RES AUSTRALIA – PRIVACY POLICY

This is the privacy policy for RES Australia Pty Ltd (ABN 55 106 637 754) and its wholly owned subsidiaries.

This privacy policy sets out how we collect, use, process, disclose and manage your personal information and the measures and processes we have put in place to ensure its adequate protection.  It describes what kinds of personal information we collect, how that information is held, the purposes for which it is collected and held, how you may access and correct that information, and how you may complain about any breach of the Australian Privacy Principles in relation to personal information held by us.

Terminology

In this policy:

• RES Australia, we, us and our means RES Australia Pty Ltd (ABN 55 106 637 754) and each of its wholly owned subsidiaries;
• the expressions you and your refer to each and every individual whose personal information we may handle from time to time;
• website means our global Group website res-group.com together with any other website we establish for any renewable energy project under development or management by us from time to time;
• personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not, and (b) whether the information or opinion is recorded in a material form or not. This can include names, addresses, email addresses and phone numbers;
• sensitive information includes information or opinions about such things as a person’s racial or ethnic origin, political opinions, membership of a political organisation, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information; and
• the meaning of general words is not limited by specific examples introduced by “including”, “such as” or similar expressions.

Our commitment to privacy

We are committed to protecting the privacy of your personal information.  We work to ensure that we comply with the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles under the Privacy Act, and any other applicable privacy laws.

COLLECTING PERSONAL INFORMATION

How we collect personal information

At all times we try to collect only the personal information directly from you we reasonably need for the particular function or activity we are carrying out.  This can include when you visit our website, contact us, raise a query or complaint with us, sign up to one of our mailing lists, apply for a job with us (as further described below), contract with us or otherwise interact with us and when we provide services to, or otherwise work with, you.

We may also collect your personal information (including, where required, sensitive information) that we reasonably need from third parties, from sources that include government agencies and other public bodies, regulators, commercial counterparties, community groups or individuals, and third party service providers (including recruitment or information agencies), and from publicly available records when handling or resolving a complaint, investigation (including investigating a data breach), conducting recruitment processes or otherwise performing any particular function or activity we are carrying out.

The types of personal information we collect

Depending on the nature of our relationship and interactions with you, we may collect a range of personal information.  This includes your name, contact details (including your address, email address and phone number), gender, location, interests, job status, organisation and IP address.  If you attend one of our events, we may also take audio or visual recordings which identify you.  We may collect these types of personal information directly from you or from third parties.

On occasion, we may collect sensitive information about you.  However, we will only do this with your consent or otherwise in accordance with applicable laws.

If you apply for employment with us

We also collect personal information when recruiting people to work with us.  This may include the types of information listed above, along with your qualifications, work history and reference details.  Before offering you a position, we may check additional details such as your tax file number, superannuation information and other background check information (such as police clearances, to the extent required or permitted by applicable laws).

Generally, we will collect this information directly from you.  We may also collect this information from third parties (such as recruitment agencies, background check agencies or your referees).

Cookies and analytics

We may from time to time use cookies or other trackers on our websites. A cookie is a small piece of text that is placed within the memory of a computer device and can be later retrieved by web page servers to uniquely identify users and enhance interaction and convenience. Cookies may record information about your visit, including the type of browser and operating system you use, the pages you access and the information downloaded by you.  If you do not wish to receive cookies, you can configure your browser so that your computer does not accept them.  Some services or features of our website will not function correctly if cookies are disabled.

Cookies and other trackers are used on our website to locate a person where we believe unlawful or inappropriate activity has occurred in connection with our website, or when required or authorised by law. 

We may also use Google reCAPTCHA (ReCAPTCHA) on our website.  This service is provided by Google LLC, of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). ReCAPTCHA analyses the data entered on our website (such as on a contact form) in order to determine whether the user is a real person or a “bot” for the purposes of preventing “automated software” from weighing down our website by automated crawling or spam. The information analysed, which may include the user’s IP address, the typing patterns of the user, the amount of mouse clicks a user has done on the site and the language the user’s browser is using, will be sent to Google. All the information gathered by ReCAPTCHA is being held by Google in accordance with Google Terms of Service and Google Privacy Policy.

Anonymous dealings

You may choose to remain anonymous or use a pseudonym in your communications with us where it is lawful and practicable.  However, if you choose to do so, please note that we may not be able to provide you with information or goods or services, or effectively manage our relationship with you.

STORING PERSONAL INFORMATION

Storage

Where you send information for a particular purpose, for instance, your CV in respect of a job application, it will be stored in accordance with our current business practices which are designed to maintain confidentiality.  If you ask us to destroy this information, we will, subject to any applicable law or regulations that require us to retain your performance information.  Please note, if you choose to delete the personal information we hold about you, we may not be able to provide you with the requested information, products or services, or to effectively conduct our relationship with you.

We will take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. We do this by having physical and electronic security systems, limiting who can access your personal information and training our staff to keep your information safe and secure.  We also endeavour to take reasonable steps to destroy or de-identify personal information that we no longer need it for any purpose for which the information may be used, disclosed or retained under the Privacy Act.

We cannot guarantee the security of any information that is transmitted to or by us over the internet, unless using transmission and data encryption and associated connection or user authentication methods that we specifically provide and control.  The transmission and exchange of information is carried out at your own risk.  Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the internet and you do so at your own risk.

Overseas disclosure and storage

Typically, we will store personal information on our information network within Australia.  Personal information may also be sent offshore to related bodies corporate, as permitted by the Privacy Act, which are located in the United Kingdom, Europe and the Americas. 

In addition, it is possible that we, or our contractors, will utilise cloud and other technologies in connection with the storage of personal information, and this may result in offshore storage. It is not practicable for us to specify, in advance, the countries in which that personal information may be stored.  Where we share your personal information with overseas entities, we will do so in compliance with the Privacy Act, and will take reasonable steps to ensure that such entities similarly agree to protect that information.

USING AND DISCLOSING PERSONAL INFORMATION

General use and disclosure

We may use and disclose your personal information for the purposes for which it is collected, for a secondary purpose which is related to that primary purpose and for which you might reasonably expect us to use or disclose your personal information for that secondary purpose or otherwise permitted by law.

In general, we use and disclose personal information for the following purposes:

• to identify and develop renewable energy and battery storage projects; including project scoping, preparing and securing project approvals, feasibility studies and assessments, and interactions with stakeholders and government bodies;
• for project development activities, project, construction and asset management, operation and maintenance services, and exploring and securing project debt / equity investment and development partner opportunities, and any resulting transactions;
• to communicate about renewable energy projects we are developing or providing services to; including responding to your requests for information, complaints and other inquiries or concerns. This includes engaging in community and stakeholder initiatives;
• to identify project sites, secure land tenure and approvals, and undertake business operations related to those sites, including dealings with landowners, occupiers, neighbours and local community members;
• to manage our business or commercial relationship with you, including to communicate with our contractors and suppliers, shareholders, existing or potential business partners (including parties we are in or proposing to enter joint ventures with) and, in relation to projects under development or management, landowners and occupiers, community members, public bodies and other interested parties;
• to administer our business (including for data storage /, printing, mailing, marketing, planning and goods or services development) or to source products or services for us, and to monitor, analyse or improve our business, services or website. This may include provision of information to third parties such as IT service providers, providers of project management services, project contractors, professional advisers and payment system operators;
• to provide products or services to you or your employer;
• to enable employees to undertake normal business activities as part of their role;
• to consider applications for employment (including reference checking), sponsorship and grants;
• to comply with our legal and regulatory obligations and exercise our legal rights;
• to conduct analytics, market research and marketing in relation to our projects and business. We do not sell personal information or disclose it to third parties for purposes unrelated to the reasons we hold;
• to enable access and use of our website, applications and social media platforms; and
• to undertake postal and other media campaigns using third party databases to obtain addresses of local people.

Your personal information may also be disclosed:

• between related bodies corporate within the RES Group located in Australia or overseas, and used by those entities for the same purposes for which we are entitled to use it; and
• to our third-party service providers and business associates who provide services in connection with our business, products and services, and to third parties such as joint venturers who work with us in developing renewable energy and battery storage projects, or anyone to whom our business or assets (or any part of them) are, or may (in good faith) be transferred.

 

These third parties may be located, or store data, locally or overseas, and may include service providers and specialist advisers who have been contracted to provide administrative, financial, information technology, marketing / business analysis or other services.

We may also disclose your personal information (including to overseas recipients):

• with your express consent; or
• to insurers, lawyers, courts, tribunals, public bodies and regulatory authorities, and any other person where we are required, authorised or permitted to do so by law; and
• to any person specifically authorised by you to act on your behalf.

We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date when using or disclosing information, and having regard to the purpose of the use or disclosure.  To protect your personal information when disclosing it to third parties, we also include suitable privacy provisions in our contracts.

Marketing

We may use and disclose the personal information you provide to us to send marketing information to you, including promotional material about us and the goods and services of relevant third parties.  We may send you such information by direct mail, email, SMS, MMS or other similar means, in accordance with applicable marketing laws.

If you do not want to receive marketing information from us, you can unsubscribe by emailing us (see email contact below) or by clicking on the “unsubscribe” link in an automated mailout you have received from us.  Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of our services and other factual information as permitted under applicable laws.

We do not use sensitive information for marketing purposes.

ACCESSING AND CORRECTION OF PERSONAL INFORMATION

If you would like to access any of the personal information we hold about you, or advise us of any required correction to your personal information, please send your request to us via email (see email contact below).  We will respond to all requests for access and/or correction within a reasonable time. 

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.

Upon request for access to personal information, we will provide you with details of any of your personal information that we hold, subject to appropriate identity verification and except in the limited circumstances permitted by law where access can be refused (for example if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality).  If we refuse a request for information, or decide to charge such a fee, we will provide you with a reason for our decision as required by applicable privacy laws.

If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct or update that information in accordance with applicable privacy laws following your request.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

When your personal information is no longer needed for the purpose for which it was obtained, or as required by law, we will take reasonable steps to destroy or permanently de-identify your personal information (including sensitive information).

INQUIRIES AND COMPLAINTS

You can contact us at any time if you have any queries or concerns about this policy or the way in which your personal information has been handled, or if you have a privacy complaint, by contacting us at ausprivacy@res-group.com

We will consider your questions, concerns and complaints to work out what steps can be taken in response.  If you make a complaint which requires detailed consideration or investigation, we may ask you to give us more information about your complaint and the outcome you are seeking.  We may need to gather relevant facts, locate and review relevant documents and speak with other people involved.  In any event, we will endeavour to acknowledge your complaint or inquiry within 30 days.

If you are not satisfied with an outcome following the above process, you may wish to contact the Office of the Australian Information Commissioner at:

www.oaic.gov.au

1300 363 992

Joint ventures involving RES Australia

RES Australia is involved in various joint ventures with third parties in relation to renewable energy projects in Australia, including the Central Queensland Power joint venture.  This policy does not apply to those joint ventures – which, where applicable, will have in place their own privacy-related policies.

RES GROUP WEBSITE

Please refer to the the privacy policy published on the RES Group website, available at: https://www.res-group.com/privacy-policy/ to find out more information about how RES Group collects and uses personal information collected via RES Group’s website.

Privacy Policy Updates

We will update this policy from time to time, by publishing a revised version online, which will include the date of the change.

For any questions or notices, please contact our Privacy Officer at: ausprivacy@res-group.com

 

RES Australia Pty Ltd