We respect your right to privacy and recognise that maintaining confidentiality is an integral part of providing our services. We are committed to protecting and maintaining the privacy of all individuals with whom we deal. We are also committed to complying with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles.
This policy describes how we manage any personal information we collect about you and how we hold, use and disclose that information. It also explains how to contact us if you have any queries about our management of your personal information. This policy applies to you only to the extent that the collection and handling of your personal information by us is subject to the Privacy Act.
2. What is personal information?
Personal information is information or an opinion (regardless of its accuracy or form) about an individual, or from which the identity of a person is reasonably identifiable. It includes your name, age, gender and contact details.
3. What kind of personal information do we collect and hold?
We may ask for a range of personal information to enable us to issue and administer your shareholding in COG. The information we may request includes:
- date of birth;
- contact details;
- bank account details; and
- tax file numbers.
Without this detail we may not be able to administer your shareholding for you. It is your choice whether to provide your information to us, however, if you don’t, we may be unable to fulfill our responsibilities in relation to maintaining our share register and regulatory reporting obligations.
We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information relating to race, political or religious beliefs, sexual preferences, criminal convictions, health information.
4. How do we collect personal information?
We only collect personal information about you in the manner permitted by the Privacy Act. We will collect your personal information either through the intermediaries you have used when transacting in COG shares (such as your broker) or directly from you through the forms that you complete. We may also collect your personal information from organisations engaged by us to carry out functions on our behalf.
5. For what purposes do we collect, hold and use your personal information?
COG primarily collects, holds, uses and discloses shareholders’ personal information so we can establish, manage and administer the share register, update our records and disseminate information about COG. In addition, we may also collect personal information to fulfil our legal obligations under applicable laws and rules such as those relating to taxation and anti-money laundering.
6. How do we hold your personal information?
When holding your personal information, we are required by the Privacy Act to take reasonable steps:
- to ensure that your personal information that we collect, hold, use and disclose is accurate, complete and up-to-date;
- to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure; and
- to destroy or permanently de-identify your personal information if we no longer require that information for any purpose that is permitted by the Privacy Act.
All reasonable measures are taken to protect personal information we hold from unauthorised access, improper use, disclosure, unlawful destruction and accidental loss. To protect your privacy, we strongly urge you not to provide any personal information that is not required or that is not asked for.
COG does not use your personal information for direct marketing.
8. Access and Correction
We will take reasonable steps to ensure your personal information is accurate. You may request access to personal information we hold about you by writing to us or emailing us at the address below. You do not have to provide a reason for requesting access. Where we hold information that you are entitled to access, we will endeavour to provide you with the information within a reasonable period. If we deem it necessary to deny your application for personal information then we will give you our reasons for denial in writing. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate then you may request it to be amended. We will then consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
If we believe the information we hold is incomplete or out of date, we may also seek to correct or complete our records by gathering data from other sources such as public records and other organisations.
9. Are we likely to disclose your personal information to overseas recipients?
COG and its share registrar will generally not send personal information overseas.
10. Contact us
In the case of a complaint about a breach of the Australian Privacy Principles or the Privacy Act, we will respond to the complaint in writing within 30 days and endeavour to resolve the complaint to your satisfaction. If we are unable to resolve your complaint you can contact the Office of the Australian Information Commission [www.oaic.gov.au].
Date: 12 March 2014