Santos Limited, Santos NA Barossa Pty Ltd and their related bodies corporate (collectively Santos, we, us, or our) are committed to managing personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act).
This document is referred to as our Privacy Policy and sets out how we manage your personal information in connection with consultation in respect of proposed activities under Environment Plans for the Barossa Gas Project and should be read in conjunction with any privacy notice that we have provided to you in connection with consultation for the Barossa Gas Project.
In this Privacy Policy, you refers to any individual about whom we collect personal information, and the Barossa Gas Project refers to a Santos-operated offshore gas and condensate project that proposes to provide a new source of gas to the existing Santos-operated Darwin liquified natural gas (DLNG) facility in the Northern Territory.
Except where expressly stated otherwise, this Privacy Policy does not apply to any third parties referred to in this Privacy Policy. We encourage you to obtain a copy of those parties’ privacy policies, to ensure that you are comfortable with how they handle your personal information.
WHAT IS PERSONAL INFORMATION?
Personal information is information or an opinion about you, or information from which you could reasonably be identified.
Sensitive information is a sub-set of personal information and refers to your racial or ethnic origin; political opinions; religious beliefs or affiliations; philosophical beliefs; political, professional, trade association or trade union memberships; sexual orientation or practices; criminal records or your health, genetic or biometric information and templates. We do not collect your sensitive information, unless you have provided your consent and the information is reasonably necessary for our functions or activities, or we are legally allowed to collect that information without your consent.
COLLECTION OF PERSONAL INFORMATION
What kinds of personal information do we collect about you?
Depending on how you interact with us, we may collect personal information which includes, but is not limited to:
- Contact and identity details – if we are in contact with each other, we may collect details such as your full name, street address, postal address, email address and telephone number.
- Community, clan group or organisation details – if you are part of a community, clan group or organisation with whom we are consulting, we may collect details of the community, clan group or organisation that you represent, your First Nations heritage and other information that you choose to provide (including your preferred manner of consultation).
- Philosophical, religious or spiritual beliefs – we may collect details about your philosophical, religious or spiritual beliefs (including cultural or spiritual connections) when you respond to our requests for consultation and feedback, including in connection with our current or proposed activities.
- Other information or opinions which identify you, or from which you are reasonably identifiable – we may collect your information, feedback or opinions including as to functions, interests or activities which may be affected by, or other relevant interests in, the Barossa Gas Project. Depending upon the information, feedback or opinions that you provide, you could be identified.
- Website interactions – if you communicate with us via our website, and/or register to nominate as a ‘relevant person’, we may collect your contact details and other information you choose to provide.
- Attendee images and videos – if you attend our consultation sessions, from time-to-time we may collect photographs and video footage of attendees.
How do we collect your personal information?
We may collect your personal information:
- directly from you (for example, when you complete a ‘relevant person nomination form’, access our portal at santos.com/barossa/, attend our consultation sessions, when we are in contact with each other or when you visit our website);
- from publicly available sources and databases (for example, if it is unreasonable or impractical for us to collect the personal information directly from you, because we have provided you with a fair opportunity to supply personal information which we reasonably require for our activities, but you have only partially provided it, or not provided it at all);
- through statutory, regulatory and other governmental processes; and
- from third parties who you have authorised to provide us with your personal information.
If we receive unsolicited personal information about you, we will assess whether we would have been entitled to collect it. If we would not have been entitled to collect it, we will destroy or de-identify it as soon as practicable (if it is lawful and reasonable to do so).
USE OF PERSONAL INFORMATION
How do we use your personal information?
We may use your personal information:
- to update and develop our environment plans;
- to prepare reports in connection with our legal obligations;
- to record your attendance at our consultation sessions;
- to receive, record and respond to any feedback that you provide to us;
- to consult with you in connection with our current or proposed activities under relevant Environment Plans;
- to understand your preferences and behaviours, including but not limited as to preferred manner or methods of consultation and information topics and format;
- to conduct our corporate social responsibility activities;
- to comply with our legal obligations, including but not limited to any obligations under the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (Cth) and Offshore Petroleum and Greenhouse Gas Storage Regulations 2009 (Cth); and
- to administer lease, licence and clearance procedures.
DISCLOSURE OF PERSONAL INFORMATION
Your personal information may be disclosed to:
- our third party service providers, including providers of mail house, professional advice, security services, technology and consultation services;
- related entities within our corporate group, including but not limited to Santos Offshore Pty Ltd;
- our joint venture parties in connection with the Barossa Gas Project;
government authorities or other statutory bodies, including the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) and other authorities or bodies, where we are required to do so by law, or it is expressly permitted under the Privacy Act. For example, where you have provided your - consent or we are legally required to do so, such as under a court order or warrant;
- any other parties to whom you have authorised us to disclose your personal information.
Do we disclose your personal information overseas?
Due to the global nature of our operations and business, your personal information may be disclosed to personnel situated outside of Santos. We may use overseas parties to collect, transfer, store and handle your personal information.
Some of the offshore jurisdictions to which your personal information may be accessed, disclosed transmitted or stored include but are not limited to, Papua New Guinea and United States.
If you submit your personal information to us, you are consenting to the transmission, disclosure, storage and access of your personal information by third parties in overseas jurisdictions. Australian Privacy Principle 8 which ordinarily obliges Santos to take reasonable steps to ensure that overseas recipients of your information do not breach the Australian Privacy Principles (except Principle 1) will not apply. If any overseas recipients handle your personal information in a manner which is inconsistent, or does not comply, with the Australian Privacy Principles:
- to the maximum extent permitted by law, Santos will not be accountable under the Privacy Act for any resulting loss or damage that you may suffer;
- to the maximum extent permitted by law, you will not be able to seek redress against Santos under the Privacy Act 1988 (Cth);
- the overseas recipient may not be subject to any privacy obligations at all, or to any principles similar to the Australian Privacy Principles;
- you may not be able to seek redress against the overseas recipient in their jurisdiction; and
- the overseas recipient may be subject to foreign laws which compel their disclosure of your personal information to other parties, such as overseas government authorities.
STORAGE AND SECURITY OF PERSONAL INFORMATION
How do we store and secure your personal information?
We take reasonable steps to protect your personal information from loss, misuse, unauthorised access, modification or disclosure.
For example, we have in place usernames, passwords and access restrictions to protect personal information that we store electronically. However, there are inherent risks with the transmission of data, including personal information, over the internet. Whilst reasonable security measures are in place for the protection of your personal information, please be aware that no guarantee can be made that your personal information is completely secure.
We also secure hard copy personal information within buildings or other storage facilities, by restricting access to those buildings or facilities.
If any unauthorised access or disclosure of your personal information occurs, we comply with our obligations under the Privacy Act in dealing with that unauthorised access or disclosure, including any obligations in respect of eligible data breaches under the Privacy Act.
ACCESS TO, AND CORRECTION OF, PERSONAL INFORMATION
How can you access and correct your personal information?
You may request access to your personal information by telephoning us or sending a written request to our street address or email address (the details appear below, under the MISCELLANEOUS ISSUES section). Upon receiving an access request, we may seek further details from you in order to verify your identity. We reserve the right to refuse access to personal information if we cannot verify your identity to our reasonable satisfaction. Access will generally be provided in an appropriate format within a reasonable period of time. We may charge a fee for providing access if it requires a significant amount of time to locate your personal information or to collate or present it in an appropriate format. This fee will be explained to you before it has been incurred.
In limited circumstances, and where it is permitted under the Privacy Act, we may refuse to provide access to your personal information.
We will take reasonable steps to seek to confirm that personal information we collect and use is accurate, up-to-date and complete. Where personal information is out-of-date or incorrect, please let us know by contacting us and we will correct it.
MISCELLANEOUS ISSUES
Can you deal with us anonymously or use a pseudonym?
You can choose to deal with us anonymously or by using a pseudonym. However, we may be unable to identify you as the individual who provided particular feedback (including in any report related to the Barossa Gas Project), or it may render us unable to discuss your feedback with you or respond.
It may also prevent us from providing you with accurate or useful information.
Will our Privacy Policy change?
We may amend this Privacy Policy from time to time, including to reflect any alterations to our information handling practices or business circumstances. Any updated Privacy Policy will be published on our website. Changes come into effect from the time when they are brought to your attention, or when you next logon to our website, whichever is earlier. Please make sure you review this Privacy Policy each time you visit our website, or interact with us, in order to keep up to date with any changes. Our website will display the date that this Privacy Policy was last updated.
How can you contact us regarding privacy matters?
If you have any concerns or complaints regarding how we handle personal information, please contact us. Correspondence should be addressed to the Compliance Team at:
Santos Limited and Santos NA Barossa Pty Ltd
Street address: 60 Flinders Street, Adelaide SA 5000
Phone: +61 8 8116 5000
E-mail: offshore.consultation@santos.com and compliance@santos.com
We take all complaints seriously and will respond to you within a reasonable period of time, unless we consider your complaint to be frivolous or vexatious.
If a privacy concern or complaint is not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner.
Last updated: – 24 March 2023