Privacy Policy
1. Purpose
This Policy reflects Northern Minerals Limited’s (ABN 61 119 966 353) commitment to protecting individuals’ personal information that we may collect, store, use, disclose and otherwise manage.
This Policy applies to Northern Minerals Limited and all members of the Northern Minerals Limited company group (including all Company offices, operations and sites) in connection with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) (together, the Privacy Act).
In this Policy, “NTU”, “Company”, “we”, “us” or “our” means Northern Minerals Limited and each member of the Northern Minerals Limited company group. References to “you” or “your” means to individuals whose personal information is collected by NTU.
2. Personal Information
“Personal Information” means information or an opinion (including information or an opinion forming part of a database) about an individual or an individual who is reasonably identifiable (whether the information or opinion is true or not or recorded in material form or not).
The Personal Information we may collect depends on our relationship with you. NTU collects Personal Information when it is reasonably necessary for the purposes of, or in connection with, our business operations and to comply with applicable laws. The following are examples of Personal Information that NTU may collect:
• Name, email / postal address, phone number and/or date of birth
• Comments made by you in the contact us form on our Company website that identifies you or someone else • Gender
• Your organisation and your role
• Health monitoring and medical information (which medical information may in particular be collected in connection with health and safety requirements relating to access to our premises or sites)
• Billing and payment information • Identity verification e.g. scans of driver’s licences and passports
We may also collect, monitor and use certain information about your usage of our Website, online services, social media pages and IT resources, including:
• the type of device you use;
• your device’s unique ID;
• the IP address of your device;
• browser user agent string;
• the pages and content accessed, and the time, date and duration of access; and
• any other diagnostic data related to your device.
For staff and job applicants, we collect further information which may in addition to the above, include:
• demographic information, such as age, date of birth, nationality, and gender;
• job application, work history and other CV information;
• background checks including criminal record checks;
• referee and emergency contact details;
• education and training records;
• citizenship, visa and work eligibility information;
• information that helps us identify and manage conflicts of interest, such as financial and personal interests (including those of family members);
• information about assessments, conduct and performance;
• health records (e.g. in connection with health checks, drug and alcohol checks, sick leave and roles requiring health monitoring); and
• payment, leave, taxation and superannuation details.
Under the Privacy Act, certain types of information are classified as sensitive information and require a higher level of protection. Sensitive information includes information about an individuals racial or ethnic origin, political opinions or membership of a political association, religious or philosophical beliefs or affiliations, trade-union membership, health, or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences. NTU will only collect your sensitive information where you provide your consent (generally express consent) or where the collection is otherwise permitted or required by law. NTU will handle such information in accordance with applicable Australian Privacy Principles.
3. Methods of Collection
Where reasonable and practical, we will collect your personal information from you directly. However, there are circumstances where we need to collect your personal information and can only reasonably or practically do so by collecting it from another source.
Broadly speaking, we collect Personal Information in the following ways:
Information that you provide voluntarily
At times, NTU may ask you to voluntarily supply Personal Information. For example, you may provide Personal Information when submitting an enquiry through, or to, our email address provided on our Website, or any other personal communications you send directly to us or our communication platforms, including social media.
In addition, we may collect Personal Information during the course of our interactions with you, including:
• when you interact with us through verbal and written communication;
• when you use any of our services, either as a prospective customer or a supplier, or enter into an agreement with us;
• when you seek employment or are employed or otherwise engaged by us;
• when you invest with us;
• when you visit our work sites or attend our events;
• when you apply for employment or volunteer opportunities with us;
• from records of activities and communications, including monitoring records like CCTV, site access, telephone records and use of our Website and IT resources; and
• NTU may monitor the use of its systems, sites and facilities, including through CCTV, access systems, vehicle monitoring systems, and information technology monitoring tools, for safety, security, compliance and operational purposes, in accordance with appliable laws; and
• through processes such as analysis, commentary, interpretation, reporting and review.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. This information is set out in section 2 above. Please see section 5 for further information on the use of cookies.
Information that we obtain from third party sources
In some cases, we may collect Personal Information about you from publicly available sources or from a third party, such as through your representatives, contractors who provide services to us, or other third parties who are entitled to share your information. In addition, where you have expressed an interest in career opportunities with NTU, we may obtain Personal Information provided to us by HR practitioners, hiring managers and recruitment advisors. We may also collect certain health information from medical practitioners or providers of medical services where we have a reasonable need for that health information for employment, safety and regulatory purposes.
4. Use and Disclosure
4.1 Use of Personal Information
We will only use Personal Information for the primary purpose(s) for which it was collected, for any secondary purpose or any other specific purpose to the extent permitted under the Privacy Act and for any other purpose that you consent to, including to:
• enable you to access and use our services and our Website;
• enable any employment or contracting arrangement with you;
• communicate with you, including processing and responding to enquiries;
• develop, manage, administer, evaluate and improve our products and services or organisational processes, including research, planning, service development, security and risk management;
• verify your identity and information; • service and administer relationships with employees, shareholders, contractors and customers;
• maintain and update our records;
• manage site access, workplace health and safety obligations, emergency response requirements, fitness for work programs and compliance with mining and environmental legislation;
• administer training, competency and workforce management processes;
• provide ongoing information about our activities where you have expressed an interest in such information (subject to our legal obligations);
• for security purposes such as monitoring and detection to protect NTU customers, staff, systems, infrastructure, information and other property;
• facilitate acquisitions and potential acquisitions of or by our business, including any related transitional and business integration activities;
• manage claims, complaints and investigations, and prevent, detect and deal with fraud, misconduct and unlawful activity, and otherwise defend our legal rights;
• where applicable, use automated systems and analytical tools to support activities such as cyber security monitoring, recruitment administration, access control management, compliance monitoring and operational administration. Where automated tools are used, final decisions affecting individuals will, where appropriate, be reviewed by authorised personnel and reasonable steps will be taken to ensure transparency, fairness and accuracy;
• to comply with regulatory and legal requirements – note we are required or authorised by various laws to collect personal information, eg under the Superannuation Guarantee (Administration) Act 1992 (Cth), Income Tax Assessment Acts and other tax laws, Corporations Act 2001 (Cth), occupational health and safety acts, public health acts, and similar.
4.2 Disclosure of Personal Information
We may disclose and share personal information with third parties, including its service providers (which includes our IT service providers), subcontractors, employees, insurers and professional advisors, as is reasonably necessary for the conduct of our business, or for other purposes set out in this Policy. We will not disclose your personal information in any circumstance other than those set out in this section or where any other legal obligation or exemption exists.
Overseas disclosure of Personal Information
We may disclose your Personal Information to third parties located in overseas countries such as America, Germany, United Kingdom, Canada, France, China. Where we disclose your Personal Information to overseas recipients, we are required to take reasonable endeavours to ensure that third party recipients comply with the APPs unless:
• you have given us your consent to disclose personal information to that third party without ensuring their compliance with the APPs; or
• we believe that:
• the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; and
• we can enforce the law or binding scheme; or
• the disclosure is required or authorised by an Australian law or court/tribunal order.
You acknowledge that:
• these overseas third party recipients may not be bound by the Privacy Act;
• we cannot control the acts or omissions of third parties; and
• there may be limitations in the application of Australian privacy protections to overseas recipients.
5. Company Website
5.1 Cookies
If you use our Website, some of the personal information referred to in section 2 may be collected through the use of cookies. A cookie is a small amount of information which is transferred to the hard drive of your computer when you visit websites. It can identify your web browser, but generally does not
identify you. Cookies provide us with information about your computer’s IP address, the date and time of your visit, and the resources or information you have accessed. We use cookies to monitor usage of our online resources and assist us in tailoring our services and making your visits easier, more productive, and more efficient. Any Personal Information obtained through the use of cookies will only be used for the purposes set out in this Policy. You can disable your web browser from accepting cookies. If you do, you can still access our Website, but not all functionality may be available.
5.2 Links
Our Website may contain links to other websites operated by third parties. If you follow a hyperlink to another third-party website or external content, the privacy policy (if any) of that third party website or host of the external content will apply. We make no representations or warranties in relation to the privacy or other practices of any third-party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website.
6. Data Security, Protection and Retention
The security of your Personal Information is important to us.
We endeavour to take reasonable steps, including implementing appropriate technical and organisational measures, to protect Personal Information we hold directly, and through our service providers that hold Personal Information on our behalf, secure and protected from loss, misuse or unauthorised access, modification, or disclosure.
It should be noted that the internet is not a secure environment, and no computer system is perfectly secure. Although all care is taken, NTU cannot guarantee the security of information provided to us. This means there may always be a risk that your Personal Information may be accessed or used without authorisation.
We may hold your Personal Information in electronic or hard copy – we use a range of physical, electronic, and procedural safeguards to protect your Personal Information from unauthorised persons and viruses, including the use of technologies such as firewalls, intrusion detection systems, and virus scanning tools. We review these safeguards from time to time and as required to address new and emerging security threats. We also train our people on privacy matters as appropriate and seek to limit access to Personal Information to those individuals who need to know the information.
Where personal information is no longer required for the purpose for which it was collected, NTU will take reasonable steps to destroy or permanently de-identify the information, unless this information is required by legal or compliance matters or for another purpose permitted under applicable laws.
If we believe that there has been a data breach that constitutes an ‘eligible data breach’ under the Privacy Act, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required and keep in contact with you about the nature of the breach, the steps we are taking, and what you can do to reduce the impacts to your privacy.
7. Anonymity, access and amendment of Personal Information
Where practicable, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us. However, you may not be able to access or purchase the full range of our products and services without providing such information.
NTU aims to ensure that all Personal Information is accurate, complete and up to date and is committed to providing an individual with access to the personal information that NTU collects about that individual, wherever possible.
If you believe the Personal Information held by NTU is incorrect or inaccurate or would like access to your Personal Information, then you may send a request to the Privacy Officer at privacy@northernminerals.com.au. We may need to verify your identity first.
We will endeavour to respond to a request for access or to amend information within thirty (30) business days of receiving the request , or such other period as required by applicable law.
In respect of access requests, we may charge you a reasonable administration fee to provide the access, to the extent permitted by law.
In certain circumstances as set out in the Privacy Act, we have the right to refuse individuals’ access or amendment of their information. Where we refuse such access or amendment, we will notify you of our decision and reason for doing so, as well as details of complaint mechanisms.
NTU may, in some circumstances, allow for Personal Information to be de-identified, at the request of the individual. However, where this information is required for the purpose of conducting our business or legal / regulatory compliance, the individual’s request may not be able to be met.
8. Complaints
If you have any queries, feedback or complaints with regard to our collection, use or management of your personal information, please contact:
A: The Privacy Officer, Northern Minerals Limited Ground Floor, 40 Kings Park Road, West Perth, Western Australia, 6005
E: privacy@northernminerals.com.au
T: +61 (8) 9481 2344
We will respond to your complaint as soon as possible and will try to resolve the complaint within thirty (30) business days.
Where an individual believes, or is concerned, that the matter has not been handled appropriately or considers that a complaint has not been addressed, the individual is able to lodge a complaint with the OAIC via its website at https://www.oaic.gov.au/, by emailing enquiries@oaic.gov.au or calling 1300 363 992.
9. Changes to Privacy Policy We will review this Policy periodically and update it from time to time, or when relevant legislative or regulatory changes occur. Please visit our Website to obtain a copy of the latest version of this Policy at any time. Where we are required by applicable law, we will make you aware of any material changes by posting a notification on the Privacy section of our Website.
This Policy was last reviewed and updated on 30th July 2026.