Effective: 1 July 2017
The Toll Way is the underpinning foundation of our core beliefs and values which guides our decisions and actions. Toll Holdings Limited and the Toll group of companies (Toll) respects the privacy of every individual and is committed to protecting the personal data it collects in accordance with the principles set out in this Policy.
Unless otherwise stated, Toll Holdings Limited is the data controller for personal data we collect from you or you provide to us.
In this Policy, “personal data” means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person’s physical, physiological, mental, economic, cultural or social identity or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably by ascertained from the information or opinion. Personal data includes “sensitive personal data” (which means information or an opinion about an individual's racial or ethnic origin, political opinion, membership of a political association or trade union, religious ideological or ethical beliefs, sexual life, health, political or union related views or activities and the commission or alleged commission of offences and related proceedings including administrative or criminal sanctions).
"Processing" is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
Personal Data Collection
To enable us to fulfil our responsibilities as an integrated provider of logistics and, in the case of our Toll People and Toll Transitions businesses, our responsibilities as a supplier of recruiting and relocation services, Toll collects personal data about its employees, clients, suppliers, sub-contractors and others with whom it deals, to enable Toll to effectively conduct its businesses. This personal data must be sufficiently detailed for Toll to effectively conduct its businesses.
You are not required to supply any of the personal data that we may request. However, if the personal data we request isnot provided, we may not be able to provide services in the most effective or efficient manner, or at all, or you may not be able to be an employee of or service provider to Toll.
We only collect personal data for our business purposes. For example, we collect information that is necessary for the establishment and maintenance of records for our employees, clients, suppliers of goods and services, sub-contractors and others with whom we conduct business in order for Toll to work effectively with them.
Depending on the business purpose, the personal data we collect may include:
- Name, address and contact details (including phone number and email)
- Information relating to previous services provided by Toll, or
- Employment or financial information
We generally collect personal data directly from you in person, in writing, by telephone, email or via our websites. For example, we may collect information when you ask us to provide services to you.
We may also collect personal data via third parties in some cases. For example, if we deliver a service to your organisation (such as a relocation service through Toll's specialist relocations business, Toll Transitions), we may collect personal data from the organisation purchasing the service (for example, in the case of relocation services, your destination address).
We will only collect personal data to the extent that it is required for the specific purposes set out in this policy or notified to you at the time of collection.
Where Toll collects data on its employees, additional requirements may apply. Please contact the data controller or HR Manager in the jurisdiction where you are employed for additional information in relation to employee information.
Collection of Information via our Websites
When you visit one of our websites, information about your computer or web device is automatically recorded by our website. This includes your IP address and associated domain name (e.g. yourcompany.com), the date and time of your visit to our site, the pages you accessed or downloaded, the address of the last site you visited, your operating system and the type of browser you used. This information may be collected by us or by a third party service provider on our behalf. This information is collected for statistical and system administration purposes, and to improve our web based services. It does not readily identify individuals, and we will not attempt to identify individuals from the records our server generates unless it is necessary to do so for law enforcement purposes.
We may also use “cookies” to assign your device a user ID. A cookie is a small piece of information that is sent to your browser and stored on your computer's hard drive. Cookies contain information that allows us to identify your device, understand your use of our websites and set your preferences for future visits. We may use this information to determine whether or not to display standard content. You can configure your browser to notify you when you receive a cookie, or disable cookies altogether. Please consult the terms and conditions of use for this website for further information about use of these cookies and how to enable them and disable them. These cookies expire when your browser window is closed.
Please note that some of the cookies we use are essential for our websites to operate, and that if you disable cookies altogether you will not be able to use all parts of our website.
Use and Disclosure of Personal Data
Your data will be processed fairly, lawfully and in an appropriate way.
We will only use personal data for the purpose for which it was collected or for related purposes permitted by law. These uses include (but are not limited to) those set out below.
Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to notify you about changes to our service; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer; and
- to provide you, or permit selected third parties to provide you, with information about goods and services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS or other messaging service or social media platform) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data.
Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Toll uses personal data to provide, manage and administer the goods and services it provides. In the normal course of our business operations we may disclose personal data to related bodies corporate and statutory entities authorised to access the information.
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- Selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you
Personal data collected is also used to facilitate distribution of corporate communications such as our financial results and other information that is relevant to the promotion or reporting of our business activities. Personal information may also be disclosed to our contract service providers, including but not limited to customer service staff, consultants, advisers, IT and internet service providers.
We also disclose personal data to third parties in some cases. For example, in connection with our Toll People business, we disclose the personal data of candidates to potential employers. We also retain the personal data of candidates who wish to be considered for future positions as and when they become available.
In addition, we will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Toll, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Toll reserves the right to transfer, and you consent to Toll transferring, your personal data to another entity in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with the principles described in this Policy.
Access and Correction
We try to ensure that personal data we hold is adequate, relevant, accurate, complete and up to date. You can contact the data controller (see below) if you would like details of personal data which may be held about you or if you wish to correct any personal information held. You have the right to access the personal data we hold about you.
To ensure the integrity and safety of personal data, Toll only discloses the personal data it holds to the individual concerned, their legally authorised representative, or to fulfil legal or regulatory requirements. Toll may also disclose personal data to its advisers and other parties in connection with the present and future conduct of its business. In some circumstances we may charge a fee, but we will not charge you for lodging a request for access. To ascertain what fee we may charge, please contact the data controller in the jurisdiction where you are located (see below).
We will keep personal data for as long as is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. Toll will destroy any personal data we hold about you when it is no longer required and we are legally able to do so.
Storage and Security of Personal Data
Personal data is principally held in electronic databases maintained within Toll’s computer network. Toll maintains appropriate administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.
We ask you not to share a password with anyone. Your personal data will be processed in accordance with our data security policies. We will maintain data security by protecting the confidentiality, integrity and availability of the personal data we hold.
Transfer of Personal Data Outside the Country in which it was Collected
Some organisations to which we disclose personal data may be located, or may store the personal data on computer servers, outside the country in which the personal data was collected. Pursuant to any applicable privacy / data protection laws (including, without limitation, the European Data Protection Directive 1995 and any national laws implementing the European Data Protection Directive 1995), your personal data may be disclosed, processed and transferred by Toll on a worldwide basis for the purposes of providing our services. Personal data may be disclosed or transferred to agents or third parties authorised to act on our behalf for the purposes of providing the services.
Some countries may not provide the same level of protection for your personal information as the country in which your personal data was collected. Please note, however, that Toll maintains appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use and where required, Toll will enter into agreements with the recipients of the personal data to ensure that the recipient abides by Toll's obligations under any applicable privacy / data protection laws.
Use of our Websites
Our website may contain links to other websites that are not owned, operated or endorsed by us. We are not responsible for the privacy practices of those websites, or for the content, product or services provided by, or contained on, those websites.
Breaches of this Policy
All suspected breaches will be investigated and appropriate disciplinary and remedial action taken. Employees who do not strictly comply with this Policy will face disciplinary action, including counselling, formal warnings and dismissal.
We may amend this Policy from time to time. Updated versions of this Policy will be placed on our website (http://www.tollgroup.com). If you are a user of our website, by accepting our terms and conditions for use of that website, or you are a user of our services, you consent to us collecting, using, disclosing and handling personal data as described in this Policy, and agree to be bound by the obligations it imposes on you. As the Policy may be amended from time to time, you should review it regularly.
If you would like to gain access to your personal data, or if you wish to voice your concern on any matter to do with either this policy or use of your personal data, please contact the relevant data controller listed below: