Privacy Policy

Effective date: 23 January 2025

ASC is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Privacy Act) when dealing with personal information about individuals. The APPs set out minimum standards about how ASC can collect, use and manage your personal information.

This Policy details in general terms how ASC collects, stores, uses and discloses personal information about individuals, and the rights that individuals have to access and correct the information ASC holds about them. Employee records that are exempt from the operation of the APPs under the Privacy Act are not subject to this Policy.

In this Policy:

‘ASC‘, ‘we‘, ‘our‘ and ‘us‘ means ASC Pty Ltd and its related bodies corporate including but not limited to, ASC Engineering Pty Ltd, ASC Shipbuilding Pty Ltd, ASC OPV Shipbuilder Pty Ltd and ASC AWD Shipbuilder Pty Ltd, and their officers and employees; and
personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

Collection of Personal Information

ASC only collects personal information that is necessary for ASC’s business functions or activities. The types of personal information ASC collects from you will depend on the nature of ASC’s dealings with you, but generally includes (without limitation) names, addresses, contact details (such as telephone number, facsimile number and email address), information forming part of security clearance procedures including photos of individuals and other information that may assist ASC in conducting its business, meeting its legal obligations and addressing your queries.

ASC may also collect various types of sensitive information which are reasonably necessary for ASC’s business functions or activities, either with your consent or where permitted to do so under the Privacy Act or by law. Sensitive information is a particular category of personal information, and may include information about a person’s racial or ethnic origin, political opinions and associations, religious beliefs and affiliations, philosophical beliefs, membership of professional trade associations, membership of trade unions, criminal record, health information, genetic and biometric information.

All personal information collected by ASC will be collected by lawful and fair means, and not in an unreasonably intrusive way. In most cases, ASC will collect your personal information directly from you. ASC collects personal information about you when you use the ASC website, make an enquiry with ASC or enter into a contractual relationship with ASC. ASC may, also collect personal information about you from third parties (for example, in connection with security clearance procedures).

If you do not provide all of the personal information requested by ASC, then ASC may not be able to answer your queries, provide you with the requested information, products or services or engage in commercial dealings with you.

Where it is practicable and lawful to do so, ASC will enable you to interact with it anonymously or pseudonymously. However, there may be situations where it would not be practicable for ASC to deal with you on such a basis. This includes, for example (and without limitation) where you have requested access to or correction of the personal information ASC holds about you. In such situations, ASC will verify your identity before considering your access and/or correction request.

ASC may create de-identified or anonymous data from personal information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or other means. ASC’s use of de-identified or anonymised data is not subject to this privacy policy.

Use and Disclosure

ASC only uses personal information for the primary purpose of its collection (being the particular purpose or reason why the information was collected by ASC). ASC collects and holds personal information about you for the purpose of:

to operate our business, including but not limited to negotiating, managing and fulfilling contracts with our customers and suppliers and other third parties;
providing you and your company with goods and or services and to otherwise fulfil our contractual and legal obligations;
for record-keeping and administrative purposes;
for fraud, loss and other crime prevention purposes;
to protect and to defend ASC’s rights and property, including through cross referencing of personal information against security camera system footage;
to comply with laws, regulations, court orders, and other legal or statutory obligations imposed on us, or pursuant to legal processes;
to maintain a safe working environment for ASC’s staff, visitors and contractors;
for recruitment related purposes;
answering your enquiries and providing you with information you may have requested; and
providing you (or your company) with information that ASC considers relevant.

ASC may disclose your personal information to:

ASC’s related bodies corporate;
other companies or individuals that assist ASC in providing services or that perform functions on ASC’s behalf, including (but not limited to) agents, consultants and solicitors;
the Australian Security Intelligence Organisation, Australian Police Force, Australian Federal Police, the Department of Home Affairs and other organisations that have a role in Australian security clearance procedures; and
anyone else to whom you authorise ASC to disclose your personal information.

ASC will not provide your personal information to any party for the purpose of that party using your personal information to market, offer or sell their products to you.

Apart from using your personal information for the primary purpose described above, ASC may also use your personal information for a related secondary purpose (or a directly related secondary purpose, in the case of your sensitive information) where you consent to that use, where ASC considers you would reasonably expect ASC to use or disclose it for that secondary purpose, or where otherwise permitted to do so under the Privacy Act.

In limited circumstances under the Privacy Act, ASC may disclose personal information where:

the use or disclosure of that information is required or authorised by or under an Australian law or a court/tribunal order;
ASC reasonably believes the use or disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body;
ASC reasonably believes the use or disclosure is necessary in taking action about a suspected unlawful activity (or serious misconduct) relating to ASC’s functions or activities; or
to lessen or prevent a serious threat to life, health or safety.

Access to Information

ASC takes reasonable steps to ensure that the personal information it collects and holds is accurate, complete and up-to-date. Further, ASC also takes reasonable steps to ensure that personal information it uses or discloses is accurate, complete, up to date and relevant.

You may request access to the personal information ASC holds about you. Generally, ASC will provide you with access, unless it considers that it is permitted under the Privacy Act (or another relevant Australian law, or a court or tribunal order) to withhold that personal information. If access is refused, ASC will provide you with written reasons for that refusal.

ASC reserves the right to verify the identity of the person making the correction request before it processes the request.

All requests for access to personal information are to be made in writing addressed to ASC’s Privacy Officer at the address shown below. ASC may charge a fee for actioning your request for access to your personal information (but any such fee will be reasonable).

If you satisfy ASC that any personal information it holds about you is inaccurate, incomplete, out-of-date, irrelevant or misleading, ASC will take reasonable steps to amend that information and its records accordingly. Please let us know if any of your personal details change.

It is important that all of the information ASC holds about you is correct and up-to-date.

Security, Destruction/Deletion of Personal Information

As a defence industry organisation, ASC maintains strict security over its physical premises and electronic systems. Access to ASC’s computer systems is limited by user identifiers, passwords and access restricted on a “need to know” basis. Access to all personal information within ASC’s possession and control is strictly controlled.

ASC takes reasonable steps to ensure that all personal information it holds is protected from loss, interference, misuse or unauthorised access, disclosure or modification. ASC also takes reasonable measures to ensure that any personal information (including any unsolicited information) is destroyed or permanently de-identified if no longer needed for any purpose for which it was lawfully collected by ASC, unless ASC is required or authorised by law to retain such information even where such information is no longer needed for the purpose(s) for which it was lawfully collected by ASC.

Cross-border disclosures

ASC may disclose your personal information to an offshore recipient in foreign country (including foreign Governments or offshore defence or security organisations in connection with ASC’s business operations with those countries, or organisations in those countries).

ASC will take reasonable steps in the circumstances to ensure the offshore recipient does not breach the APPs in relation to your personal information, except where:

ASC reasonably believes the offshore recipient is subject to privacy laws in that foreign country consistent with the APPs, and you have access to mechanisms in that country for the enforcement of those privacy laws for the protection of your information;
ASC is legally permitted or required to make that offshore disclosure;
ASC informs you that it will not take reasonable steps in the circumstances to ensure the offshore recipient does not breach the APPs, and you consent to the disclosure; or
the Privacy Act otherwise permits the offshore disclosure.

ASC may also store and process personal information at offshore locations, including cloud database or computing facilities provided by third parties. By providing your personal information to ASC, you consent to your personal information being disclosed offshore for this purpose.

Where ASC does disclose personal information outside Australia, the countries in which those offshore recipients are likely to be located are the United States of America, France, Sweden and Spain.

Job Applicants

If you are a job applicant, and your application is unsuccessful, ASC may retain your personal information for 12 months for the purposes of considering you for other roles within ASC. We are under no obligation to retain your personal information for this purpose and may elect to delete your personal information at any time following an unsuccessful application.

You may request that we delete your personal information from our database at any time, by contacting ASC’s Privacy Officer.

Identifiers

ASC does not adopt as its own identifier of an individual a Commonwealth or State government identifier (e.g. Tax File Number (TFN) or driver’s licence number). Other identifiers such as Australian Business Numbers (ABNs) may be used by ASC for ordinary commercial purposes and for ASC’s compliance with taxation laws such as Goods and Services Tax (GST) (but only for GST purposes).

Website

ASC may use cookies or any other similar program to collect information about you when you access and use ASC’s website at www.asc.com.au. ASC may also use third parties to analyse traffic to ASC’s website which may, in some cases, involve the use of cookies.

ASC cannot guarantee the privacy or security of personal information provided via the ASC website, during the transmission process. Once that personal information is received, ASC then takes take reasonable steps to protect your personal information as outlined in this Policy.

ASC’s website may contain links to other websites. ASC is not responsible for the privacy practices or the use and protection of your personal information on those sites. You should read the privacy policy of any other websites you visit prior to using them.

Further Information about Privacy Law

More information about the Privacy Act and the Australian Privacy Principles is available from the Office of the Australian Information Commissioner at www.oaic.gov.au.

ASC may amend this Policy from time to time to reflect changes in the law, or its business functions or activities. A current version of the Policy will at all times be posted on ASC’s website at www.asc.com.au.

Alternatively, a copy may be requested from ASC’s Privacy Officer at the details below.

Updates

ASC will update this policy from time to time where ASC considers it necessary or where changes to laws or regulations necessitate it.

Contact

All queries about ASC’s dealings with your personal information, its compliance with the Privacy Act or any complaints about an alleged breach by ASC of the Australian Privacy Principles must be made in writing to ASC’s Privacy Officer at the contact details set out below. ASC aims to respond to any such queries (or complaints) at first instance within 30 days of the date of receipt of the query (or complaint).

ASC’s Privacy Officer can be contacted at:

Privacy Officer
ASC Pty Ltd
694 Mersey Road
OSBORNE SA 5017

or on (08) 8348 7280 or by e-mail at [email protected]

If you are not satisfied with ASC’s response to your complaint, you may escalate your complaint to the Office of the Australian Information Commissioner.

The Office of the Australian Information Commissioner can be contacted at:

Office of the Australian Information Commissioner
Phone: 1300 363 992
www.oaic.gov.au