Kumul Petroleum Holdings Limited (KPHL), the National Petroleum & Energy Company of PNG, is committed to protecting the privacy and security of personal information entrusted to us by our employees, contractors, partners, stakeholders, and community members.

This Privacy Statement outlines how KPHL collects, uses, stores, and protects personal information in compliance with applicable laws and regulations, including the Papua New Guinea Cybercrime Code Act 2016 and other relevant legislation.

1. Scope of This Privacy Statement

This Privacy Statement applies to all personal information collected by KPHL in the course of its operations, including through its website, business interactions, employment processes, and community engagement activities. Personal information refers to any data that can identify an individual, such as names, contact details, or employment records.

2. Information KPHL Collects

KPHL may collect the following types of personal information:

  • Identity and Contact Information: Name, address, phone number, email address, and other contact details.
  • Professional Information: Employment history, qualifications, and job-related data for employees, contractors, or business partners.
  • Community Engagement Data: Information provided during consultations, community programs, or stakeholder engagements.
  • Website Usage Data: Information collected through cookies or analytics tools when you visit our website, such as IP addresses, browser type, and browsing behaviour.
  • Financial Information: Payment or banking details for vendors, contractors, or partners, where applicable.

3. How We Collect Information

KPHL collects personal information through:

  • Direct interactions, such as forms, contracts, or communications with staff.
  • Automated technologies, such as cookies and analytics tools on the website.
  • Third parties, such as recruitment agencies, government bodies, or business partners, with your consent or as permitted by law.

4. How We Use Information

KPHL uses personal information for legitimate business purposes, including:

  • Managing employment and contractor relationships, including payroll and performance evaluations.
  • Facilitating business operations, such as vendor payments and project management.
  • Engaging with communities and stakeholders for projects, social responsibility programs, and consultation processes.
  • Ensuring compliance with legal and regulatory obligations in Papua New Guinea.
  • Improving website and services through analytics and user feedback.
  • Protecting the security and integrity of our operations, including cybersecurity measures.

5. Legal Basis for Processing

KPHL processes personal information based on:

  • Consent: Where explicit consent for specific purposes has been provided.
  • Contractual Obligations: To fulfill contracts with employees, contractors, or partners.
  • Legal Obligations: To comply with PNG laws and regulations, e.g. tax or labour requirements.
  • Legitimate Interests: For business operations, provided these do not override rights and freedoms.

6. Sharing Your Information

KPHL may share personal information with:

  • Service Providers: Trusted third parties, such as IT providers or auditors, under strict confidentiality agreements.
  • Government Authorities: As required by PNG laws or regulations, such as for tax or compliance purposes.
  • Business Partners: For collaborative projects, with appropriate safeguards in place. KPHL do not sell or disclose personal information for commercial purposes unrelated to its operations.

7. Data Security

KPHL implements robust technical and organisational measures to protect personal information, including encryption, access controls, and regular security assessments. KPHL strives to prevent unauthorised access, loss, or misuse of data. In the event of a data breach, KPHL will notify affected individuals and relevant authorities as required by law.

8. Data Retention

KPHL retains personal information only for as long as necessary to fulfill the purposes outlined in this statement or as required by law. For example:

  • Employment records may be retained for the duration of employment and as required by PNG labour laws.
  • Community engagement data may be kept for the duration of a project or as needed for reporting. When no longer needed, personal information is securely deleted or anonymised.

9. Your Rights

As a data subject, employees have the following rights, subject to applicable laws, to:

  • Access: Request access to the personal information KPHL holds about them.
  • Correction: Request correction of inaccurate or incomplete information.
  • Deletion: Request deletion of personal information, where permitted by law.
  • Objection: Object to the processing of information for specific purposes.
  • Restriction: Request restriction of processing in certain circumstances. To exercise these rights, please contact our Data Protection Officer (see Section 12).

10. International Data Transfers

As a company operating in PNG, most of KPHL’s data processing occurs domestically. However, if personal information is transferred internationally (e.g., to cloud service providers), KPHL ensures appropriate safeguards, such as contractual agreements, to protect data in accordance with PNG laws.

11. Cookies and Website Analytics

The KPHL website uses cookies to enhance user experience and analyse site performance. Employees can manage cookie preferences through browser settings. For more details, please refer to the Cookie Policy on the KPHL website.

12. Contact Us

For questions, concerns, or to exercise rights, please contact our Data Protection Officer:

  • Email: privacy@kumulpetroleum.com
  • Phone: +675 320 2250
  • Address: Kumul Petroleum Holdings Limited, Level 6, Kina Bank Building, Port Moresby, Papua New Guinea

13. Changes to This Privacy Statement

KPHL may update this Privacy Statement to reflect changes in practices or legal requirements. Any updates will be posted on the KPHL website with an updated effective date. KPHL encourages you to review this statement periodically.

Kumul Petroleum Holdings Limited is dedicated to responsible data stewardship, ensuring personal information is handled with care and respect.