Privacy Notice - Nature Energy Group Employee, Contractor and Dependents' Personal Information Canada

Privacy Notice - Nature Energy Group Employee, Contractor and Dependents' Personal Information

What does this Privacy Notice cover?
This notice sets out what personal information we collect, for what purposes and your rights in this respect.

Every individual within Nature Energy Canada Inc. ("Nature Energy Group", “we”) is responsible for protecting personal information about each other as well as that of our customers, business partners and suppliers. Nature Energy Group is part of the Shell Group of companies. You can find further information about how the Shell group protects personal data here: https://www.shell.ca/en_ca/privacy.html.

This Privacy Notice provides information about personal information collected, used and disclosed by Nature Energy Group in relation to individuals who are or were employees, interns or individual contractors as well as dependents of Nature Energy Group employees (‘Nature Energy Group Staff’).

For individuals who apply to work for Nature Energy Group, or who attend a recruitment event or undertake an assessment please refer to the Privacy Notice – Nature Energy Group Recruitment at https://nature-energy.com/privacy-notice-recruitment-ca.

As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we collect, use and disclose your personal information in relation to specific HR processes. In those instances, such privacy notices will be communicated to you separately.

This Privacy Notice explains what personal information is collected about you, why we are collecting your personal information and for which purposes, how long we hold your personal information for, how to access and update your personal information, as well as the options you have regarding your personal information and where to go for further information.

What personal information do we collect about you? Collection of information
The categories of personal information we collect about you.

We collect personal information necessary to manage the employment relationship, to engage contractors and interns and to provide benefits to certain dependents of Nature Energy Group employees.

This includes personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country/ies you are engaged in, as well as any other information necessary for managing the employment relationship, for engaging contractors and for providing benefits to certain dependents of Nature Energy Group employees (such as those dependents who accompany a Nature Energy Group employee while on an expatriate assignment).

Sensitive personal information

In some circumstances some special categories of personal information (’sensitive personal information’) such as information relating to an individual’s health. We will only process such personal information where it is necessary for the purposes of complying with employment and social security laws, for the establishment, exercise or defense of claims or where necessary for the purposes of occupational health/fitness for duty, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health or where the individual has provided their explicit consent.

Why do we collect your personal information?
We will only collect your personal information where we have a legal basis to do so.

We collect your personal information:

to manage all aspects of the employment relationship
to satisfy our obligations to comply with local laws and regulations;
for health, safety and security purposes;
to ensure that only authorised personnel can access certain sites or assets;
litigation and defense of claims; or
where we have your explicit consent.

In accordance with applicable laws, Nature Energy Group may collect, use or disclose employee personal information without consent, but with notice to you. In circumstances where consent is required, Nature Energy Group will obtain your consent before collecting, using or disclosing employee personal information.

Personal information of Nature Energy Group Staff required by Nature Energy Group is the minimum required in order to fulfil legal and/or contractual requirements and to provide opportunities to take part in programs or to provide a benefit. Failure to provide Nature Energy Group with the information requested may negatively affect your ability to remain in employment, internship or engagement as a contractor or from participating in a program or receiving a benefit.

In those cases where collection is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the collection prior to the withdrawal of consent. Withdrawal of consent may however impact your ability to remain employed or otherwise engaged or from participating in a program or receiving a benefit.

For what purposes do we collect your personal information?
The purposes for which we collect your personal information.

We use personal information covered by this Privacy Notice for the following purposes:

Human Resources, personnel management, business process execution, internal management, management reporting, organisational analysis and development - including budgetary, financial and organisational planning, administration, compensation, performance management;
Health, safety and security - including protection of Nature Energy Group Staff’s life or health, occupational health and safety, protection of Nature Energy Group assets and authentication of Nature Energy Group Staff status and access rights; or
Legal and/or regulatory compliance - including compliance with legal or regulatory requirements.

We may also use your personal information for a secondary purpose where it is closely related, such as:

fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
statistical, historical or scientific research.

Monitoring

All activities on Nature Energy Group IT equipment and/or when connected to the Nature Energy Group or Shell IT network may be monitored for legitimate business purposes.

All Nature Energy Group Staff receive an access badge which allows Nature Energy Group to record the date, time and access points made by individuals within Nature Energy Group premises and assets. The information from the access and security systems are used:

for health, safety and security purposes, to prevent fraud and specifically the protection of Nature Energy Group assets, Nature Energy Group Staff and visitors to Nature Energy Group premises;
to comply with legal and regulatory requirements, specifically where there is a local legal requirement to provide information to government/regulatory authorities;
to monitor (on an aggregated basis) the number of individuals entering and working in a Nature Energy Group premise for human resources and real estate planning; and
in the case of contractors only (not Nature Energy Group employees) the date and time of their entry and exit of Nature Energy Group premises is used for the purposes of financial management and control.

Most of our premises and assets are equipped with surveillance cameras (CCTV). Where Nature Energy Group-administered surveillance cameras are used they will be identified. Surveillance cameras are used for health, safety and security specifically the protection of Nature Energy Group assets, Nature Energy Group staff and visitors to Nature Energy Group premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or otherwise for legal preservation, in which case they may be viewed by internal Nature Energy Group investigation teams or other Nature Energy Group Staff on a need-to-know basis, and externally if legally required or permitted by law or other government authority.

Screening

In order to comply with legal and regulatory obligations, to protect Shell Group’s assets and employees/contractors and specifically to ensure that the Shell Group can comply with trade control, anti-money laundering and/or bribery and corruption laws and other regulatory requirements, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available or government issued sanctions lists and is compared with information held about you by Nature Energy Group.

Any personal information collected through the screening will not involve profiling or automated decision-making regarding suitability for continued employment, internship or engagement as a contractor.

Who is responsible for any personal information collected?

Nature Energy Canada Inc. with registered address at 5005 Boul. Lapinière #1020, CA-Brossard, (Québec) J4Z 3H8, Canada is responsible for the collection, use, disclosure and safeguarding of your personal information, either solely or jointly with its affiliates within the Shell group of companies.

In the case of individual contractors, the company within the Nature Energy Group or the Shell Group that has contracted your services solely or jointly with its affiliates within Nature Group or the Shell group of companies and your external contracting/employing company/agency.

Who will we share the personal information with?

Your personal information is exclusively collected for the purposes referred to above and will only be accessed within Nature Energy Group on a strict need to know basis. We may disclose your personal information to organizations outside of Nature Energy Group as follows:

Other companies within the Shell group of companies, including to those which may be located outside of your location;
Authorized third party agents, service providers, external auditors and/or subcontractors of Nature Energy Group and/or Shell;
A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Nature Energy Group and/or Shell company/companies is subject to or as permitted by applicable law; or
Any person to whom Nature Energy Group proposes to transfer any of its rights and/or duties.
As otherwise permitted by applicable laws

Transfers of your personal information to other countries
Your personal information may be transferred outside of your country, subject to appropriate safeguards.

Where your personal information has been transferred to companies within the Nature Energy Group and Shell group and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal information is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal information. These measures include Binding Corporate Rules for transfers among the Shell group and for Shell companies in the EU, European Commission approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements. You can find a copy of Shell Binding Corporate Rules at www.shell.ca/en_ca/privacy.html or by contacting privacy-office-SI@shell.com.

Security of your personal information
Nature Energy Group is committed to safeguarding your personal information.

We have implemented technical, administrative and physical safeguards with the objective of protecting your privacy from unauthorized access and improper use and will update these measures as new technology becomes available, as appropriate.

How long do we hold your personal information for?
Nature Energy Group only holds your personal information for a defined period of time.

All information, including personal information, is managed in line with the Nature Energy Group standards for Information and Records Management and securely deleted once no longer required for a legitimate business purpose or for a legal/regulatory purpose.

With some exceptions required to comply with local legal requirements:

Information contained within personnel files is held for no longer than 10 years once your employment has terminated;
information relating to retirement benefits are held for no longer than 99 years from the commencement of employment;
any personal information gathered as part of the screening against publicly available or government issued sanctions lists and media sources are held for no longer than 15 years after they were first gathered;
the names, date, time and access points for all individuals entering Nature Energy Group premises are held for 3 years from each access;
where an individual has been dismissed or had their contract terminated due to serious misconduct, including breaching the Nature Energy Group Life Saving Rules or breaching the Nature Energy Group Code of Conduct that information is held for up to 30 years post termination.

In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where you object to the processing of the personal information and there is no longer a legitimate business purpose to retain it.

Your rights in relation to your personal information
Your rights and how to exercise them.

We aim to keep our information about you as accurate as possible. You can request:

access to your personal information;
correction or deletion of your personal information (but only where they are no longer required for a legitimate business purpose); and/or
that the collection, use or disclosure of your personal information is restricted (where permitted under applicable law);

To make a request, please contact legal@nature-energy.com. If you are a contractor, you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact legal@nature-energy.com.

Who can you contact if you have a query, concern or compliant about your personal information?

If you have any issues, queries or complaints, regarding the processing of your personal information, please contact the data protection coordinator on legal@nature-energy.com.

You may also contact the Shell Group Chief Privacy Officer at Shell International B.V. The Hague, The Netherlands - Trade Register, No. 27155369 Correspondence: PO Box 162, 2501 AN, The Hague.

If you are unsatisfied with the handling of your personal information by Nature Energy Group as part of the Shell group, then you have the right to lodge a complaint to the provincial Office of the Privacy Commissioner or the Dutch Data Protection Authority whose address is Autoriteit Persoonsgegevens, PO Box 93374, 2509 The Hague, The Netherlands. Please visit https://autoriteitpersoonsgegevens.nl/en for more information.

Changes to this Privacy Notice
This Privacy Notice is updated over time.

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes. This Privacy Notice was last updated in April 2023.