Privacy Statement

Gulf Energy is committed to recognising and respecting your privacy

This Privacy Statement details how Gulf Energy collects, holds, uses and discloses personal information. It sets out rights in relation to personal information and how you can contact us. 

 In this Privacy Statement, references to ‘Gulf Energy ’, ‘we’ or ‘us’ means Gulf Energy Pty Ltd (ABN 58 094 620 176) and all related or subsidiary companies both in and out of Australia. 

 This privacy statement was last updated on 17 April 2023. The contents of this Privacy Statement and the disclaimer may be updated from time to time by publishing the updated version on Gulf Energy’s website. You should regularly check this Privacy Statement to ensure you have the latest versions. By dealing with Gulf Energy, you acknowledge that you have understood and accept the contents of this Privacy Statement and the disclaimer including any changes made to these documents by Gulf Energy from time to time. 

Who does this Privacy Statement apply to? 

This Privacy Statement applies to: 

• Directors, officers and employees of Gulf Energy. 

• Employees of contractors to Gulf Energy. 

• Individuals external to Gulf Energy including: 

• Visitors to and users of our website. 

• Visitors to our offices or sites. 

• Potential employees. 

• Investors or prospective investors, and employees of such investors. 

• Parties with whom Gulf Energy has business relationships, and employees of such parties. 

• Joint venture participants. 

• Customers. 

• Stakeholders. 

What is personal information?

Personal information is information or an opinion about you as an individual that identifies you or from which your identity can be ascertained, or any other information protected as ‘personal information’ under applicable law. 

What is sensitive information?

Sensitive information means certain special categories of personal information that are deemed as ‘sensitive’ under applicable law.  

Sensitive information includes information about a person’s: 

• Racial or ethnic origin. 

• Political opinions. 

• Membership or political association. 

• Religious beliefs or affiliations. 

• Philosophical beliefs. 

• Membership of a professional or trade association. 

• Membership of a trade union. 

• Sexual preferences or practices. 

• Criminal record. 

• Health, genetics or biometrics. 

Types of information collected

 During your dealings with Gulf Energy, we, our agents and service providers may collect or receive some or all of the following information about you. 

Website interaction information 

When visiting Gulf Energy’s website, Gulf Energy keeps a record of your visit. The following information may be collected for statistical purposes and may be used by Gulf Energy to help improve the website: 

• Your Internet Protocol (IP) address. 

• The previous site you visited. 

• Your type of browser and operating system. 

• T he pages you access and the documents you download. 

Gulf Energy will not attempt to identify users or their browsing activities, however, government agencies may be entitled to inspect such records in the event of an investigation. 

During your visit to our website, we may also ask you to provide us with other information. For example, if you wish to request information from us, you may provide your email address and information about your interests. Similarly, if you apply for a job via our website, we will receive details of your application (including your CV).  

Cookies 

The website uses tracking technologies called ‘cookies’, including to monitor the pages accessed by browsers on our website. Third party cookies may be placed by contracted service providers on Gulf Energy’s website and Gulf Energy may share anonymous aggregate information from the website with contracted service providers. You may set your browser to refuse cookies if you wish, although this may affect your browsing experience. 

Cookies are small text files which are stored in memory or on your hard drive for record keeping purposes and are used to enhance Gulf Energy’s website. 

You may set your browser to refuse cookies without impacting the use of the Gulf Energy website. You can find out how to do this at visit www.aboutcookies.org or  www.allaboutcookies.org

The website uses cookies which perform the following functions: 

• utmz - records whether the visitor came from a search engine (and if so, the search keyword used), a link, or from no previous page (e.g. a bookmark). 

• utma - stores the amount of visits for each visitor, the time of the first visit, the previous visit, and the current visit. 

• utmb and utmc - checks how fast people leave and when a visit starts and ends. 

• WSS_FullScreenMode - indicates whether a page is shown in full screen mode and expires when you close your browser. 

The cookies (other than WSS FullScreen Mode) are stored by Google Analytics to see how people visit the website and capture trends, but do not identify the user. The information may be collected for statistical purposes and used by Gulf Energy to help improve the website. 

Links to other websites and social media 

Other websites and social media may be accessible via hyperlinks from the Gulf Energy website. Gulf Energy is not responsible for the levels of data protection afforded to you by these other websites and social media platforms. We encourage you to review the separate privacy guidance for these websites and platforms before using them.  

Gulf Energy may provide links to other websites and social media features (e.g. so that you can interact with Gulf Energy on social media websites). As these are third party websites and features, Gulf Energy cannot be responsible for your use of them.  

Your use of other websites and social media features could lead to the collection or sharing of information about you. 

Those websites and social media platforms are not subject to this Privacy Statement. Gulf Energy encourages you to review the privacy guidance and settings of each website and social media platform with which you interact to assess whether the guidance and settings are satisfactory to you in relation to the collection, use and disclosure of information by those websites and platforms. 

We may also collect, use or disclose personal information to regulatory or governmental agencies in the event of an investigation in order to meet our on-going regulatory and compliance obligations. Where permitted or authorised by law, we use systems designed to flag suspicions of potentially unlawful or fraudulent activity. 

We will only collect the above personal information to the extent permitted by applicable law. 

Third party information you provide 

Occasionally, you may give us personal information about other people - for example your referees or authorised representatives. If so, you must tell those individuals that you are giving their personal information to us and that this Privacy Statement governs the collection, use, disclosure and storage of that information, and obtain their consent. 

Government related identifiers 

A government related identifier of an individual is one that has been assigned by a government agency or authority, or an agent of these, or a contracted service provider for a government contract acting that capacity. Examples of government related identifiers may include your Tax File Number or Medicare number. Gulf Energy does not use government related identifiers as a means of identifying the personal information we may have collected about you. 

Information about directors, officers, employees and contractors’ employees 

In addition to the information outlined above, if you interact with Gulf Energy as a director, officer, employee, or contractors’ employee, we, our agents or our service providers may collect some or all of the following information about you, where appropriate. Please note that this list is not exhaustive: 

• Your date of birth, gender, emergency contact and next of kin details. 

• Medical information. 

• Your tax file number and bank account details. 

References about you.

 •Other recruitment related information including criminal record checks where permitted by law, sanctions and bankruptcy checks, directorships and shareholdings, 100 points identification, verification of qualifications or licenses and evidence of ability to work in Australia or another country. 

• Working with children checks. 

• Your passport, visa, frequent flyer number, driver’s license number and vehicle details. 

• Your GPS location when utilising Gulf Energy vehicles and other plant and equipment. 

• Biometric information including samples and templates.  

• Information about your access to Gulf Energy sites, premises, systems and assets. 

• Details of any grievance or disciplinary matters, whether brought by or against you or in which you are otherwise involved. 

• Details of any leave you take or request during your employment, or sickness absence including health-related information. 

• Diversity information including racial or ethnic origin, religious or other beliefs, and physical or mental health, including disability-related information. 

• Other information relevant to your relationship with us or the Gulf Energy Code of Business Conduct and Ethics. 

Medical information collected from employees may relate to pre-employment medicals, alcohol and drug tests, periodic medicals and related documentation to support ongoing fitness for work (such as for remote environments, to meet statutory requirements, demonstrate emergency response capability, travel or assurance relating to capacity or return to work), health and well-being (such as flu vaccinations) and occupational exposure monitoring. De-identified biometric information (e.g. blood pressure, cholesterol level and other medical test results) may be collected as summary information as to workforce health and the success of health and well-being initiatives. 

Biometric data collected from directors, officers, employees and contractors’ employees may relate to maintaining security or safety with respect to Gulf Energy sites, premises, systems, assets, equipment or people and absence monitoring. CCTV footage may be collected at Gulf Energy premises and used, disclosed and stored for security and safety related purposes.

 Gulf Energy only collects, uses or discloses sensitive information about you as allowed by law, for example, where we need to process this information in order to make reasonable adjustments to the workplace for you, or where we have received your consent to do so and the collection is reasonably necessary for one or more of  Gulf Energy’s functions or activities, or the collection is necessary for the establishment, exercise or defence or a legal or equitable claim, or to meet some other legal obligation. See Why we collect, hold, use and disclose personal information below.

Why we collect, hold, use and disclose personal information

We use your information for our legitimate business interests, in order to comply with regulatory obligations and in connection with investigations or claims. Sometimes, we will ask for your express consent to use certain types of personal information and, where we do so, you may have the right to withdraw that consent.  

Gulf Energy may collect, use and store this personal information for the following legitimate business interests of Gulf Energy, including: 

• Facilitating our internal business and oil and gas operations, work management and maintain proper business records. 

• Administering databases (including our contracts database). 

• Establishing and managing good commercial or stakeholder relations with you or the organisation with which you are associated. 

• Engaging in business sales or acquisitions or joint ventures. 

• Receiving and providing services (including maintaining records of business relationships). 

• Arranging travel. 

• Investigating or responding to any incidents, complaints or grievances. 

• Authenticating your access to protect and maintain the security and safety of Gulf Energy -owned or operated premises, sites, systems and assets and people. 

• To monitor and take responsible action in relation to adherence to Gulf Energy’s management system requirements 

• Learning more about customers, stakeholders and products, services or information you receive or may be interested in receiving. 

• Giving you the option of receiving our publications. 

• Inviting you to Gulf Energy functions. 

• Taking steps to improve our products, services and stakeholder communication and our use of technology. 

• Billing and accounts. 

• Publishing information sources used in advertising and mailing lists for public relations. 

We may also use your information in order to comply with the law or enforce the law or cooperate with investigations carried out by the police, government or regulators, or for the establishment, exercise or defence of a legal or equitable claims. 

We may sometimes ask you for your consent to use personal information for other purposes. If we do, we will ask for your consent explicitly and you may be entitled to withdraw that consent. 

Information about directors, officers, employees and contractors’ employees 

In addition to the above, if you interact with Gulf Energy as a director, officer, employee or contractors’ employee, Gulf Energy may collect, use and store personal information for the following legitimate business interests of Gulf Energy: 

• Carrying out the recruitment and administration of staff and human resources activities (including payroll and benefits administration, maintaining emergency contact and beneficiary details, assessing your performance, disciplinary procedures, absence monitoring and training/people management). 

• Facilitating the operation of employee incentive arrangements, such as bonus plans, the Gulf Energy ESOP and the Executive Incentive Scheme (or any other employee equity plan introduced from time to time). 

• Facilitating participation in volunteering opportunities. 

• Undertaking due diligence activities. 

Gulf Energy may also collect, use and store personal information of directors, officers, employees or contractors’ employees in accordance with its written policies and procedures.

Cross-border disclosure of information 

Due to the global nature of Gulf Energy’s business, we may disclose your information to recipients who are outside of the country in which your personal information was collected. For example, the recipient may be in a country outside of Australia and the European Economic Area (EEA), which does not have laws in place that require your personal information to be protected in the same way as it would be within Australia or the EEA. Gulf Energy will ensure that disclosure to overseas recipients occurs in accordance with applicable privacy laws and that measures are put in place to safeguard your personal information (e.g. contracts obliging the third party to protect your data). 

Personal information held by Gulf Energy may be disclosed for specific purposes from time to time and this may occur in the many countries around the world.  

The countries in which Gulf Energy processes or stores data from time to time may include: 

Australia. 

United Kingdom. 

Singapore. 

Canada.

European Economic Area. 

USA.

Japan.

Korea.

Indonesia. 

Malaysia. 

Brunei. 

Qatar. 

Dubai. 

Saudi Arabia. 

China. 

India.

Personal information may be disclosed to providers around the world. 

Gulf Energy, its contracted services providers (and their affiliates or subcontractors) may also use cloud services, systems and servers both within and outside of Australia to store and manage your personal information. Gulf Energy requires its service providers to ensure that any data transfer in relation to such cloud storage occurs in accordance with applicable privacy laws. 

Gulf Energy requires service providers it contracts with from time to time to take appropriate steps to protect the privacy and manage the security of your personal information. 

If you have any further questions about the protections Gulf Energy puts in place when transferring information overseas, please contact our Privacy Officer. 

How we collect personal information 

We may receive information about you whenever you interact with us, including via our website, emails, letters, applications, calls, enquiries about our products, our business or an investment in Gulf Energy, or when you respond to surveys or other invitations to engage with v, etc. We may also receive information about you from third parties (e.g. public registers). 

If you are a director, officer, employee or contractors’ employee, we will generally collect personal information from you directly. However, sometimes information may be collected about you from some or all of the following other sources, where relevant. Please note that this list is not exhaustive: 

• From third parties, such as our agents or your representatives or (in the case of contractors’ employees) the organization for which you work. 

Your employer, in the case of contractors’ employees (for example, we may be organising travel and accommodation arrangements for you, for you to do some business with Gulf Energy, so we may need to ask your employer about any health or special dietary requirements you have or your passport and/or visa details). 

We may require personal information to ensure that you are covered by insurance policies, and we request this information from a health provider or another insurance company in order to ensure coverage is quickly organised. 

From public sources such as a public register, for example, to check directorships and shareholdings, as part of monitoring compliance with Gulf Energy’s Code of Business Conduct and Ethics.

In some cases, where entitled by law, you may also be entitled to withdraw your consent where this is the basis on which Gulf Energy is processing your personal information. 

How we secure and retain personal information 

Security 

The security of your personal information is important to us. Gulf Energy takes such steps as are reasonable in the circumstances to protect personal information from loss, misuse, interferences, unauthorised access, modification or disclosure. However, please note that no method of protection is 100% secure and we cannot guarantee absolute security.  If a security breach occurs, we will notify you of the incident and the measures taken to reduce risks in accordance with applicable law. Please notify us immediately if you become aware of any breach of security. 

Gulf Energy employs several means to protect your personal information, including: 

• External and internal premises security measures designed to ensure that your information is not capable of being seen or modified by unauthorised persons. 

• Restricted access to personal information. 

• Maintaining technology products designed to prevent unauthorised computer access. 

• Regular review and testing of our technology in order to improve the level of security. 

• Implementation of mandatory requirements in relation to use of Gulf Energy’s IT Systems.

It is important to be aware that email is generally not a secure way to communicate. Personal information contained within emails sent to and from email addresses external to Gulf Energy may not be secure.

 

Retention 

Gulf Energy will retain your data in line with good record-keeping practices. The relevant time period for retention of your information is determined in accordance with relevant legal and regulatory requirements, the purpose for which your personal information was collected, limitation periods for any claims that might arise and industry practice guidelines.

 Gulf Energy’s approach to retention and disposal of information groups ‘like information’ together in order to apply Gulf Energy’s retention rules according to legal and operational requirements. This policy is based on best practice, the Australian Records Retention Manual and legal requirements in applicable laws.  After the requisite time has passed, we will take such steps as are reasonable in the circumstances to attend to the destruction, de-identification or deletion of your personal information. 

Individual rights 

Gulf Energy complies with applicable laws which grant individuals certain rights in respect of their personal information (e.g., rights to access, correct, delete, withdraw consent, complain etc.). You can contact our Privacy Officer to exercise your rights. 

The rights that individuals have in respect of their personal information vary from country to country. We set out below a list of the key rights you should be aware of. Some rights will not apply in some jurisdictions and there may also be limitations on the ways in which rights can be exercised. 

Please contact our Privacy Officer if you would like to request the exercise of any of these rights in relation to your personal information held by Gulf Energy . If we deny your request, we will explain why.

 

Right to access 

You may request access to or correction of any of the personal information Gulf Energy holds about you. Your entitlement to access your personal information will be subject to applicable laws. 

For more detailed requests for access to personal information, for example, access to information held in archives, a fee may be charged where permitted under applicable laws to cover the cost of retrieval and supply of this information to you. 

Your request for access will be handled as soon as reasonably practicable. We will comply with applicable laws and, in any event, endeavor to process your request within 30 days after receiving the request. Some requests may take longer to process depending upon the nature of the personal information being sought. 

Right to correction 

Gulf Energy takes reasonable steps to ensure that information is up to date and complete. However, if you believe the information, we hold about you is inaccurate or incomplete, you may request that we correct it. 

You may request that we correct any of the personal information which we hold about you, to ensure that having regard to the purpose for which we hold it, the information is accurate, up to date, complete relevant and not misleading. 

If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal information to. 

If we refuse your request, we will tell you in writing why we have done so, as well as the mechanisms which are available to you to complain about our refusal and anything else of which we are required to inform you. 

Right to object to, or restrict use of, data 

You may write to us to object to us using your personal information – either generally or for specific purposes. 

Right of deletion 

In some circumstances, you may be able to request that Gulf Energy erase some or all of the personal information we hold about you. 

Right to data portability 

If you have made personal information available to us for automated processing and have provided your explicit consent for that processing (or that processing is required for the purposes of a contract between Gulf Energy and you), you may be able to ask us to transfer that data to you or a third party in a machine-readable format. 

Right to withdraw consent 

If you have given us explicit consent for the use of your personal information, you may later withdraw that consent (although this will not affect the lawfulness of our previous use of your information). 

Right to make a complaint 

If you believe that Gulf Energy has not protected your personal information as set out in this Privacy Statement or has breached your privacy rights in any way, you may lodge a complaint with us by contacting our Privacy Officer using the contact details set out below. 

On receipt of your complaint, Gulf Energy will: 

• Provide a written acknowledgement or receipt 

• Promptly investigate the complaint and let you know if further information is required to investigate it 

• Endeavour to provide you with a substantive written response within 30 days 

Contact our Privacy Officer 

Our Privacy Officer is responsible for Gulf Energy's management of data privacy. You can contact our Privacy Officer for all queries relating to data privacy or in order to exercise your rights. 

Our Privacy Officer is able to receive queries on behalf of all Gulf Energy entities and, if required, can also confirm which Gulf Energy entity is a data controller of your personal information, and provide further contact details for that entity. 

Note, our Privacy Officer does not amount to a data protection officer for the purposes of the European General Data Protection Regulation.  

You can contact our Privacy Officer in any of the following ways: 

• By emailing privacy@gulfenergy.com.au 

• By phone in Australia: +61 2 9247 9888, between 8:00 am and 4:00 pm AWST, Monday to Friday. 

• By sending a letter to: 

  The Privacy Officer 
 Gulf Energy Pty Ltd 

Suite 2, Level 10,
  52 Alfred Street, Milsons Point NSW 2061 Australia

Privacy Regulators 

We invite you to first discuss with us any concerns or queries you might have. If you are not happy with our handling of your concern or query, you can contact the relevant privacy regulator.  

In Australia, the privacy regulator is the Office of the Australian Information Commissioner

•By telephoning 1300 363 992 (of +61 2 9284 9749 if calling from outside Australia). 

•By fax to +61 2 92849666. 

•By emailing enquiries@oaic.gov.au 

By writing to: 

  Director of Compliance 
  Office of the Australian Information Commissioner 
  GPO Box 5218 
  Sydney, New South Wales 2001 

In the European Union, the privacy regulators for each Member State are listed (along with contact details) on the following website: http://edpb.europa.eu/about-edpb/about-edpb/members. 

Read more about Gulf’s ESG commitment to:

Read Gulf’s Policies on: