Privacy

This Privacy Statement explains how Santos Limited ABN 80 007 550 923 and its related entities (collectively “Santos”, “we”, “us” or “our”) collect, use, disclose and store personal information.

Santos recognises the importance of your personal privacy and is committed to protecting your personal information.  Santos is bound by and required to protect personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”), including the Australian Privacy Principles (“APPs”).

This Privacy Statement describes generally the kinds of personal information that Santos collects and holds, how Santos collects, uses, holds and discloses that personal information, and its purposes for doing so.

Santos websites may contain links to other (third party) websites. This Privacy Statement will not apply to, and Santos is not responsible for, the content or the privacy practices of such third party websites. Please read the privacy policy or privacy statement of any such third party website before you visit or use it or provide the third party with your personal information.

For information about how Santos, including Santos NA Barossa Pty Ltd ABN 44 109 974 932, handles personal information collected in connection with Barossa Gas Project consultation, please read our Barossa Gas Project Consultation Privacy Policy, which is available at santos.com/barossa, along with further information on the Project.

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 which includes information or an opinion about 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.

Santos will 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 required or permitted to collect that information without your consent.

What kinds of personal information do we collect?

• Depending on how and why you interact with us, we may collect the following personal information about you:
• Contact and identity details – if we are in contact with each other (including if you apply to work with us, if you submit an enquiry via one of our websites, if you are the contact person for one of our contractors, suppliers or service providers or if you are a current or potential investor), we may collect details from you such as your full name, street address, postal address, email address and telephone number.
• Recruitment and employment-related details – if you are a job applicant, a current or former employee of, or individual contractor to, Santos, in addition to your contact and identity details, we may also collect your date of birth, your gender, copies of or information from identity information such as your drivers’ licence, passport and right to work in Australia documentation, your nationality and citizenship, details of your membership of a trade association or union, information required in relation to the payment of your wages (including your bank account details, tax file number and superannuation details) and other information related to your employment (such as your image, details for your emergency contact(s), medical records, performance and training information, employment history, licences and qualifications and criminal history checks).
• Website interactions – if you visit one of our websites, we will collect your Internet Protocol (IP) address or Unique Device Identifier, as well as other details about your browsing experience on the website (also see “Cookies” below).
• Community, clan group or organisation details – if you are part of a community, clan group or organisation with whom we are consulting on a particular project, in addition to your contact and identity details, we may also 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).
• Landholder or titleholder details – if you are a landholder or titleholder with whom we are dealing in relation to a particular project, in addition to your contact and identity details, we may also collect your bank details.
• Other information or opinions which identify you, or from which you are reasonably identifiable –we may collect your information, feedback or opinions (including if you are part of a community, clan group or organisation with whom we are consulting for any purpose) in relation to Santos’ activities and operations.  Depending upon the information, feedback or opinions that you provide, you could be identified.
• Visitors and attendee images and videos – if you visit our premises, we may collect information about your access and attendance at Santos premises including security records about the time(s) or entry and exit, and your image through CCTV (if you are reasonably identifiable from the image captured by CCTV), or if you attend our consultation sessions we may collect photographs and video footage of you (and other) attendees.
• In certain circumstances, you may choose to deal with us anonymously or by using a pseudonym.  However, if you do so, we may be unable to (for example) identify you as the individual who provided particular feedback to us as part of a consultation process, 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 about our projects or business.

How do we collect your personal information?

We may collect your personal information:

• directly from you (for example, when you complete and submit any form, survey or application to us, attend our premises and complete visitor sign-in logs or through CCTV we operate at our premises, 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, or 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 permitted to collect it under the Privacy Act and the APPs.  If we would not have been permitted to collect it, we will destroy or de-identify it as soon as practicable (if it is lawful and reasonable to do so).

Do we disclose your personal information to anyone outside of Santos?

We may share your personal information with the entities forming part of the Santos Group, where those entities require the information for the purposes described in this Privacy Statement.  From time to time, we may also disclose your personal information to:

• our third party service providers, including providers of mail house, archival, auditing, professional advice, marketing, recruitment, data processing, security services, technology and consultation services;
• our joint venture partners for particular projects;
• government authorities or other statutory 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;
• our professional advisers, including those that provide us with legal, taxation and audit services, where those advisers are bound by obligations of confidentiality;
• where you have applied to work with us, your nominated referees for the purpose of receiving a reference; and
• any other parties to whom you have authorised us to disclose your personal information.

We won’t disclose your personal information to other third parties unless you consent, or unless we are permitted to do so by law.

Do we disclose your personal information to anyone located overseas?

Some of the Santos group entities and third parties we have referred to above may be located outside of Australia.

The overseas locations to which your personal information may be disclosed, transmitted, stored or accessed from include but are not limited to, Papua New Guinea, the United States, Indonesia, Vietnam, Bangladesh, India, Timor-Leste and Singapore.

If we disclose personal information to a recipient located overseas, we will take steps to ensure that the overseas disclosure complies with the Privacy Act and the APPs. This may include entering into a legally binding contract with the recipient which requires them to protect and handle personal information in accordance with applicable privacy laws.

Why do we collect, use and disclose your personal information? 

We may collect, use and disclose your personal information for a number of purposes connected with our business operations, including:

• to respond to your enquiries and provide you with the information and/or services you have requested;
• to comply with our legal and regulatory obligations, including preparing reports, liaising with law enforcement agencies and regulators;
• to conduct our social responsibility activities;
• to record your attendance at our consultation sessions;
• to receive, record and respond to any feedback that you provide to us;
• to process and respond to your employment application and other recruitment-related purposes, including conducting reference checks, considering you for career opportunities with Santos;
• to update and develop our environment plans, including engaging in consultation with you in connection with our current or proposed activities under relevant environmental plans;
• to understand your preferences in relation to your preferred manner or methods of consultation and information topics and format;
• to manage safety and security risks, including monitoring and managing access to and use of Santos premises and sites, for safety and security at Santos premises and sites (including through CCTV use), and managing and securing our IT environment and assets (including monitoring email and other electronic communications) and the health and safety of persons on Santos premises and sites;
• for public relations and marketing purposes, including to personalise your experience on Santos websites, to analyse the characteristics of visitors to Santos websites, to undertake data analytics and profiling for business research and development purposes, to engage with our communities and stakeholders and promote our projects, business and operations, to send invitations to stakeholder events and community receptions, and to manage and our newsletters and other communications; and
• other business-related purposes including negotiating and managing contracts with our customers and suppliers and other third parties, managing our business relationships, managing our finances, accounts and records, conducting resource planning and workforce management, conducting internal investigations, and to administer lease, licence and clearance procedures.

We may also use your personal information for purposes related to those we’ve described above which would reasonably be expected by you, where we have your consent, in order to prevent injury or death, or as permitted by law (including for law enforcement or public health and safety reasons).

How do we store and secure your personal information?

We take reasonable steps to protect your personal information from loss or misuse, and from unauthorised access, modification or disclosure.

We implement a range of physical and electronic security measures to protect the personal information that we hold, including:

• usernames, passwords and access restrictions to protect personal information that we store electronically; and
• securing hard copy personal information within buildings or other storage facilities via restricted access to those buildings or facilities.

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.

If any unauthorised access or disclosure of your personal information occurs, we will 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.

Please let us know immediately if you become aware of any breach of security affecting your personal information that Santos holds.

Cookies

Cookies are small data files that a website is able to place on a user’s hard drive to record aspects of that user’s experience of the website.  Like many sites, the Santos’ websites may use cookies from time to time.  For example, we may use cookies to record that a user visited a particular section of a website, that their browsing software was a particular version or that they chose not to be on a mailing list.  In this way, cookies can improve the operation of the website, and make the experience more efficient, enjoyable and personalised.

Cookies do not need to identify the user or record any personal information.  Santos will generally not make any attempt to identify you or your browsing activities except in very limited circumstances, for example, where a law enforcement agency may exercise a warrant to inspect the service provider’s logs, or where your usage is causing technical issues for our site that may need to be resolved and we need to contact you.

Direct marketing communications

If you are a local stakeholder for a particular project, a potential or actual investor or a business contact of Santos and you register your name, email or other contact details with us, we may send you communications from time to time about receptions or events, or our projects and business, that we think will be of interest to you. You can opt-out of receiving these communications from us at any time, by using the opt-out facility provided in each communication or by contacting us using the details provided below.

How can you access or correct your personal information?

You may request access to your personal information by contacting us using the details provided below).  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 confirm that any 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.

How can you contact us regarding privacy matters, including to make a complaint?

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
Street address:  60 Flinders Street, Adelaide SA 5000
Phone:  +61 8 8116 5000
E-mail:  compliance@santos.com

We take all complaints seriously and will respond to your complaint within a reasonable period of time.

If a privacy concern or complaint is not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner (“OAIC”).

Will our Privacy Statement change?

We may amend this Privacy Statement from time to time, including to reflect any alterations to our information handling practices or business circumstances.  Any updated Privacy Statement will be published on our website.  Please make sure you review this Privacy Statement 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 Statement was last updated.

Last updated: 19 December 2024