Scope

This policy relates to all direct employees of Coogee and its related entities.

Personal Information

Personal Information we collect

Coogee collects personal information (including sensitive information) about clients, suppliers, job
applicants, representatives of regulatory bodies and other individuals who interact with the Company. Coogee will only use and disclose personal information for the purposes for which it was collected, or otherwise in accordance with the Privacy Act.

Personal information is obtained in many ways including but not limited to interviews, correspondence, by telephone and facsimile, by email, via websites and from third parties. We collect personal information for the primary purpose of providing services, providing information to our clients and marketing. We may also use personal information for secondary purposes closely related to the primary purpose, in circumstances where such use or disclosure would be reasonably expected.

When we collect personal information we will, where appropriate and where possible, explain why we are collecting the information and how we plan to use it. By providing us with personal information the provider consents to the Company handling this information in accordance with this Privacy Policy.

The types of information Coogee collects include:

• Names, job titles, contact and address details
• Information in identification documents (for example passport, driver’s license)
• Tax file numbers and other government issued identification numbers
• Date of birth and gender
• Bank account details
• Details of superannuation and insurance arrangements
• Educational qualifications, employment history, salary and referee reports
• Visa or work permit status
• Internet Protocol (IP) address
• Payment details
• Personal information about spouse or dependents
• Photographic images
• Any additional information provided to us directly through our website or indirectly through use of our websites, through our representatives or otherwise; and
• Information provided to us through customer service, surveys or visits by our representatives from time to time.

It may be necessary in some circumstances for Coogee to collect sensitive information in order to provide specific services or for recruitment purposes. Examples of types of sensitive information that may be collected in such circumstances include professional memberships, ethnic origin, criminal record, psychometric testing results, biometric information, directorship, identity, eligibility to work and health information.

For customers, we may collect information in relation to credit standing.It is generally not practical to remain anonymous or to use a pseudonym when dealing with Coogee as usually we need to use personal information to provide specific services.

How we collect and manage personal information

Generally Coogee collects personal information either over the phone, in person or via correspondence such as email.

On occasion it may be necessary to collect personal information from a third party. Coogee may collect information from a personal representative, another Coogee member, or as part of the selection process from previous employers or a publicly available record.

We may collect and use health and other personal information to ensure the health and safety of work colleagues.

Coogee also collects statistical information about visitors to our website using web analytics provided by third party service providers such as Google Analytics. These services use ‘cookies’ that allows our system to identify and interact more effectively with your browser. Cookies assists us in understanding how visitors access and utilise our site, remembering your details and preferences for when you return. You can configure you web browser software to reject cookies however some parts of our website may not have full functionality as a result.

Our website may use Google services such as Google Analytics from time to time. For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/.

Personal information about third parties

Personal information provided to us which relates to a third party should only be done with the consent of that party.

Holding personal information

Coogee holds personal information in hard copy and electronic formats. We have security measures in place to protect the personal information that we collect and hold. These steps include security passes to enter our offices and storage of files in lockable cabinets, password protection for accessing our electronic IT system, restriction of access, firewalls etc.

Personal information or information disclosed to the Company under a non-disclosure agreement will not be released without the permission of the person providing the information except as prescribed by law. Personal information is destroyed or de-identified when no longer needed in accordance with the requirements of the Archives Act 1983 (Cth).

Purpose for which we collect, hold, use and disclose personal information
Coogee collects, holds and uses personal information for a number of purposes including:

• To verify identity
• For recruitment and administrative purposes including processing payment transactions
• For purposes relating to the employment of staff
• When engaging service providers, contractors or suppliers relating to the operation of ourbusines
• To provide and enhance professional services
• To respond to requests or queries
• To maintain contact with our clients and other contacts
• To keep our clients and other contacts informed of our services and industry developments
• To conduct surveys
• For seeking feedback from customers
• To meet any regulatory obligations
• To update our records
• To process and respond to any complaints
• For any other business related purposes.The types of third parties to whom we may disclose your personal information includes:
  • Our service providers
  • Government or regulatory bodies or agencies, as part of an engagement or otherwise. Forexample the Australian Taxation Office.We do not disclose personal information to third parties for the purpose of allowing them to send marketing material.
  • Gaining access to and keeping current personal information we hold up to date

Individuals or entities may request access to any personal information we hold about them at any time by contacting the Human Resources team via email. Coogee will endeavour to grant access to such information as soon as possible, subject to the circumstances of the request.

A request to access information will be declined if providing access would have an unreasonable impact on the privacy of another person; would pose a serious and imminent threat to the life or health of any person; or would prejudice Coogee’s legal rights.

If any information we hold is incorrect, incomplete or inaccurate a request to have it amended may be made. To do so, please contact the Human Resources team via email and we will take reasonable steps to correct or update the information in accordance with the Privacy Act.

Complaints

Any complaints relation to a potential breach of privacy should be made to a member of the Human Resources team so that the complaint can be investigated as per our complaints resolution process.

When a complaint is received, Coogee will conduct internal enquiries into the possible breach. Coogee will deal with any complaints as quickly as possible and will keep the complainant informed of its progress.

Coogee may decline to investigate the complaint if the complaint relates to an act or practice that is not an interference with the privacy of the person or entity making the complaint.

Policy

Coogee Chemicals Pty Ltd (The Company) recognises the importance of privacy and protecting the privacy of individuals. This policy operates in accordance with the Australia Privacy Principles contained in the Privacy Act 1988 (Cth) and outlines the broad controls Coogee has adopted to govern how we collect, store, use, disclose, dispose and otherwise handle personal information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner.