERSONAL INFORMATION
Individuals should notify CASTROL immediately if they become aware of any breach of security.
Where Personal Information is no longer needed for any purpose for which CASTROL is authorised to use it and there is no legal requirement for CASTROL to keep it, CASTROL will take reasonable steps to destroy or de-identify 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 CASTROL using the contact details provided in 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. For example, we may need to refuse access if granting access would interfere with the privacy of others.
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. CASTROL is committed to ensuring that your Personal Information is kept accurate and up to date. However, CASTROL can only make changes to your Personal Information if you notify us of any inaccuracies or changes, or if CASTROL otherwise becomes aware that Your Personal Information is no longer accurate. While CASTROL takes reasonable steps to ensure the Personal Information that it uses or discloses is accurate, up-to-date, complete and relevant, it is also your responsibility to let us know if there are inaccuracies in or changes to your Personal Information.
Correction of Personal Information may be requested by contacting CASTROL using the contact details provided 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 and what mechanisms are available for you to complain about CASTROL’s refusal to correct your Personal Information. 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
Enquiries, requests for access, requests for corrections and complaints in relation to CASTROL’s privacy practices must be sent to the BP group Privacy Officer using the following contact details:
Mail: BP Privacy Officer
BP Australia Pty Ltd
GPO Box 5222
Melbourne VIC 3001
Telephone: 1300 130 027
GLOBAL DATA PRIVACY RULES