SJN has appointed a Privacy Officer who will ensure that our activities are carried out in compliance with applicable laws. For questions regarding this Policy, to exercise your rights or to lodge a complaint with us, please contact our Privacy Officer at firstname.lastname@example.org .
- Personal Information is defined as information and data, whether recorded in a material form or not, relating to an identified or identifiable natural person that is processed by or on behalf of SJN, whether by automated means; and
Whose information do we collect?
SJN collects Personal Information from a range of individuals in the context of its business activities, including:
- representatives of our suppliers, customers, and business partners;
- industry association representatives;
- users of SJN websites; and
- job applicants.
What information we collect and why we collect it
We collect Personal Information from you where it is relevant for our purposes as further detailed below.
SJN may collect a range of information in a business context, such as your name, gender, job title, photographic identification, email address, home address and other contact details, details of your business and other interests, experience and/or academic and professional qualifications, third party references, communications with you (including notes from meetings and telephone call recordings), feedback or survey responses that you provide to us, financial and payment information, and information collected from questionnaires and/or interviews.
SJN uses information collected from you for business-related purposes, including negotiating, concluding and performing contracts, managing business relationships, administering real estate leases and licences, recruitment, managing accounts and records, communicating with you and third-party contacts, supporting corporate social responsibility activities, security, legal, regulatory and internal investigations and debt administration.
When you use our websites, SJN collects certain standard information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times, and any referring website addresses.
SJN uses this information to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. SJN also collects certain information to provide users with a personalised experience when visiting our websites. Through the use of a ‘cookie’, SJN can record information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page
- where a law enforcement agency exercises a warrant to inspect logs or any such information is otherwise required to be produced by SJN to authorities or regulators; or
- where SJN believes it is required to collect and produce relevant electronic documentation to fulfil its obligations to third parties, including statutory organisations under local law.
Access to other websites via hyperlink
Cookies & Related Technologies
You may set up your web browser to block cookies or remove cookies stored from your computer or mobile device. However, if you do so, you may not be able to use certain features and functions of our websites and apps.
Providing Personal Information
At times, SJN may ask you to voluntarily supply Personal Information, such as your name, email address, location, telephone number, and preferred means of communication, for purposes such as subscribing to SJN news alerts, direct marketing or requesting further information from SJN.
Where we ask you to voluntarily supply Personal Information, we will use it to provide you with the information or services that you have requested from us.
Sensitive Personal Information
Sensitive Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade- union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences may be processed by SJN if such processing is necessary to comply with laws and regulations or where you provide this information voluntarily or otherwise consent for us to do so.
SJN may monitor emails sent to and from its workforce, which may contain Personal Information relating to third parties. The information contained in such emails may be used for business-related purposes, for example when investigating incidents within SJN. Although SJN endeavours not to review the contents of personal emails, there may be occasions when this is necessary, for example, to investigate a breach of security within SJN, or in the context of legal proceedings.
The legal basis for SJN processing your Personal Information
To comply with applicable data protection and privacy laws, SJN is required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for SJN processing your Personal Information will typically be one of the following:
- your consent;
- the performance of a contract that we have in place with you or other individuals;
- SJN’s or our business partners’ legitimate business interests; or
- compliance with our legal obligations.
Disclosure of the information we collect
SJN may share your Personal Information with people within SJN who need to know that information for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within SJN.
We may disclose your Personal Information to third parties including the authorities, SJN’s advisors, suppliers of financial or IT services and third parties engaged by SJN for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from SJN’s websites; for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation; and to enforce SJN’s trading terms.
We may disclose your Personal Information to third parties if we sell, buy, or merge any business or assets, including to the prospective seller or buyer of such business or assets. SJN may also disclose the Personal Information you provide to us in connection with the job recruitment process to SJN HR practitioners and to SJN’s recruitment advisors for the purpose of considering you for career opportunities with SJN.
Transfer of your Personal Information to other countries
Retention of Personal Information
SJN’s aim is to keep your Personal Information for no longer than is necessary for regulatory or SJN’s business reasons. The amount of time for which records are kept varies depending upon the type of Personal Information they contain.
Your rights in relation to your Personal Information
If you would like to access or obtain a copy (which may be in machine-readable form) of the Personal Information SJN holds about you, please email your request to email@example.com.
SJN endeavours to ensure that the Personal Information it holds about you is complete, accurate, and up to date. If you consider that your Personal Information is incomplete, inaccurate, or out of date, you have the right to require us to correct it. To correct, erase or limit the processing of any of the Personal Information we hold about you, please email your request to firstname.lastname@example.org.
If you do not provide us with the information sought in the required fields, we may be limited in our ability to provide you with services.
Complaints and Concerns
If you have a concern or complaint about how SJN has used your Personal Information, as a first step, you should raise this in writing with SJN, via email to email@example.com.
If you are not satisfied with the handling of your concern or complaint by SJN, you can escalate this to the Australian Information Commissioner (www.oaic.gov.au) if you are in Australia.
Effective 1 December 2020