Overview

Pacific National is committed to the protection of your Personal Information when you are working with or doing business with us.

The purpose of this policy is to outline Pacific National’s approach to implementing and embedding a consistent way to collect and manage Personal Information and comply with the Australian Privacy Principles (APPs) as set out in the Privacy Act.

This policy applies to all companies within the Pacific National Group, and to all Personal Information collected during business interactions conducted by Pacific National.

We require all directors, employees, and contractors of Pacific National to comply with this policy.

We expect suppliers to comply with this policy or implement consistent standards with respect to the handling of any Personal Information.

Certain exemptions apply under the Privacy Act in relation to employee records and we may rely on those exemptions despite this policy.

Our Commitment

Pacific National is committed to the lawful and correct handling of Personal Information.

This Privacy Policy establishes the minimum requirements for collecting, holding, using and disclosing Personal Information across Pacific National’s operations. Individuals are also entitled to access their own information and to correct that information when required.

Our Approach

At Pacific National, people need to be able to trust us to respect their privacy and how we handle their Personal Information when working with or doing business with us.

This Privacy Policy helps us to do this. Failure to comply with privacy and data protection laws, and the principles set out in this policy, could lead to financial and reputation damage to Pacific National, as well as result in a loss of trust from the individuals we work with.

That is why protecting Personal Information is important for our business and the way in which we deliver what matters – to our people, customers, and shareholders.

1. Handling of personal information

1.1 Personal Information we collect

Personal Information is information that identifies you as an individual or from which your identity can be established.

For example, the types of personal information Pacific National collects includes your contact details, photographs, identification information and information about an individual’s activities and characteristics.

Pacific National collects Personal Information depending on the type of dealings you have with us. We collect information for a range of business purposes including:

Managing people data: Personal Information about employees, prospective employees and contractors is collected for people management purposes. This includes identity and contact information, data about employment history, training and qualifications, experience, character and screening checks (including eligibility to work and criminal record checks), performance information and information needed to pay salaries and other benefits. This may also include sensitive information, such as health and medical information and drug and alcohol testing results for the purpose of monitoring compliance with our policies and standards.
Managing business relationship with customers, suppliers, and other external parties: Personal Information about individuals within external organisations is collected for business purposes such as supplying goods and acquiring services, entering contracts, and for communication. This includes information you provide, or was provided on your behalf, as part of our induction and compliance processes.
Managing community relationships: Personal Information is collected from members of communities where Pacific National conducts operations for the purposes of engaging and interacting with those communities.
Managing shareholder relationships: personal information from shareholders including directors appointed by them, is collected for the purposes of regulatory reporting and external communications, benchmarking and reporting. From time to time this information may be provided to regulatory bodies.
Managing safety, security, and legal obligations: Personal Information is collected from visitors to our sites for safety and security purposes. This can include collection of images by closed circuit television (CCTV) where permitted by law. Pacific National also collects Personal Information in compliance with its legal obligations, such as to meet obligations under anti-money laundering legislation and whistleblowing legislation.

Where it is lawful and practicable for Pacific National to allow it, you have the right to not identify yourself when dealing with us. However, not providing us with your Personal Information may impact on our ability to provide you with certain services.

1.2 Sensitive Personal Information

Under the Privacy Act, certain categories of Personal Information are considered particularly sensitive and need additional protection. This includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, trade-union membership, health, genetic or biometric information, sexual orientation, or criminal convictions.

Pacific National will only collect, hold, and use your sensitive Personal Information where we have obtained your express consent or where we have other lawful grounds to do so under applicable laws.

1.3 How we collect and maintain information

Pacific National only collects Personal Information necessary for our business purposes or to communicate with you.

Personal Information may be collected verbally, in writing, by telephone, electronically, including by email and through Pacific National’s website, and by monitoring and recording your communications and interactions with Pacific National.

For purposes including people management, safety, security, and training, Pacific National may operate video and audio surveillance devices in our premises, assets and on our systems.

Pacific National endeavours to collect Personal Information directly from an individual, except where it is not reasonably practical to do so. Where you provide us with Personal Information about someone else, you must have their consent to provide their information to us.

We take reasonable steps to ensure that Personal Information is accurate and kept up to date. Where Personal Information is inaccurate, we take reasonable steps to erase, rectify or supplement that information before using it.

1.4 How we use Personal Information

Pacific National understands how important it is to safeguard your Personal Information. We use and disclose personal information that we hold about you:

for the purposes we collected it; or
when you agree to the use or disclosure; or
when use or disclosure is required or authorised by law.

We may use and disclose Personal Information:

in connection with our business such as providing or improving our products and services, to protect our legal interests, or in connection with the sale of Pacific National’s business;
to verify your details and manage our relationship with you, including if you send an email message to Pacific National, to respond to your email;
where there is suspected fraud, misconduct, and other unlawful activity under laws in Australia including the Rail Safety National Law;
if you apply for a job with Pacific National, to assess your application, and consider you for suitable roles;
if you are employed by Pacific National, for purposes relating to managing your employment or engagement with Pacific National including training, performance, payroll and superannuation, health and safety, insurance (including WorkCover) and claims management; and
to gather information about Pacific National’s website visitors and to improve that website, including using cookies.

1.5 How we protect Personal Information

All Personal Information collected by Pacific National is held securely. Personal Information may be stored in physical files, in Pacific National’s systems or in databases, or on infrastructure owned and operated by external service providers for Pacific National. Where external service providers are engaged to assist Pacific National to process Personal Information, Pacific National requires those service providers to comply with contractual privacy and data protection obligations, and all applicable privacy and data protection laws.

A range of measures are undertaken by Pacific National to protect the security of data from accidental, unauthorised or unlawful access, modification, or disclosure. These measures apply whether the Personal Information is stored in hard copy form (such as paper) or in electronic form (such as in databases).

Personal Information is only made available to Pacific National employees on a ‘need to know’ basis and for the purposes outlined in this Policy. Pacific National has policies and procedures in place to ensure that appropriate physical, technical, and organisational security measures are in place, including in relation to acceptable use and cyber security.

1.6 Sharing information with others

Pacific National may need to disclose Personal Information about you to:

companies within the Pacific National Group, in which case the disclosure is protected as set out in the Policy;
third parties who provide services to Pacific National or to government regulators and agencies, as part of our statutory obligations. If we need to disclose Personal Information outside the Pacific National Group, we will ensure that the disclosure is protected by contractual data privacy clauses or the disclosure is authorised by law. This includes an assessment of whether any transfers across national borders comply with relevant laws.

Pacific National may disclose your Personal Information to external providers in the following countries: Australia, Singapore, the USA and Philippines as part of our ordinary business practices for the storage of data.

2. Your rights

We acknowledge that individuals to whom Personal Information relates have rights, including the right to:

seek access to Personal Information that Pacific National holds about them;
seek correction of inaccurate, incomplete, or out of date Personal Information;
seek erasure of their Personal Information;
be provided with details about how their Personal Information is handled;
complain about the handling of their Personal Information; or
withdraw previously given consent regarding Pacific National’s handling of their Personal Information.

If there are legal exceptions to the exercise of these rights, Pacific National will review each request on a case-by-case basis, by reference to relevant laws.

2.1 Exercising your rights

We take all reasonable steps to ensure that Personal Information is up to date, accurate and complete. You have rights to access, update and correct your Personal Information.

When you contact us and request access, we will verify your identity and may ask you further questions so that we can respond to your request as quickly as possible.

If you wish to access, update, or correct your personal information held by us, please contact our Privacy Officer.

Pacific National will aim to respond within a reasonable period after the request is made or when the information is received to process your request.

2.2 Complaints and questions

If you have any questions or wish to make a complaint about the handling of your Personal Information, you can do so by contacting our Privacy Officer.

Our Privacy Officer is responsible for investigating and responding to complaints unless the complaint is about the Privacy Officer’s handling of Personal Information. In these circumstances, another person will be appointed to investigate and respond to your complaint.

If you are not satisfied with how your complaint has been addressed by Pacific National, you can make a complaint to the Office of the Australian Information Commissioner (OAIC).

3. Compliance and review

This Policy will be reviewed and revised from time to time to take account of new laws and changes to Pacific National’s operations and practices. We will notify you of changes by publishing the latest policy from time to time at www.pacificnational.com.au/privacy-policy.

Pacific National expects its people, customers, suppliers, and other stakeholders to report any actual or suspected breaches of this Policy to the Privacy Officer or a senior manager at Pacific National. The Privacy Officer will investigate reported breaches, and report to the board of directors of Pacific National as required.

3.1 Contact details

If you require further information on privacy matters or this Policy, please contact our Privacy Officer on the following details:

The Privacy Officer – Pacific National

Level 1, 2-4 Blue Street

North Sydney NSW 2060

Email: PNLegal@pacificnational.com.au

Privacy policy