Chawla Group Pty Ltd t/a Drill and Complete (D&C) and its Related Bodies Corporate (as defined in the Corporations Act (Cth) 2001) (D&C) manages individual privacy and the security of personal information in accordance with the Privacy Act 1988 (Cth) as amended (the Privacy Law).

1. Purpose of Privacy Statement

The purpose of the Privacy Statement is to provide:

• a framework that governs how D&C manages the collection, use, disclosure, protection and disposal of certain personal information to ensure D&C at all times complies with the Privacy Law; and
• information to persons from whom D&C may collect certain personal information, as well as the public in general, regarding the information collection and handling practices of D&C.

2. What is Personal Information and What Personal Information does D&C Collect?

Personal information is any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true or not and whether or not the information is recorded in a material form or not (Personal Information). Personal Information also includes Sensitive Information as defined in item 6 of this Privacy Statement below.

The type of Personal Information that D&C may collect is broad and will depend on the circumstances in question, but may include a person’s name, address, phone number, email address or other contact details, medical records, employment history, bank account details, photos, videos or details of membership to any association or organisation.

In relation to visitors to any D&C website, D&C may also collect certain electronic information as outlined in item 8 of this Privacy Statement below.

3. Collection and Holding of Personal Information

D&C only collects Personal Information that is reasonably necessary for it to perform its business functions and activities.  All Personal Information D&C collects is collected, used, disclosed and otherwise treated in accordance with the law, including but not limited to the Privacy Law.  Where possible, D&C collects Personal Information directly during the course of its relationship with individuals.  Where this is not possible, D&C may also collect Personal Information by other means, such as where such information is given to D&C by the relevant individual.

Generally and where practicable, the primary purpose of the collection will be made clear to an individual before or at the time of collecting the individual’s Personal Information.  A typical purpose for which D&C may collect Personal Information may include one or more of the following:

• assessment of a potential employee or contractor’s suitability for a particular role;
• sending information regarding an existing or potential employee or contractor to potential clients as part of a tender submission/bid;
• seeking client approval to engage an employee or contractor or on-board an individual to a particular project;
• monitoring, reviewing and assessing the performance of an employee or contractor of D&C;
• otherwise contacting an employee, contractor or client of D&C;
• ensuring the security and safety of all D&C personnel and property;
• responding to a complaint or conducting an investigation;
• statistical reasons, such as recording/monitoring demographics and complying with Australian participation obligations; and
• ensuring the prompt payment of D&C contractors and employees.

If you do not want D&C to use, collect, disclose or access your Personal Information, please notify D&C at the time it requests your Personal Information.

4. Use and Disclosure of Personal Information

Primarily, D&C will use, hold and disclose Personal Information in connection with the supply of its products, services or information or otherwise for a legitimate business purpose, to the extent permitted by law, and for a purpose for which it was collected.  D&C only uses and discloses Personal Information for a purpose other than its primary purpose, without the consent of the individual concerned, when disclosure is directly related to the primary purpose of collection.

As part of its primary purpose, D&C may be required to share Personal Information with other parties with which it conducts business, including but not limited to D&C’s existing or proposed:

• joint venture partners, affiliates and clients;
• service providers, such as recruitment agents, technology and security services;
• professional advisors including lawyers, auditors and accountants; and
• other contractors that assist D&C to provide its business.

D&C ensures that any disclosure is limited to what is necessary and allowed by the Privacy Law and/or any other law.

5. Related Body Corporate

D&C may disclose Personal Information to its Related Bodies Corporate.  In this scenario, the Related Body Corporate must use such Personal Information for the original primary purpose for which D&C collected the information, or a related purpose, to the extent permitted by the Privacy Law and/or any other law.

6. Sensitive Information

Sensitive Information includes information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, or health records.

D&C does not collect Sensitive Information without an individual’s consent, other than as permitted by the Privacy Law and/or any other law.

7. Anonymity and Pseudonymity

Wherever lawful and practicable, D&C respects the right of an individual to remain anonymous, or use a pseudonym, when dealing with D&C.

8. Website Privacy

(a)       Access to website

When accessing D&C’s website, D&C may record and log information for statistical and security purposes.  This information does not include any personally identifying information but may include a user’s server address and domain name, the operating system used, the date, time and duration of the visit, the pages accessed and the type of web browser used.  D&C uses this information to analyse its site’s usage and performance and to refine and develop our site.

(b)       Cookies

Cookies are small data files that are written to a computer’s hard drive when accessing a website.  D&C’s web server may send cookies to a user’s web browser in order to improve the functionality of D&C’s site.  D&C’s site uses cookies to support current activity on its website by providing a unique identifier in order to allow its web server to distinguish the web browsers accessing our site.

D&C only uses cookies to track the use of its website so that it can understand how users access the website.  D&C’s site does not store any personally identifying information in cookies.  The cookies sent by D&C’s site expire when a session ends, and are not stored permanently on computer hard drives.  Any information D&C collects regarding user traffic patterns on its website is used on an anonymous basis.

It is possible for a user to adjust their browser settings to allow the user a choice whether to accept or refuse cookies.  However, if the user chooses to disable the receipt of cookies from D&C’s website, some aspects of the website may not be accessible.

(c)       Hyperlinks

D&C does not warrant or make any representations with respect to the privacy policies or practices of operators of other websites where D&C provides a hyperlink to that website on D&C’s website.

9. Security of Personal Information

The security of Personal Information is of utmost importance to D&C.  D&C takes all appropriate action and reasonable precautions to safeguard and protect Personal Information that its collects from loss, interference, misuse, unauthorised access, modification or disclosure.

D&C utilises a number of means to protect Personal Information including:

• external and internal premises security;
• maintaining and reviewing technology; and
• internal policies with respect to computer usage.

10. International/ Cross-Border Disclosure of Personal Information

D&C (including its joint venture partners, affiliates and clients) operates and conducts business in various international locations.  An overview of D&C’s global operations and the countries in which it operates can be viewed at drillandcomplete.com.au

D&C may be required to disclose Personal Information to parties who are not located in Australia or an external Territory (including but not limited to overseas clients, joint venture partners, affiliates) (Overseas Recipient) as part of D&C’s primary functions and activities, locations of which may include but are not limited to Papua New Guinea, United Kingdom, United States of America, the People’s Republic of China, Thailand, Vietnam, Indonesia, India, Malaysia and Singapore.

Examples of the type of Personal Information that may be disclosed by D&C to Overseas Recipient’s, and the purposes for which D&C may use and disclose such Personal Information, may be found in Section 3 and Section 4 of this Privacy Statement above.

D&C will take such steps as are reasonable in the circumstances to ensure that an Overseas Recipient does not breach the Australian Privacy Principles in relation to the information.

11. Identifiers

D&C does not adopt, use or disclose any Commonwealth identifier as a means of identifying the Personal Information that we may have collected about an individual. A Commonwealth identifier is a Commonwealth Government or Commonwealth Government agency designated identification number such as Tax File Numbers or Medicare numbers.

12. Access and correction to personal information

Generally, D&C endeavours to comply with any reasonable request to detail our information handling practices.  Sufficient steps are taken, in a general way, to outline the type of Personal Information D&C holds, for what purposes and how such information is collected, used and disclosed.

An individual may request access to any of the Personal Information that D&C holds about them.  D&C will provide an individual with access to Personal Information pertaining to them following a reasonable request and upon the verification by D&C, to its reasonable satisfaction, of the identity of that individual.  D&C will endeavour to handle all requests for access to Personal Information as quickly as possible. An individual may request access to, or seek the variation or amendment of, Personal Information on that individual that is held by D&C by contacting us at legal@drillandcomplete.com.au .

In some circumstances, D&C may refuse access to Personal Information where D&C is required or authorised to do so by law, including where the request for access may be regarded as frivolous or vexatious.  If a request for access to Personal Information is denied, D&C will explain the reason for the denial.

D&C will also take appropriate action to correct any Personal Information which is deemed to be in accurate, incomplete or not up to date.

13. Copies of Privacy Statement

A copy of this Privacy Statement will be made available at all times on the D&C website at www.drillandcomplete.com.au

14. Variations to this Privacy Statement

This Privacy Statement will be reviewed at least every three years or otherwise in accordance with the Privacy Laws.

16. Responsibilities within D&C

The Human Resources Manager of D&C is accountable to the D&C management for ensuring that this Privacy Statement is implemented throughout D&C’s operations.

D&C’s Legal Department is responsible for the management and implementation of this Privacy Statement.