Privacy Policy – Shell Group Employee, Contractor and Dependents' Personal Data

Information for individuals who are or were employees, interns or individual contractors as well as dependents of Shell Energy employees.

This Policy sets out what personal data we collect, for what purposes and your rights in this respect.

 

Every individual within the Shell group of companies (‘Shell’) is responsible for protecting personal data about each other as well as that of our customers, business partners and suppliers.

This Privacy Policy provides information about personal data processed by Shell Energy Operations Propriety Limited and its affiliates (‘Shell Energy’ or ‘we’) in relation to individuals who are or were employees, interns or individual contractors as well as dependents listed as emergency contacts of Shell Energy or Powershop employees (‘Shell Energy Staff’).

For individuals who are referred to, express interest in or apply to work for Shell Energy, or who attend a recruitment event or undertake an assessment for Shell Energy, please refer to the Privacy Policy – Shell Energy Recruitment at shellenergy.com.au/privacy/

As well as this Privacy Policy, bespoke privacy policies and supplementary privacy statements containing further information about how we process your personal data, may exist for specific HR systems and processes (such as Chris21, HR21, Job adder, Cognology Onboarding and Workday Learning platforms). Details on these can be provided separately upon employee request.

This Privacy Policy explains what personal data are processed about you, why we are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.

Collection of information

We process personal data necessary to manage the application process and employment relationship and to engage contractors and interns of Shell Energy.

This includes personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information, emergency contacts, work history, qualifications, work performance information, information required to ensure you have the right to work in the country you are engaged in, as well as any other information necessary for managing the employment relationship and engaging contractors.

The categories of personal data we collect about you.

We may also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership. We will only process such personal data where it is necessary for the purposes of complying with employment and social security laws, for the establishment, exercise or defence of claims or where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health or where the individual has provided their explicit consent.

We will only process your personal data where we have a legal basis to do so.

We process your personal data:

    • in order to satisfy our obligations to comply with local laws and regulations;
    • for legitimate business interests (for example performance management in order to ensure we have qualified and competent personnel or for health, safety and security purposes to ensure that only authorised personnel can access certain sites or assets, litigation and defence of claims); or
    • where we have your explicit consent.

Please note that as a general principle, Shell Energy does not seek or rely on the consent of Shell Energy Staff for processing personal data. However, there are limited circumstances when consent is required, such as if required by applicable local law.

Personal data requested from Shell Energy Staff are the minimum required in order to fulfil legal and/or contractual requirements and to provide opportunities to take part in programs or to provide a benefit. Failure to provide us with the information requested may negatively affect your ability to remain in employment, internship or engagement as a contractor or from participating in a program or receiving a benefit.

In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. Withdrawal of consent may however impact your ability to remain employed or otherwise engaged or from participating in a program or receiving a benefit.

The purposes for which we process your personal data.

We process personal data covered by this Privacy Policy for the following purposes:

    • Human Resources, personnel management, business process execution, internal management, management reporting, organisational analysis and development – including budgetary, financial and organisational planning, administration, compensation, performance management;
    • Health, safety and security – including protection of Shell Energy’s Staff life or health, occupational health and safety, protection of Shell Energy’s assets and authentication of Shell Energy Staff status and access rights; or
    • Legal and/or regulatory compliance – including compliance with legal or regulatory requirements.

We may also process your personal data for a secondary purpose where it is closely related, such as:

    • storing, deleting or anonymising your personal data;
    • fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
    • statistical, historical or scientific research.

All activities on Shell Energy IT equipment and/or when connected to the Shell Energy IT network may be monitored in line with relevant legislation and company policies for legitimate business purposes.

All Shell Energy Staff receive an access pass which allows Shell Energy to record the date, time and access points made by individuals within Shell Energy premises and assets. The data from the access and security systems may be used:

    • for health, safety and security purposes, to prevent fraud and specifically the protection of Shell Energy assets, Shell Energy Staff and visitors to Shell Energy premises;
    • to comply with legal and regulatory requirements, specifically where there is a local legal requirement to provide information to government/regulatory authorities;
    • to monitor the number of individuals entering, exiting and working in a Shell Energy premises for human resources and/or real estate planning purposes.

Most of our premises and assets are equipped with surveillance cameras (CCTV). Where Shell Energy operate surveillance cameras, they will be identified. Surveillance cameras are used for health, safety and security and specifically the protection of Shell Energy assets, Shell Energy staff and visitors to Shell Energy premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or actual criminal activity, in which case they may be viewed by internal Shell Energy investigation teams and externally if legally required or permitted by law enforcement or other government authority.

In order to comply with legal and regulatory obligations, to protect Shell Energy’s assets and employees/contractors and specifically to ensure that Shell Energy can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we may carry out screening on all employees and contractors on a periodic basis.  This screening takes place against publicly available or government issued sanctions lists.

Any personal data collected through the screening will not involve profiling or automated decision-making regarding suitability for continued employment, internship or engagement as a contractor.

Shell Energy Operations Propriety Limited, 275 George Street, Brisbane QLD 4000, Australia will be responsible for processing your personal data, either solely or jointly with its affiliates within the Shell group of companies.

In the case of individual contractors, Shell Energy or its affiliates that have contracted your services solely or jointly within the Shell group of companies and your external contracting/employing company/agency.

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:

    • Other companies within the Shell group of companies, including to those which may be located outside of your location;
    • Authorised third party agents, service providers, external auditors and/or subcontractors of Shell Energy;
    • A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Shell Energy company/companies is subject to or as permitted by applicable law; or
    • Any person to whom Shell Energy proposes to transfer any of its rights and/or duties.

Your personal data may be transferred outside of your country, subject to appropriate safeguards.

Where your personal data has been transferred to companies within the Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data in accordance with the Privacy Act 1988 No. 119 and the Australian Privacy Principles (‘APPs’).  Companies within the Shell Group have adopted Binding Corporate Rules which you can access here.

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.

We’ll only store your personal data for as long as is necessary to fulfil the purposes outlined in this Privacy Policy or for as long as we reasonably consider necessary to establish, exercise or defend our legal rights.

Information may be held for (a) a longer period of time where there is a lawful reason to do so (in which case it will be deleted once no longer required for that purpose) or (b) a shorter period where you object to the processing of the personal data and there is no longer a legitimate business purpose to retain it.

Your rights and how to exercise them.

We aim to keep our information about you as accurate as possible. You can request:

    • access to your personal data;
    • correction or deletion of your personal data (in the case of deletion, only where it is no longer required for a legitimate business purpose);
    • that the processing of your personal data is restricted; and/or
    • that you receive personal data that you have provided to Shell Energy, in a structured, digital form to be transmitted to another party if this is technically feasible.

For those individuals who have access to HR21 you can access your personal data through: hr.shellenergy.com.au/ichris/Home/Index#/home

Alternatively, please contact a member of the Shell Energy HR team. If you are a contractor you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact [email protected] or the Shell group email [email protected].

If you have any issues, queries or complaints regarding the processing of your personal data please contact [email protected] or the Shell group email [email protected].

If you are unsatisfied with the handling of your personal data by Shell Energy, then you have the right to lodge a complaint to the Office of the Australian Information Commissioner at GPO Box 5218, Sydney NSW 2001, Australia, or the Dutch Data Protection Authority whose address is Prins Clauslaan 60, 2595 AJ The Hague, The Netherlands. Please visit oaic.gov.au or autoriteitpersoonsgegevens.nl/en for more information.

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This Privacy Policy is updated over time.

This Privacy Policy may be changed over time. You are advised to regularly review this Privacy Policy for possible changes. This Privacy Policy was last updated in May 2021.