Privacy Notice

Personal data includes any information relating to an identified or identifiable living person. KAZ Minerals processes personal data for numerous purposes and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose may differ. When collecting and using personal data, our policy is to be transparent about why and how we process personal data

Security

We take seriously the security of all the data we hold. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so and when we do so, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards. KAZ Minerals does not sell or otherwise release personal data to third parties for the purpose of allowing them to market their products and services.

We may transfer personal data within the KAZ Minerals Group and this may involve transferring data outside the European Union (“EU”). We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, including the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights. In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 6 years.

Personal data held by us may be transferred to:

• Other KAZ Minerals companies
  We may share personal data with other KAZ Minerals subsidiary and associated companies where necessary for administrative purposes and to provide products to our customers.
• Third party organisations that provide applications, data processing or IT services to us
  We use third parties to support us and to help provide, run and manage our IT systems and website. For example, providers of information technology, cloud-based software as a service providers, mailing list services, website hosting and management, data back-up, security and storage services. The servers powering and facilitating the cloud infrastructure are located in a secure data centre in the UK and personal data may be stored in any one of them.
  
• Third party organisations that otherwise assist us in providing goods, services, administration or information.
• Auditors and other professional advisers.
• Law enforcement or other government and regulatory authorities or to other third parties as required by, and in accordance with, applicable law or regulation.

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and we include further information about the rights that individuals have and how to exercise them below.

Access to personal data

You have a right of access to your personal data held by us as a data controller. This right may be exercised by emailing us at dataprotectionleader@kazminerals.com. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Amendment of personal data

To update personal data submitted to us, or to request erasure or deletion of your personal data, you may email us at dataprotectionleader@kazminerals.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications for which you registered. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at dataprotectionleader@kazminerals.com or, to stop receiving KAZ Minerals email alerts, please click on the ‘unsubscribe’ link in the relevant email received from us.

Complaints

If you need to complain about our use of personal data, please send an email with the details of your complaint to dataprotectionleader@kazminerals.com. You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

Business contacts (including customers, suppliers and subcontractors)

Collection of personal data

KAZ Minerals processes personal data about business contacts (including existing and potential KAZ Minerals customers, suppliers, subcontractors and/or individuals associated with them) as part of its contracting procedures. Personal data relating to business contacts will include name, employer name, contact title, phone, email and other business contact details.

Use of personal data

Personal data relating to business contacts may be visible to and used by KAZ Minerals employees and may be used for the following purposes:

• Administering, managing and developing our businesses;
• Providing information about us;
• Making contact information available to our employees;
• Describing the nature of a contact’s relationship with us;
• Performing analytics;
• Receiving services;
• Providing products to customers; and
• Complying with any requirement of law, regulation or relevant professional body.

Others who get in touch with us

We collect personal data when an individual contacts us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication). In these cases, the individual is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication.

Registered shareholders

We collect and process personal data provided by shareholders, or on their behalf, which relates to individuals as shareholders, and includes information which the shareholder or their agent may provide on application forms, in letters, via electronic messages or by telephone. The type of personal data processed by us may include: your name, address, telephone number, email address, the votes you cast and the shareholder reference number attributed to you by the registrar.

We may store, use and process your personal data in order to:

• compile and update our records to keep them up to date;
• fulfil our legal obligations;
• investigate or prevent fraud or other crimes;
• process the exercise of shareholder rights;
• contact shareholders with information and related communications; and
• provide services of benefit to shareholders.

We will hold your personal data for as long as is necessary for the relevant activity or service and, if necessary, your information may also be disclosed and processed for these purposes after you have sold your shareholding.

Disclosure

We may transfer or disclose your personal data to the following recipients or categories of recipients:

• Computershare Investor Services PLC, as KAZ Minerals’ registrar;
• any third party at your request or with your consent;
• our suppliers, subsidiaries, service providers, professional advisers, agents and auditors;
• local or foreign regulators, government authorities, law enforcement authorities, courts, tribunals and arbitrators or other judicial committees, if the law requires or permits disclosure, or if there is a duty to the public to reveal it, the FCA, the London Stock Exchange or any other relevant regulatory authority or exchange in the UK or overseas;
• any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of the Company share register; and
• any other person that requires access to or receipt of your personal data in connection with or as a result of any agreement we may have with or concerning you, or our arrangements with you.

Recruitment applicants

As part of any recruitment process, KAZ Minerals collects and processes personal data relating to job applicants. This may include:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlements;
• whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

We collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. We will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

Purpose of processing personal data

KAZ Minerals has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims. We may process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. We may process other special categories of data, such as information about ethnic origin, sexual orientation, religion or belief for equal opportunities monitoring purposes. For some roles we are obliged to seek information about criminal convictions and offences. Where we seek this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment. We will not use your data for any purpose other than the recruitment exercise for which you have applied.

Data retention

Your information will be shared internally to a limited degree for the purposes of the recruitment exercise. This includes with members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles. We will not share your data with third parties, unless your application for employment is successful and an offer of employment is made to you. We may then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.

If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the relevant recruitment process. At the end of that period, your data is deleted or destroyed.

Visitors to our website – Collection of personal data

Visitors to our website are generally in control of the personal data shared with us and personal data is collected only when the visitor volunteers it. We receive personal data (such as name, title, company address, email address, and telephone and fax numbers) from website visitors; for example, when an individual subscribes to updates from us. We collect standard internet log information and details of visitor behaviour patterns (in a way which does not identify anyone) and we may capture limited personal data automatically via the use of cookies on our website, including browser type and IP address. Please see our Cookies Policy below for more information.

We ask that you do not provide sensitive information (such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation and criminal records) to us when using our website. If you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent to us collecting and using that information in the ways described in this privacy notice at the point where you choose to disclose this information.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at the point of collection (or as obvious from the context of the collection). Typically, personal data is provided to:

• register for certain areas of the site;
• subscribe to updates;
• request further information;
• register a CV.

Personal data may be used by us to:

• administer and manage our website;
• aggregate data for website analytics and improvements;
• monitor and enforce compliance with our terms and conditions of use of our website;
• compile a mailing list database
• distribute requested reference materials.

KAZ Minerals uses industry-standard efforts and takes reasonable precautions to safeguard information obtained from our online visitors against unauthorised access and use, and we periodically review our security measures. Our website does not collect or compile personal data for dissemination or sale to third parties for marketing purposes or host mailings on behalf of third parties but we may disclose your personal data where necessary to cooperate with law enforcement inquiries and third parties to enforce their intellectual property or other rights.

Data retention

Personal data collected via our website will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual). KAZ Minerals may retain certain information on file in order to resolve disputes or issues. Upon request, your information will be removed from our database.

To make this request, please email dataprotectionleader@kazminerals.com.

Changes to this privacy notice

We recognise that transparency is an ongoing responsibility so we will keep this privacy notice under regular review. This privacy notice was last updated on 25 May 2018.

Data controller and contact information

The data controller is KAZ Minerals Limited, a private limited company, registered in England under company number 05180783 with its registered office address at 7th Floor, 83 Victoria Street, London SW1H 0HW.

If you have any questions about this privacy notice or how and why we process personal data, please contact us at: Data Protection Leader, KAZ Minerals, 7th Floor, 83 Victoria Street, London SW1H 0HW. Email: dataprotectionleader@kazminerals.com. Phone: 020 7901 7800.

KAZ Minerals cookies policy

This policy applies to our use of ‘cookies’ in connection with the KAZ Minerals (“we”, “us”, “our”) website (“website”, “www.kazminerals.com”).

Our website uses small text files called ‘cookies’, which are placed on website users’ computers to assist in personalising and enriching browsing experience by displaying content that is more likely to be relevant and of interest to the user. By continuing to browse our website without adjusting your browser settings to block cookies (for information about how to do this please see below Accept or Block Cookies), you are agreeing to our use of cookies.

Cookies must be accepted in order to register on our website and some functionality in the website may be impaired if cookies are disabled. After termination of the visit to our website, the cookie can be deleted from the user’s system if preferred.

How we use cookies

The ways in which we use cookies on our website are detailed below. Cookies are used to collect information about how visitors use our website and we use the information to compile reports and to help us to improve the website.

‘Session’ cookies remain in your browser during your browser session only, i.e. until you leave the website.

‘Persistent’ cookies remain in your browser after you leave the website (unless deleted by you).

Accept or block cookies

You can block any cookies from any website by activating the settings on your browser that allow you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit https://www.aboutcookies.org/.

If you share the use of a computer, accepting or rejecting the use of cookies may affect all users of that computer.