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


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

Every individual within Nature Energy US LLC, (‘Nature Energy Group’ or ‘we’ ) is responsible for protecting personal data 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:


This Privacy Notice provides information about personal data processed 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


As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we process your personal data in relation to specific HR processes . In those instances, such privacy notices will be communicated to you separately, for example the HIPAA privacy notice.


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


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

We process personal data 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 data

We also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership.


We will only process such personal data where:


  • it is necessary for the purposes of complying with employment and social security laws including those specifically for the purposes of ensuring equal employment opportunities as required by US law, covering applicant and employee information such as gender, race/ethnicity, nationality, disability and veterans status;

  • for the establishment, exercise or defense of claims;

  • where necessary for the purposes of providing occupational medical advice and support, 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 (only if required by local law).



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

We process your personal data:


  • in order to satisfy our obligations to comply with local laws and regulations;

  • for legitimate business interests (for example performance management in order to ensure we have qualified and competent personnel or 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.


Please note that as a general principle, Nature Energy Group does not seek or rely on the consent of Nature Energy Group Staff for processing personal data. However, there are limited circumstances when consent is required.


Personal data requested from Nature Energy Group Staff are 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 us 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 processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing 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 process your personal data?
The purposes for which we process your personal data.

We process personal data 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 process your personal data for a secondary purpose where it is closely related, such as:


  • storing, deleting or anonymising your personal data;

  • fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or

  • statistical, historical or scientific research.



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 data 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 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 actual criminal activity, in which case they may be viewed by internal Nature Energy Group investigation teams and externally if legally required or permitted by law enforcement or other government authority.



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 data 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 data collected?

Nature Energy US LLC, whose address is 2550 University Ave. West, Suite 320 S, US-St. Paul, MN 55114, along with your employing company, if different, (or in the case of dependents, the employing company of the Nature Energy Group employee) 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 Energy Group or the Shell group of companies and your external contracting/employing company/agency.


Who will we share the personal data with?

Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:


  • Other companies within the Shell group of companies, including to those which may be located outside of the United States of America;

  • Authorized third party agents, service providers, external auditors and/or subcontractors of Nature Energy Group and/or Shell; and

  • 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

  • As necessary or appropriate to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and

  • Any person to whom Nature Energy Group proposes to transfer any of its rights and/or duties.



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

Where your personal data have been transferred to companies within the Nature Energy Group and/or 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 data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include contractual obligations preventing service providers from selling your personal data and Binding Corporate Rules for transfers among the Shell group. You can find a copy of Shell Binding Corporate Rules at



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

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.


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

All information, including personal data, is managed in line with the Nature Energy Group standards for Information and Records Management and securely deleted thereafter.

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 data 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 data and there is no longer a legitimate business purpose to retain it.



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

We aim to keep our information about you as accurate as possible. Regardless of which State you are resident of you can request:


  • access to your personal data;

  • correction or deletion of your personal data (but only where they are no longer required for a legitimate business purpose);

  • that the processing of your personal data is restricted; and/or

  • that you receive personal data that you have provided to Nature Energy Group, in a structured, digital form to be transmitted to another party if this is technically feasible.


For California residents, you can also request:


  • limit to the disclosure or use of your sensitive personal information for purposes other than exempted purposes, if collected;

  • that you not be retaliated against for exercising your rights.

  • Nature Energy Group does not sell or share your personal information. 

  • Nature Energy Group does not sell or share your personal information, whether or not for monetary or other valuable consideration.


To exercise any of the above rights, please contact If you are a contractor, you should speak with your external contracting/employing company/agency.


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

If you have any questions, complaints, or comments to Nature Energy Group's processing of your personal data, please contact the data protection coordinator on


You can also contact or 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.


Without prejudice to any rights you may have in line with local law you have the right to lodge a complaint with the Dutch Data Protection Authority whose address is Autoriteit Persoonsgegevens, PO Box 93374, 2509. Please visit 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.